Standard 8 — Health & Migration
Criteria in this standard
8.2 — Digital Literacy and Device Access Barriers Are Actively Addressed
8.3 — Language and Communication Aids — Interpreters and Cultural Mediators
8.4 — Genuine Agency Is Respected, Not Treated as a Passive Technology Recipient
8.5 — Continuity Across Mobility Is Actively Supported Through Portable Records
8.6 — Evidence-Informed Care for Refugee and Migrant Populations
8.7 — Staff Reflective Practice, Bias Awareness, and Self-Care in Migration Contexts
8.8 — Digital Privacy Concerns Specific to Displaced Populations Are Genuinely Addressed
8.9 — Legal Status Diversity Recognition
8.10 — Care Is Documented and Provided Regardless of Immigration or Legal Status
People-Centred Care Adapted to Migration and Displacement Experience
Non-Negotiable
In plain terms: Care is genuinely adapted for refugee and migrant patients — recognising trauma, legal-status fears, and the barriers they face — not just delivered the same way as for everyone else.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Full | Full |
Why this matters
A refugee who has crossed a border on foot, lost family, and now fears deportation does not arrive at the telemedicine service as an ordinary patient. They may not disclose symptoms that could mark them as a burden. They may not return for follow-up because they moved or because the last clinic reported them. They may react to a physical examination with terror rooted in what was done to them before. Trauma-informed care means staff understand this, explain before touching, ask permission, avoid triggering procedures where possible, and never threaten legal consequences. It means the telemedicine service has decided that a person's migration status does not change their right to care — and staff know it.
What good looks like
- Care is genuinely, visibly adapted to migration and displacement history.
- Trauma-informed practice is actually applied, not just referenced.
- Providers demonstrate specific awareness of legal-status access barriers.
Common failure modes
- Care is delivered identically regardless of migration history.
- Trauma-informed practice exists only as a stated principle, not applied practice.
- Providers show no specific awareness of legal-status barriers.
Worked example
If you are starting from zero — do this first
- Ask refugee-serving organisations in your area what their clients say about your telemedicine service.
- Write one sentence: 'We do not ask immigration status and it does not affect care.' Post it.
- Arrange trauma-informed care training with an NGO that knows the population.
- Remove immigration document requests from registration.
Self-assessment questions
Evidence: Training record on migration-adapted care
Evidence: N/A — tested directly
Evidence: N/A — tested directly
Common reasons for a PARTIAL answer
- Adaptation happens for patients who disclose their history but isn't proactively considered otherwise. — Not every patient will volunteer this history unprompted, even when it is clinically relevant.
- Providers are aware of the principle but haven't received specific training on applying it remotely. — General awareness doesn't reliably translate into genuine practice adaptation without specific training.
- Adaptation is strong for the first consultation but isn't sustained across ongoing remote follow-up.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current practice for genuine adaptation to migration and displacement history. |
| Week 2 | Train providers specifically on trauma-informed, migration-adapted practice. |
| Week 3 | Build awareness of legal-status access barriers into standard practice. |
| Ongoing | Revisit adaptation as the ongoing patient relationship develops. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Migration-adapted care interview | Asks providers how they adapt practice specifically for a patient's migration and displacement history. |
| OBSERVE | Trauma-informed practice observation | Observes an actual consultation for genuine trauma-informed practice, not generic sensitivity. |
| DOCUMENT | Training content review | Reviews training materials for specific coverage of migration-adapted, trauma-informed care. |
Supervisor tips
- Ask a provider to describe a specific example of adapting care for a patient's migration history. — A real, specific example reveals genuine practice, not familiarity with the principle.
- Ask about continuity of care support specifically for patients without stable documentation. — This is where genuine adaptation is most tested.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Digital Literacy and Device Access Barriers Are Actively Addressed
Non-Negotiable
In plain terms: The service actively removes the barriers refugees and migrants face in using telemedicine — no smartphone, no data, no quiet place, no digital experience — with loaner devices, data support, partner sites, and hands-on help.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Adapted | Full |
Why this matters
Telemedicine assumes a smartphone, a data plan, a private space, and the skill to use an app. A refugee in a shelter, a migrant worker in shared housing, an elderly person who has never used video — each lacks one or more. 'Telemedicine is accessible' is true only for people who already have the means. Addressing barriers means: loaner devices; data credits or Wi-Fi access; partner sites (community centres, NGOs) with private rooms and equipment; a tech assistant who sets up the first call; phone-only options; and materials in the patient's language. The service that does not do this has excluded the people who most need it.
