Telehealth centre or platform: which are you building?

This is the most common misunderstanding. DHA limits the role of a telehealth platform to providing an approved technological tool. A platform licence does not allow you to deliver clinical services, operate as a healthcare provider, or recruit or contact healthcare professionals to deliver services through the platform.

So if your business plan is "we hire doctors and patients book them in our app", a platform alone will not cover it. You also need a licensed facility. Services can only be offered through a DHA-licensed facility, and the physicians providing them must work through one of the licence categories.

The cleanest structures we see are these. Which one fits depends on your business, and DHA has the final say on any model.

• Your own centre: you hold a standalone telehealth centre licence, employ the physicians and use approved technology.
• Your own clinic with an add-on: an existing clinic or hospital adds telehealth to its licence.
• A technology business: you hold the platform approval and sell access to facilities that hold their own licences and clinicians.

Under the standard, every DHA-licensed facility providing telehealth has to:

• Employ the minimum number of physicians set by DHA's licensing rules
• Keep medical liability or malpractice insurance in place for as long as it provides telehealth
• Use equipment, devices and technologies approved by the Ministry of Health and Prevention (MOHAP)
• Run a physician-led service, with nurses and allied professionals working under the treating physician's direction
• Get telehealth accreditation within 24 months of initial licensure, from a body such as QAI, EIAC, JCI, URAC or NCQA
• Write policies covering scope, patient selection, consent, prescribing protocols, records, privacy, referral, incidents, quality, business continuity, emergencies, equipment and security

DHA's licensing manual describes a telehealth centre as a facility that uses telecommunications technologies to enable safe, direct communication between patients and practitioners, so they can assess and treat. HealthcareSetup UAE covers the licence itself in its guide to DHA telemedicine licence requirements.

Any telehealth platform, for in-house or commercial use, must be assessed and approved by DHA through its health facility licensing section before it goes live. It also needs:

• Legal representation in Dubai, with a relevant trade licence
• An assigned business technical director
• Technical support for physicians and patients, with a defined escalation matrix
• Communication channels approved by the UAE's Telecommunications and Digital Government Regulatory Authority (TDRA)
• Data held to the UAE's health data law, on UAE-based servers
• HIPAA and ISO 27001 compliance certification, and possibly HITRUST or SOC 2 for certain conditions

Changes to its core functions, data management or ownership must be reported to DHA and approved. Our guide to platform and data rules goes through the technical side.

Whichever structure you pick, DHA excludes these from telehealth:

• Emergency cases that need immediate life-saving intervention or referral
• Prescribing narcotic, controlled or semi-controlled medication
• Platforms used for face-to-face in-person consultation

Telepharmacy has its own definition too. DHA says it covers dispensing prescribed medication only, and does not include vending machines, delivery services, online pharmacy or non-prescription medication. If your model depends on delivering medicines, get that part checked separately.

Any advertising must comply with MOHAP's medical advertising requirements and DHA's standards for medical advertising on social media. Pharmareg UAE has a detailed reading of the version 4 standards.