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What a Digital Prescription Must Carry in India

Team CareZenix
Team CareZenix

A prescription written during a teleconsultation is a legal document, and what it has to contain is set out more precisely than most practices realise. The rules are also not where people go looking for them. What follows is taken from the Telemedicine Practice Guidelines themselves, not from a software vendor’s summary of them.

Which rulebook you are actually under

The Telemedicine Practice Guidelines were notified on 25 March 2020 by the Board of Governors in supersession of the Medical Council of India. They are not a separate code. They are an integral part of the Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002, which is why a breach is professional misconduct rather than a paperwork slip.

There is a live source of confusion here worth clearing up. The National Medical Commission notified the Registered Medical Practitioner (Professional Conduct) Regulations, 2023 in August 2023, and then kept them in abeyance within weeks, after the objections to mandatory generic prescribing. The 2002 regulations still govern. If you have been waiting for the 2023 rules to bite, they have not, and a fair amount of clinic software copy still assumes otherwise.

What the prescription format asks for

Annexure 2 of the guidelines carries a sample prescription format. It is a suggested format rather than a form you are obliged to copy, but it is the clearest statement of what the regulator expects to see on the page, and a prescription missing several of these fields is difficult to defend afterwards.

The practitioner’s block, at the head:

  • Registered medical practitioner’s name
  • Qualification
  • Registration number
  • Address
  • Contact details, email and phone number

The patient’s block:

  • Date of consultation
  • Name of patient
  • Age and gender
  • Address
  • Height, weight and LMP, wherever applicable

The clinical body: chief complaints, relevant points from history, examination or lab findings, suggested investigations, and against them the diagnosis or provisional diagnosis. Then the Rx itself, where each line is the name of the medicine in capital letters with the generic name, followed by drug form, strength, frequency of administration and duration. Below that, special instructions, and the practitioner’s signature and stamp.

The format also carries a footnote at the very bottom: a line stating that the prescription was generated on a teleconsultation. It is easy to leave out and it is part of the format.

Worth noticing: capital letters and the generic name are already in the 2020 sample format. That requirement is not waiting on the 2023 regulations.

The three things most often left off

Age, asked explicitly. Section 3.2.3 requires the practitioner to explicitly ask the patient’s age before issuing a prescription, and to seek age proof where there is any doubt. If the patient is a minor, the teleconsultation is allowed only where the minor is consulting along with an adult whose identity has been ascertained.

The registration number, everywhere. Section 3.2.5 says the registration number goes on prescriptions, the website, electronic communication including WhatsApp and email, and receipts. Most clinics get it onto the prescription and nowhere else.

The diagnosis. Section 3.7.4 is blunt about this: prescribing medicines without an appropriate diagnosis or provisional diagnosis amounts to professional misconduct. An empty diagnosis box is the single most common gap in a teleconsultation prescription.

What you may prescribe, and over which mode

The guidelines put medicines into four groups, and which group a drug sits in decides both whether you can prescribe it and over which mode of consultation.

  • List O, any mode, first consult or follow-up. Common over-the-counter medicines: paracetamol, cough lozenges, ORS packets, syrup zinc, iron and folic acid, vitamin D, calcium. Plus anything the government notifies during a public health emergency, the example given being chloroquine for malaria control in a notified endemic region.
  • List A, video for a first consultation, any mode for a refill. Medicines whose diagnosis can reasonably be made on video: clotrimazole, mupirocin, calamine and benzyl benzoate for skin, ciprofloxacin drops for conjunctivitis, ear drops. And refills for chronic illness: enalapril or atenolol for hypertension, metformin or glibenclamide for diabetes, a salmeterol inhaler for asthma.
  • List B, any mode, follow-up only. Add-on medicines that optimise an existing regimen, such as a thiazide diuretic added to atenolol, or sitagliptin added to metformin.
  • Prohibited list, never, in any mode and in any type of consultation. Medicines in Schedule X of the Drugs and Cosmetics Act and Rules, and any narcotic or psychotropic substance under the Narcotic Drugs and Psychotropic Substances Act, 1985.

Injectables sit outside this grid. They can be prescribed only where the consultation is between one practitioner and another, or in certain circumstances to a health worker who will administer them, with the exception of follow-up medicines that are only available as injections, such as insulin, low molecular weight heparin and vaccines.