What good looks like
- Device and connectivity barriers are genuinely, actively assessed.
- Digital literacy support is genuinely offered where needed.
- A real alternative access method exists for unreliable technology access.
Common failure modes
- Barriers are assumed absent because a patient managed to connect for this visit.
- No digital literacy support is offered; independent navigation is assumed.
- No alternative exists for patients with unreliable technology access.
Worked example
If you are starting from zero — do this first
- Ask ten refugee patients what stopped them using the service.
- Partner with a community organisation for private rooms and devices.
- Assign someone to set up the first call with every new patient.
- Offer a phone-only option.
Self-assessment questions
Evidence: Access barrier assessment process
Evidence: Digital literacy support materials
Evidence: Alternative access method documentation
Common reasons for a PARTIAL answer
- Assessment happens at intake but isn't revisited as a patient's actual circumstances may change. — A patient's access reliability can genuinely change, particularly for a population with real mobility.
- Digital literacy support exists in the dominant local language but not in the patient's own language. — Genuine support needs to be usable in the language the patient actually understands.
- An alternative access method exists but isn't proactively offered, relying on the patient to request it.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current practice for genuine assessment of device and connectivity barriers. |
| Week 2 | Build digital literacy support materials in relevant languages. |
| Week 3 | Establish and proactively offer a genuine alternative access method. |
| Ongoing | Revisit access barrier assessment as patient circumstances change. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Barrier assessment review | Reviews the process for genuinely assessing device and connectivity barriers for this population. |
| DOCUMENT | Digital literacy support review | Reviews materials or processes genuinely supporting patients with lower digital literacy. |
| DOCUMENT | Alternative access review | Reviews the genuine alternative access method available for patients with unreliable technology access. |
Supervisor tips
- Ask how the service would identify a patient struggling with the platform who hasn't said so directly. — A specific, thoughtful answer reveals genuine, proactive attention, not reliance on the patient to report difficulty.
- Ask what alternative exists for a patient whose smartphone or data access is genuinely unreliable. — A specific, real answer reveals a genuine alternative, not an assumption everyone has adequate access.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Language and Communication Aids — Interpreters and Cultural Mediators
Non-Negotiable
In plain terms: Trained interpreters or cultural mediators are used for language-discordant consultations — never children, and family members only when there is truly no alternative.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Adapted | Full |
Why this matters
This is the refugee-specific counterpart of 8.3, and the stakes are higher. Refugee patients may be discussing torture, sexual violence, or mental illness — topics a family member cannot interpret and should not hear. A cultural mediator adds what an interpreter cannot: understanding of why a patient from a particular background may refuse a male examiner, may not disclose a symptom, or may interpret a question as a threat. Children must never interpret for parents: it exposes them to adult content, it distorts the information, and it places the child in an impossible position. Where the telemedicine service serves a refugee population, interpreter and mediator access is a core service, not an extra.
What good looks like
- Trained interpreters or cultural mediators are the default for language-discordant consultations.
- Providers confirm, without hesitation, that minors are never used to interpret.
- Family-member interpretation, when it happens, is reserved for genuinely low-risk situations only.
Common failure modes
- Ad hoc bilingual staff or family members are the default, with trained interpreters rarely engaged.
- A minor has been used to interpret, even occasionally.
- Family members interpret for high-risk situations like informed consent or bad news.
Worked example
If you are starting from zero — do this first
- Ask how the last ten refugee consultations were interpreted. Count how many used a child or a family member.
- Write the rule today: no children; family only as a last resort and never for sensitive topics.
- Recruit mediators from the main language groups — NGOs can help.
- Contract a phone service for other languages.
Self-assessment questions
Evidence: Interpreter engagement record
Evidence: N/A — tested directly
Evidence: N/A — tested directly
Common reasons for a PARTIAL answer
- Trained interpreters are engaged for scheduled consultations but not for urgent or same-day remote visits. — Risk doesn't scale down proportionally with how urgent or unscheduled an interaction feels.
