Executive Summary
Australia's telehealth landscape was permanently expanded following the COVID-19 public health response, with bulk-billed and privately billed telehealth consultations now embedded in Medicare Benefits Schedule (MBS) item structures. In parallel, Schedule 4 peptide prescribing — particularly of GLP-1 receptor agonists for weight management — has grown rapidly, with a significant proportion of new prescriptions originating from telehealth consultations.
This convergence is under-regulated relative to its clinical risk profile. The Coalition for Better Health holds that the appropriate response is proportionate, evidence-led reform that preserves the legitimate access benefits of telehealth while introducing prescriber accountability mechanisms matched to the risk profile of Schedule 4 peptide therapies.
This brief outlines the current framework, identifies four specific gaps, and proposes reform priorities for consideration by the Department of Health and Aged Care, the Therapeutic Goods Administration, the Pharmacy Board of Australia, and state and territory health departments.
The Current Australian Framework
Schedule 4 ("Prescription Only Medicine") in the Standard for the Uniform Scheduling of Medicines and Poisons (the Poisons Standard) requires a prescription from a registered health practitioner with prescribing authority. The key components of the current framework as it intersects with telehealth are:
Prescriber registration. Only practitioners registered with the Australian Health Practitioner Regulation Agency (AHPRA) holding general or specialist registration and appropriate prescribing rights may issue Schedule 4 prescriptions. This includes general practitioners, specialists, and increasingly endorsed nurse practitioners within scope.
Medicare telehealth items. The MBS includes telehealth equivalents for most face-to-face consultation items, with both video and phone options at different rebate rates. Continuity-of-care provisions require an established patient relationship for many bulk-billed telehealth services, though these provisions are inconsistently applied to fully privately billed consultations.
Real Time Prescription Monitoring (RTPM). State-level RTPM systems — SafeScript (Victoria), CanberraScript (ACT), PRP (other jurisdictions) — capture controlled medicine prescriptions. RTPM coverage of Schedule 4 peptides is inconsistent across jurisdictions, and notably most GLP-1 receptor agonists are not currently within RTPM scope despite their increasing prescribing volume and emerging safety considerations.
TGA enforcement scope. The TGA regulates the supply, advertising, and quality of therapeutic goods, but clinical practice oversight rests with AHPRA and the relevant National Boards, not with the TGA. This means that questionable prescribing practices for legitimately TGA-approved products fall into a regulatory seam.
For the foundational regulatory framework for peptides specifically, see our prior briefs on TGA regulation of peptides in Australia and on compounding pharmacy regulation under the TGA.
The Telehealth Permanence Question
The MBS telehealth item structure was made permanent in 2022, following the temporary expansion during the COVID-19 response. This was the correct decision on public-interest grounds: telehealth reduces barriers to care, particularly for patients in rural and remote areas, patients with mobility constraints, and patients in low-supply specialty cohorts.
The Coalition's earlier brief on telehealth permanency advocacy sets out the access case in detail. The question this current brief addresses is not whether telehealth should exist as a permanent care modality — it should — but rather whether the regulatory framework around telehealth is calibrated for the specific risk profile of Schedule 4 peptide prescribing.
That calibration question has not been adequately addressed in the policy literature to date.
Asynchronous vs Synchronous Consultations
A central regulatory question is whether asynchronous consultations — questionnaire-driven prescribing without a real-time video or phone interaction — satisfy the clinical assessment requirements for Schedule 4 prescribing.
The Medical Board of Australia's Guidelines for technology-based patient consultations indicate that prescribing without a real-time consultation is generally inappropriate, with limited exceptions for established patients receiving repeat prescriptions for established conditions. However, enforcement of this guidance against asynchronous-only prescribing services has been limited in practice.
