Physiotherapy teleconsultations - legality and documentation

Ms Aleksandra runs a practice in a small town, and some of her patients are people who moved abroad for work but want to keep following her exercise programme under her supervision. She started running video consultations. After a few months, though, she began to wonder: "Is telerehabilitation even legal? Am I keeping records correctly? Am I breaching GDPR by recording these calls?"

Physiotherapy teleconsultations are an increasingly popular form of service, but they still raise questions. In this article we'll explain whether they're legal, what their limits are, how to document a tele-visit, and what to keep in mind regarding GDPR and billing.

Are physiotherapy teleconsultations legal?

Yes. Health services provided remotely - via IT communication systems - are permitted under the Act on Medical Activity, which explicitly allows services to be provided through communication systems as well. Telemedicine, including telerehabilitation, is a recognised form of service provision.

What matters is understanding the limits of this format. Physiotherapy teleconsultations work well for:

• Consultation and patient interview
• Instruction and correction of exercises
• Patient education and prevention
• Monitoring progress on a home programme
• Reviewing imaging results

They cannot replace activities requiring direct contact - manual therapy, palpation, or physical treatments. Responsibility for judging whether a given case is suitable for a teleconsultation rests with the physiotherapist.

Conditions for a legal teleconsultation

For a tele-visit to be lawful, you need to meet several conditions:

Condition	Explanation
Business registration	A valid RPWDL entry and the right to practise the profession
A secure communication channel	An encrypted connection, GDPR-compliant
Patient consent	To the teleconsultation format and to data processing
Medical records	Kept the same way as for an in-person visit
OC insurance	Covering telemedicine services
Identity verification	Confirmation you're speaking with the correct patient

Documenting a tele-visit

A teleconsultation doesn't exempt you from the documentation duty arising from the Act on Medical Activity and the regulation on medical documentation. A tele-visit record should include:

• The patient's and physiotherapist's details
• A note that the service was provided as a teleconsultation (and via which channel)
• The date and time
• A description of the interview, recommendations, and exercise instruction
• The plan for further action
• A note on whether an in-person visit was recommended, if applicable

Verifying the patient's identity

In a teleconsultation you don't see an ID card. Confirm identity, e.g. by asking for verification details (date of birth, previous visits), and note the verification method in the record.

GDPR in telerehabilitation

A tele-visit involves processing a special category of data (GDPR Article 9) remotely - the risk of a leak is higher. You need to ensure:

• A secure, encrypted messaging tool - not an ordinary, private chat app; choose a solution backed by a data processing agreement
• A data processing agreement with your video platform provider
• Consent to the teleconsultation format and to data processing in that form
• Recording rules - you only record with the patient's explicit consent; without it, you don't record
• A location for the call that ensures discretion (not a café, not an open-plan office)

[Solo] Example - solo practice: You conduct tele-visits from your practice, over an encrypted medical platform with a signed data processing agreement. At the first tele-visit, the patient signs an electronic consent to this format. You don't record sessions - you note the course of the call in the record.

[Group] Example - group practice: Several therapists run telerehabilitation. The practice chooses one platform for everyone, with a central data processing agreement, and sets the rule: calls take place from closed consultation rooms, never from home over a private messaging app.

OC insurance and teleconsultations

Check your policy to see whether your OC (professional liability) insurance covers remotely provided services. Some policies apply only to in-person services. Inform your insurer that you run tele-visits and get written confirmation of the scope of coverage.

Billing and cash registers

Payment for a teleconsultation is usually made by bank transfer or BLIK (Poland's instant mobile payment system), which simplifies documentation. The obligation to record sales on a fiscal cash register applies to physiotherapists, as a rule, for remote services too - for cashless payments, check the current scope of exemptions with your accountant, as some bank-transfer transactions may be exempt from the cash register requirement under certain conditions.

When not to run a teleconsultation

A responsible physiotherapist knows that not every case is suitable for a remote consultation. Skip the teleconsultation and invite the patient to the practice (or refer them to a doctor) when:

• The patient is presenting for the first time with an unclear problem requiring a physical examination
• Warning signs ("red flags") appear - sudden severe pain, neurological symptoms, fever
• Palpation or a range-of-motion assessment requiring physical contact is necessary
• Connection quality prevents a reliable assessment of the patient

The decision to skip a teleconsultation and refer the patient to an in-person visit is worth noting in the documentation - it's evidence of professional diligence.

Benefits of telerehabilitation

Despite its limits, teleconsultation has real benefits worth communicating to patients:

• Continuity of therapy - a patient who has moved away or is ill doesn't interrupt their exercise programme
• Accessibility - patients from areas far from the practice gain access to care
• Time savings - no travel needed for follow-up consultations
• Education in a home setting - you can correct exercises in the patient's actual environment

Well-run telerehabilitation complements in-person visits rather than replacing them. An increasingly common combined model looks like this: a first in-person visit with a full examination, followed by some follow-up and instructional consultations remotely. This arrangement preserves the safety of a full patient assessment while giving them convenience and continuity of therapy between practice visits.

Frequently asked questions

Can a physiotherapist legally offer teleconsultations?

Yes. The Act on Medical Activity permits services to be provided via IT communication systems. Telerehabilitation is legal for consultations, exercise instruction, education, and progress monitoring. It cannot, however, replace activities requiring direct contact, such as manual therapy or palpation.

Do I need to keep documentation for a tele-visit?

Yes, under the same rules as an in-person visit. In the record you additionally note that the service was provided as a teleconsultation, through which channel, and how the patient's identity was verified.

Can I record tele-visits?

Only with the patient's explicit, prior consent. A recording contains special-category data, so without consent, recording isn't permitted. If you don't have consent, document the course of the call in narrative form in the record.

Which platform should I use for teleconsultations?

Choose a solution with encryption and the ability to sign a data processing agreement. Private, consumer messaging apps without such an agreement don't meet GDPR requirements for medical data.

CTA: Want a ready-made teleconsultation consent template, a GDPR notice for telerehabilitation, and a procedure for documenting tele-visits? The STANDARD package includes a full set of documents adapted to a modern physiotherapy practice. See FizjoReady packages →

Related articles:
- GDPR in a physiotherapy practice - a practical guide
- Patient consent to a physiotherapy procedure - template
- Medical records in physiotherapy - what's mandatory