- The no-minors rule is understood by providers but not consistently reinforced with support staff scheduling sessions. — A critical safeguard needs to be embedded across the whole team, not held only by the treating provider.
- Remote interpreter access exists but connection quality issues sometimes lead to reverting to a family member mid-session.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review recent language-discordant consultations for interpreter engagement patterns. |
| Week 2 | Establish reliable remote interpreter access, tested for connection quality alongside the platform itself. |
| Week 3 | Brief all staff on the firm exclusion of children as interpreters, without exception. |
| Ongoing | Audit interpreter use records for consistency. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Interpreter engagement review | Reviews records for evidence of trained interpreter or cultural mediator engagement. |
| ASK | Minor-interpreter policy check | Asks providers directly whether minors are ever used to interpret, and confirms understanding that this is never acceptable. |
| OBSERVE | High-risk situation check | Checks whether family-member interpretation, where it occurs, is confined to genuinely low-risk situations. |
Supervisor tips
- Ask staff directly whether a child has ever interpreted for a parent during a remote session. — A direct question often surfaces what a general policy question won't.
- Ask what happens if the remote interpreter's own connection fails mid-session. — This reveals whether a genuine backup exists, not reversion to an unqualified family member.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Genuine Agency Is Respected, Not Treated as a Passive Technology Recipient
Core
In plain terms: Refugee and migrant patients are treated as capable people who can learn and use telemedicine — supported, not assumed helpless or handed off to a family member.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | N/A | Full | Adapted | Full |
Why this matters
There is a paternalism that looks like kindness: assuming the refugee patient cannot use technology, cannot make decisions, needs a relative to speak for them. It strips the patient of agency and often of privacy. Respecting agency means: teaching the patient to use the platform themselves; speaking to them directly, through an interpreter, not to their relative; asking their preferences; involving them in decisions; and recognising that someone who crossed a continent can learn a video app. Support is offered; capability is assumed.
What good looks like
- Technology competence is genuinely assessed per individual, not assumed from population background.
- Communication genuinely respects patient agency, not a presumptive tone.
- Staff are specifically trained on this documented risk of over-generalizing incapability.
Common failure modes
- All patients from this population are assumed uniformly incapable with technology.
- Communication is presumptive or simplified based on the patient's background alone.
- No specific training addresses this documented stereotype risk.
Worked example
If you are starting from zero — do this first
- Watch three sessions with migrant patients. Who does the provider address?
- Require interpreters instead of family members.
- Do tech set-up with the patient, not the relative.
- Ask the patient how they want family involved.
Self-assessment questions
Evidence: N/A — tested directly
Evidence: N/A — tested directly
Evidence: Staff training on agency and stereotype avoidance
Common reasons for a PARTIAL answer
- Individual assessment happens for adult patients but assumptions persist more readily for older patients within this population. — Age within this population doesn't determine genuine technology competence any more than population background does.
- Staff avoid overtly presumptive language but subtly simplify explanations more than the individual patient's demonstrated understanding warrants. — Genuine respect for agency means calibrating explanation to the actual person, not a background-based default.
- Awareness of this concern exists informally but hasn't been specifically, formally trained.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current practice for genuine, individual assessment versus population-based assumption. |
| Week 2 | Train staff specifically on this documented stereotype risk and how to avoid it. |
| Week 3 | Build communication practices that calibrate to individual demonstrated competence. |
| Ongoing | Audit communication tone for continued respect of patient agency. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| OBSERVE | Individual assessment observation | Observes whether technology competence is genuinely assessed per patient, not assumed from population background. |
| OBSERVE | Communication tone observation | Observes provider communication for genuine respect of patient agency, not a presumptive, simplified tone. |
| DOCUMENT | Staff training review | Reviews training records for specific coverage of this documented stereotype risk. |
Supervisor tips
- Observe how a provider explains platform use to a patient from this population, if possible. — Direct observation reveals genuine, individually calibrated respect, not a presumptive default tone.