The clinical considerations are not trivial:
- Weight assessment for GLP-1 prescribing requires accurate baseline body composition and trajectory data
- Cardiovascular history, especially history of medullary thyroid carcinoma or MEN-2 syndrome (boxed warning for GLP-1 class), requires direct verification rather than self-report alone
- Gallbladder history and pancreatitis risk factors carry weight in informed consent
- Concomitant medications with relevant interaction profiles must be reconciled
A questionnaire alone, without a synchronous clinician interaction, raises material concern about the depth of clinical assessment underpinning Schedule 4 peptide prescriptions issued through this modality.
Risk Profile: GLP-1 Telehealth Prescribing Data
Direct Australian data on telehealth GLP-1 prescribing volume, prescriber concentration, and clinical outcomes is sparse and inconsistently reported. International data from comparable jurisdictions suggests:
- Telehealth-issued GLP-1 prescriptions account for a substantial and growing share of new GLP-1 prescriptions
- A small subset of telehealth providers issue a disproportionately high volume of prescriptions per practitioner
- Adverse event reporting from telehealth-prescribed GLP-1 use is consistent with face-to-face prescribing populations on most measures, but monitoring follow-up rates appear lower for telehealth-issued prescriptions
The absence of robust Australian-specific data on these questions is itself a policy gap. The Department of Health and Aged Care should consider commissioning a structured analysis of telehealth GLP-1 prescribing patterns and outcomes using PBS, MBS, and adverse event data linkage.
For background on the wider GLP-1 access question, see GLP-1 medication shortage policy 2026 and medicare-PBS obesity treatment reform.
Compounded Peptide Telehealth: A Specific Gap
The intersection of telehealth, compounded peptides, and Schedule 4 regulation is the area where current oversight is most ambiguous.
Compounded peptides — including GLP-1 agonists prepared by compounding pharmacies during periods of approved-product shortage — exist in a distinct regulatory category from registered therapeutic goods. The TGA's 2024 to 2025 enforcement actions narrowed the legitimate scope of compounded GLP-1 supply substantially, but the residual permitted compounding activity remains accessible through telehealth prescribing pathways.
This raises three specific concerns:
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Quality and identity verification — compounded peptides are not subject to the same batch-release testing as registered therapeutic goods. A telehealth-issued prescription for a compounded peptide places greater weight on the compounding pharmacy's quality systems than on regulatory oversight.
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Indication scope — compounded peptide prescribing through telehealth can drift toward off-label and research-context indications more readily than face-to-face prescribing, where direct clinical assessment provides a counterweight.
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Patient understanding of regulatory status — patients receiving a compounded peptide through a streamlined telehealth pathway may not understand the difference between a TGA-registered therapeutic good and a compounded preparation, with implications for informed consent.
The Coalition's earlier analysis of compounding pharmacy regulation under the TGA discusses the broader regulatory architecture; the telehealth dimension adds an additional access modality that current regulation does not directly address.
Comparative Frameworks: UK and US
The UK General Medical Council's guidance on remote consultations explicitly addresses prescribing for weight management, requiring assessment of body mass and history through synchronous consultation, verification of patient identity, and continuity-of-care arrangements. The Medicines and Healthcare products Regulatory Agency has taken enforcement action against several online weight-loss prescribing services that failed these standards.
The United States Ryan Haight Online Pharmacy Consumer Protection Act of 2008 imposed stricter requirements for controlled-substance telehealth prescribing, with COVID-era flexibilities now being progressively narrowed by the Drug Enforcement Administration. While the controlled-substance framing does not map directly to Australian Schedule 4 (which is broader and not exclusively about abuse potential), the principle of modality-specific prescribing requirements is relevant.
Australia has not yet adopted a structurally similar approach for Schedule 4 telehealth prescribing.
Reform Priorities
The Coalition for Better Health proposes the following four reform priorities for consideration:
1. Clarify Synchronous vs Asynchronous Standards
The Medical Board of Australia's Guidelines for technology-based patient consultations should be updated with explicit reference to Schedule 4 peptide prescribing, clarifying that first prescriptions for these medicines require a synchronous (video or phone) consultation with the prescribing practitioner. Asynchronous follow-up for established patients on stable therapy should remain permitted under defined conditions.
