The National Network for Children, together with the “Community BRIDGES” Association, has submitted an opinion on the draft Ordinance on the conditions, procedures, criteria and specifics for providing medical care from a distance (so-called telemedicine), published by the Ministry of Health for public consultation.
The draft ordinance aims to create a legal framework for the provision of remote medical services, focusing on wider access to healthcare, making it easier for patients, and enabling continuous monitoring of their health status. While we acknowledge the legitimacy of these goals, in this opinion we express specific concerns and propose improvements to ensure that telemedicine is implemented in an effective, accessible and inclusive way.
A key concern is the requirement that telemedicine be provided exclusively through the National Health Information System (NHIS). The NHIS should be one of the possible options, not the only one. Such a monopoly could result in risks of limiting patients’ access to the system and, consequently, their ability to receive remote medical services.
At present, the application of a multidisciplinary approach in patient care is limited – the NHIS does not provide specialists with access to the patient’s full medical history.
Another serious limitation is the inability to establish telemedicine connections with foreign medical teams. Such consultations are crucial for patients referred for treatment abroad or for those needing a second opinion on complex medical cases. Restricting the system to NHIS effectively excludes the possibility of real-time collaboration between Bulgarian and foreign specialists, which contradicts the very purpose of telemedicine.
The ordinance provides for signing informed consent, but it is unclear how this will be done in an online environment – whether only through a qualified electronic signature (QES), and how access will be guaranteed for people who do not possess one.
Additionally, the high technical requirements for healthcare facilities and individual practices – such as certified equipment, backup power supply, etc. – could prove to be an insurmountable barrier for small practices, especially in remote or vulnerable areas.
The NNC and the “Community BRIDGES” Association propose:
-
Expanding the possibility to provide telemedicine services through alternative platforms and technologies beyond the NHIS;
-
Establishing regulations for access to the patient’s medical record for all specialists involved in their care;
-
Introducing a more flexible informed consent procedure, including options for signing without a QES;
-
Adjusting technical equipment requirements so they do not limit access to telemedicine for small practices;
-
Clearly regulating the levels and pricing of medical services provided remotely.
Telemedicine is undoubtedly an important step towards modernising the healthcare system in Bulgaria. To achieve its real goal – easier, timely and equitable access to healthcare – it must be regulated in a way that takes into account the realities of the system, the needs of patients, and the capacities of medical professionals.
The full text of the opinion is available HERE.