First consult or follow-up, and why the difference matters

List B is follow-up only, so the classification is not academic.

It counts as a first consult if the patient is consulting you for the first time, or more than six months have passed since the previous consultation, or the patient has consulted you before but for a different health condition.

It counts as a follow-up if the patient is consulting the same practitioner within six months of their previous in-person consultation, for continuation of care of the same condition. It stops being a follow-up the moment new symptoms appear outside the spectrum of that condition, or where you do not recall the context of the earlier treatment and advice.

How the prescription has to reach the patient

Section 3.6.4.2 allows a photo, scan or digital copy of a signed prescription, or an e-prescription, sent to the patient by email or any messaging platform. WhatsApp is squarely inside that. The official FAQ published alongside the guidelines also answers the printout question directly: no printout is needed, an e-prescription that complies with the guidelines is sufficient.

One condition attaches. If you transmit the prescription directly to a pharmacy rather than to the patient, you must have the patient’s explicit consent, and the patient keeps the right to have the medicines dispensed at any pharmacy of their choice.

Consent for the consultation itself is simpler than people expect. If the patient initiates the teleconsultation, consent is implied. Explicit consent is needed only where a health worker, another practitioner or a caregiver starts it, and it can be recorded in any form, including the patient saying so on the call, as long as you record it in the patient record.

What you are required to keep

The FAQ is specific. Keep a log or record of the telemedicine interaction: phone logs, email records, chat or text records, video interaction logs. Keep the patient records, reports, documents, images and diagnostics used in the consultation. And where a prescription was shared, keep prescription records exactly as you would for an in-person consultation.

This is the part clinics tend to run informally, with prescriptions sitting in a WhatsApp thread and nowhere else. If you are tightening this up, our guide to patient data management for clinics covers how the records themselves should be kept.

What this means for your prescription template

If your prescription is a Word file or a printed pad, the gaps are predictable. The registration number reaches the prescription but not the WhatsApp message it goes out on. The teleconsultation footnote is missing. The diagnosis box is blank because it was faster to leave it. The medicine is written by brand alone.

Software helps here only to the extent that it enforces the fields rather than offering them. If you are comparing options, our guide to software for doctors in India covers what else to look at.

CareZenix generates prescriptions carrying the clinic’s own name and the doctor’s registration number, with fields for the generic name, form, strength, frequency and duration, and sends them to the patient on WhatsApp with SMS as a fallback. You can see how prescriptions work on the features page. What it will not do is decide what is lawful for you to prescribe in a given consultation. That judgement stays with the practitioner, which is exactly where the guidelines put it.

Read the source

This is a summary written for practising doctors, not legal advice, and the medicine lists can be amended from time to time by the Commission and the Ministry. The Telemedicine Practice Guidelines and the FAQ issued with them are short, and they are the documents any dispute will be read against. If you consult remotely at all, they are worth an hour.

Related reading

Frequently Asked Questions

Insights and details about this topic.

Yes. The Telemedicine Practice Guidelines allow a photo, scan or digital copy of a signed prescription, or an e-prescription, to be sent to the patient by email or any messaging platform, and WhatsApp falls inside that. Remember that the registration number has to appear on electronic communication as well, not only on the prescription itself.

No. The FAQ published alongside the guidelines answers this directly: an e-prescription as specified in the guidelines is sufficient, provided it complies with what the guidelines require.

The suggested format in Annexure 2 asks for the practitioner name, qualification, registration number, address and contact details; the date of consultation; the patient name, age, gender and address, with height, weight and LMP where applicable; chief complaints, relevant history, examination or lab findings and suggested investigations; the diagnosis or provisional diagnosis; each medicine in capital letters with the generic name, form, strength, frequency and duration; special instructions; the signature and stamp; and a line noting that the prescription was generated on a teleconsultation.

No. Medicines listed in Schedule X of the Drugs and Cosmetics Act and Rules, and any narcotic or psychotropic substance under the Narcotic Drugs and Psychotropic Substances Act, 1985, are on the prohibited list. They cannot be prescribed in any mode of teleconsultation or in any type of consultation.

A follow-up consultation runs for six months from the previous in-person consultation, for continuation of care of the same condition. Past six months it counts as a first consult again, and so does any consultation where new symptoms appear outside the spectrum of that condition.

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