Social media guidelines for Registered Medical Practitioners

The National Medical Commission has proposed the Code of Medical Ethics which is a self-regulatory set of guidelines for registered medical practitioners, reflecting their professional as well as social expectations. The proposed draft regulations are based on the basic ethical principles including beneficence, empathy, non-maleficence, respect for patient autonomy and confidentiality, integrity, honesty, and justice. The NMC has invited comments from the public and experts/stakeholders/organisations for the proposed regulations.

NMC code of ethics is not intended to establish legal or clinical standards in practice but to provide a set of ethical guidelines according to which the doctor is expected to practice as a medical professional. Ethical guidelines must be differentiated from laws, as ethical standards expected of the medical professional may sometimes exceed legal requirements.

“Med Dr.” prefix

According to the draft code of ethics, all Registered Medical Practitioners (RMPs) who practice modern medicine and are registered under NMC Act, 2019, can use Medical Doctor (Med Dr.) as a prefix before their names. This will help them distinguish from people of other backgrounds like researchers, scientists and professionals who practice other systems of medicine.

Social media guidelines for RMPs

1. RMPs can provide information and announcements on social media. However, the information should be factual and can be verified. The information should not be misleading or deceptive, nor should it exploit the patient’s vulnerability or lack of knowledge. 
2. RMPs should avoid discussing the treatment of patients on public social media or prescribing medicine to patients on the public social media platform. If a patient approaches doctors through public social media, the doctor should guide the patient toward a telemedicine consultation or in-person consultation as the situation warrants. 
3. RMPs should not post patients’ photographs or scan images (ct/pet scans) on social media. Once an image is posted in social media, it becomes data that is owned by the social media company or the general public.
4. RMPs behaviour on social media towards his colleagues should be guided by general principles of medical ethics on professional behaviour.
5. RMPs should not directly or indirectly indulge in the practice of purchasing “likes”, “followers”, or paying money so that search algorithms lead to their name being listed at the top or registering on software programs(apps) that charge fees for higher ratings or soliciting patients.
6. RMPs should not request or share patients’ testimonials or recommendations or endorsements or reviews in social media.
7. RMPs should refrain from sharing images of healed/cured patients, or surgery/procedure videos or images displaying impressive results under any circumstances.
8. RMP is allowed to share educational material for the information of the general public. However, communication should be limited to the expertise of the RMP.
9. RMP’s webpage should also follow the same guidelines as above.
10. On social media, RMPs should refrain from boundary crossings or violations and conduct themselves with dignity and decorum.

Guidelines on Advertisements

1. An RMP is permitted to make a formal announcement in any media (print, electronic or social) within 3 months regarding the following: (1) On starting practice (2) On change of type of practice (3) On changing address (4) On temporary absence from duty (5) On resumption of practice (6) On succeeding to another practice (7) Public declaration of charges. 
2. An RMP or any other person including corporate hospitals, running a maternity home, nursing home, private hospital, rehabilitation centre, or any type of medical training institution, etc. may place announcements in the lay press, but these should not contain anything more than the name of the institution, type of patients admitted, kind of training and other facilities offered and the fees. (Guidelines on social media conduct).
3. An RMP is allowed to do public education through media without soliciting patients for himself or the institution.

RMPs must ensure that any platform they associate with must comply the following guidelines –

1. RMPs shall not participate in telemedicine platforms that provide ratings by patient or others including reviews, advertisements, and promotions of RMPs by any means. (manipulation of algorithms/search engines etc). Advertising of RMPs is not allowed by anybody under any pretext. 
2. Technology platforms (Mobile Apps, Websites etc.) providing telemedicine services to consumers shall be obligated to ensure that the consumers are provided services and are consulting with RMPs who are duly registered with the National Medical Register or their respective State Medical Councils and comply with their relevant provisions and laws amended from time to time. 
3. The Platform must provide the Name, Qualifications (Graduate and Post-graduate with Super-specialty qualifications if any), Registration Number, Contact details (current Mobile numbers and e-mail addresses) of every RMP listed on their platform. The contact details of the RMPs, however, should not be displayed to the public or shared, except with the patient being consulted. 
4. The onus of ensuring that all the information regarding the RMP and all their qualifications that have been mentioned on their portal have been authenticated and are registered with the National Medical Register or their respective State Medical Councils rests wholly on the Owners and Administrators of the Technology Platform. 
5. In the event of non-compliance with these guidelines or infringement of the existing laws applicable to the provision of services provided by the Technology Platform, or if complaints against the Technology Platform are received by the NMC, appropriate action including legal action may be initiated against the Technology Platform by the NMC. 
6. Technology platforms based on Artificial Intelligence/Machine Learning are not allowed to counsel the patients or prescribe any drugs to a patient. Only RMPs are entitled to counsel or prescribe and have to communicate directly with the patients in this regard. While new technologies such as Artificial Intelligence, Internet of Things, advanced data science-based decision support systems etc. could assist and support the RMP on patient evaluation, diagnosis or management, the final prescription or counselling has to be directly delivered by the RMP. 
7. Technology Platform must ensure a proper grievance redressal mechanism for end users of their services. 
8. In case any specific Technology Platform is found to violate these guidelines or any applicable existing laws applicable to them, the EMRB/NMC may designate the Technology Platform as blacklisted, and no RMP may then use that platform to provide telemedicine. 
9. Technology platforms based on Artificial Intelligence/Machine Learning are not allowed to counsel the patients or prescribe any drugs to a patient. Only RMPs are entitled to counsel or prescribe and have to communicate directly with the patients in this regard. While new technologies such as Artificial Intelligence, Internet of Things, advanced data science-based decision support systems etc. could assist and support the RMP on patient evaluation, diagnosis or management, the final prescription or counselling has to be directly delivered by the RMP. 

Note: The words ‘must’, ‘shall/should’ and ‘may’ are used purposefully in these guidelines and indicate the degree of obligation that the doctor has to follow the guidelines. The word ‘must’ indicates a higher level of commitment and obligation required of the doctor, while in the case of ‘shall/should’ the level of obligation is less and there could be room for individual judgement.

Reference: NMC RMP REGULATIONS 2022 Draft