2. Mandate RTPM Coverage of Schedule 4 Peptides
State and territory real-time prescription monitoring systems should be expanded to include Schedule 4 peptides, with national consistency in scope. This would enable detection of:
- Doctor-shopping patterns across telehealth and face-to-face providers
- Prescribing concentrations (small numbers of high-volume prescribers)
- Co-prescription patterns with relevant interacting medicines
RTPM is an existing infrastructure investment. Expanding its scope is a marginal-cost reform with significant safety upside.
3. Audit Framework for High-Volume Telehealth Peptide Prescribers
AHPRA, in coordination with the Medical Board of Australia, should establish a structured audit framework for medical practitioners issuing high volumes of Schedule 4 peptide prescriptions through telehealth pathways. The audit should cover:
- Documentation of clinical assessment, including body composition baseline and cardiovascular history
- Verification of informed consent processes, especially for boxed-warning indications
- Continuity-of-care arrangements for monitoring and adverse event response
- Prescription patterns consistent with TGA-approved indications versus off-label use
This is not a restriction on telehealth prescribing — it is an accountability framework matched to the prescribing volume of the practitioner. The Coalition has set out broader thinking on practitioner accountability in our pharmacy scope of practice debate piece.
4. Defined Scope for Compounded Peptide Telehealth
The TGA, in coordination with the Pharmacy Board of Australia, should publish specific guidance on the intersection of telehealth prescribing and compounded peptide supply, addressing:
- When compounded peptide supply via telehealth is permissible (likely limited to documented approved-product shortage or specific clinical justification)
- Quality assurance requirements for compounding pharmacies receiving telehealth-originated prescriptions
- Informed consent standards specific to compounded preparations
- Reporting requirements for adverse events associated with telehealth-prescribed compounded peptides
This guidance currently exists only in fragmented form across multiple regulatory instruments. Consolidation would benefit prescribers, pharmacists, patients, and regulators.
Implementation Sequencing
The four reform priorities differ in implementation complexity:
| Reform | Complexity | Lead agency | Indicative timeline | |---|---|---|---| | Synchronous/async clarification | Low | Medical Board of Australia | 6 to 12 months | | RTPM scope expansion | Medium | State/territory health departments | 12 to 24 months | | Telehealth audit framework | Medium-High | AHPRA + Medical Board of Australia | 18 to 24 months | | Compounded peptide telehealth guidance | Medium | TGA + Pharmacy Board of Australia | 12 to 18 months |
A coordinated reform package would deliver the most coherent regulatory framework. A sequenced approach, beginning with the synchronous/asynchronous clarification, would deliver early risk reduction without prejudicing the longer-cycle reforms.
What the Coalition Is Not Advocating
For clarity, this brief does not advocate any of the following:
- Restriction of telehealth as a care modality
- Restriction of legitimate Schedule 4 peptide prescribing
- Reversal of the permanent MBS telehealth items
- Special restrictions on rural or remote telehealth access
- Penalties for individual patients accessing care through telehealth
The reform priorities are directed at prescriber accountability and regulatory clarity, not at patient access.
Conclusion
Australia has appropriately made telehealth a permanent component of healthcare delivery. The growth in Schedule 4 peptide prescribing — particularly of GLP-1 receptor agonists for weight management, and including increasing volumes of compounded peptide supply — has occurred faster than regulatory frameworks have adapted.
The Coalition for Better Health holds that proportionate reform — focused on clarifying assessment standards, extending real-time prescription monitoring, instituting audit frameworks for high-volume prescribers, and consolidating compounded-peptide guidance — would preserve the legitimate access benefits of telehealth while addressing the specific clinical and regulatory risks that this prescribing modality presents.
These reforms are within the existing authority of the relevant regulatory bodies. They do not require new legislation, only the deliberate use of existing regulatory levers in proportion to the clinical and policy stakes.
The policy question is not whether to act — the risk profile justifies action. The question is whether the action will be shaped deliberately, through coordinated reform of the kind outlined above, or whether it will arrive reactively, in response to harm events that are foreseeable from the current framework.