- Ask staff whether they've received specific training on avoiding this documented stereotype. — A specific, confident answer reveals genuine awareness, not an assumption good intentions are sufficient.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Continuity Across Mobility Is Actively Supported Through Portable Records
Non-Negotiable
In plain terms: When a displaced patient moves, the service gives them a portable record — a summary they hold, in a form that works anywhere — and keeps the connection going where possible.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Adapted | Full |
Why this matters
Telemedicine's advantage for displaced people is that it can follow them — a patient who moves from a shelter to a city to another country can, in principle, keep the same provider. In practice, licensure (2.4) may prevent that. The fallback is a portable record: a summary the patient holds (paper and digital), in their language and the destination's, covering diagnoses, medications, results, vaccinations, and the service's contact. Where licensure allows, care continues; where it does not, the record travels and a handover is attempted.
What good looks like
- A genuinely portable, patient-accessible record format is actively provided.
- The record is genuinely kept current, particularly near a known relocation.
- Patients genuinely know how to access and use their own record independently.
Common failure modes
- Records remain locked within this service's own system, not genuinely portable.
- The record becomes outdated, not reflecting the patient's actual, recent status.
- Patients remain dependent on requesting their own information from this service each time.
Worked example
If you are starting from zero — do this first
- Give every mobile patient a portable summary at every session.
- Make it a PDF on their phone and a print if possible.
- When they move, check licensure; continue or hand over.
- Follow up high-priority conditions at two weeks.
Self-assessment questions
Evidence: Portable record format documentation
Evidence: N/A — tested directly
Evidence: Patient record access instruction
Common reasons for a PARTIAL answer
- A portable record format exists but isn't proactively offered unless the patient specifically requests it. — A patient who doesn't know to ask shouldn't be less likely to receive genuine continuity support.
- The record is current at creation but isn't genuinely updated as the ongoing relationship continues. — Continuity value depends on the record reflecting the patient's actual, current status, not only their status at one point in time.
- Patients are given the record but not specific instruction on how to actually use or share it with a future provider.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current record practice for genuine portability versus system lock-in. |
| Week 2 | Establish a standard, portable, patient-accessible record format, proactively offered. |
| Week 3 | Build a process for keeping the record genuinely current, particularly near known relocations. |
| Ongoing | Confirm patients understand how to access and use their own record independently. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Portable record review | Reviews whether patients genuinely receive a portable, accessible record format. |
| DOCUMENT | Record currency review | Reviews whether the record is genuinely kept current, particularly near a known relocation. |
| ASK | Patient access interview | Asks a patient whether they know how to access and use their own portable record. |
Supervisor tips
- Ask a patient whether they have their own accessible copy of their health record, and whether they know how to use it. — A real, specific answer reveals genuine portability, not a record locked within the service's own system.
- Ask how the record is updated when a patient reports an upcoming relocation. — A specific, confident answer reveals genuine, proactive practice, not passive record-keeping.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Evidence-Informed Care for Refugee and Migrant Populations
Core
In plain terms: Staff use clinical guidelines specific to refugee and migrant health where they exist, know where evidence is thin, and adapt sensibly.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | N/A | Full | Adapted | Full |
Why this matters
Refugee health has specific evidence: screening for TB, hepatitis B, and parasites by region of origin; vaccination catch-up schedules; recognition of conditions rare in the host country; management of trauma-related mental illness. Applying host-country guidelines without adaptation means missing conditions the host population does not have and over-testing for ones the refugee population does not. Where evidence exists — WHO, UNHCR, national refugee health guidelines — staff should use it. Where it does not, they should know that, and adapt with judgment rather than guess.
What good looks like
- Staff are aware of and use population-specific evidence-informed guidelines where they exist.
- Staff can describe specific, genuine differences in this population's health needs.
- Practice is genuinely adapted where population-specific evidence indicates it should be.
Common failure modes
- General telemedicine guidelines are applied uncritically with no population-specific awareness.
- Staff cannot describe any specific way this population's needs differ.
- Awareness exists but doesn't translate into any actual practice adaptation.
Worked example
If you are starting from zero — do this first
- Find your national refugee health guideline, or the WHO/UNHCR one for your region.
- Compare it to what you currently do for refugee patients.
- Write a screening protocol based on the guideline.
- Brief clinicians and review annually.
Self-assessment questions
Evidence: Guideline awareness record
Evidence: N/A — tested directly
Evidence: N/A — tested directly
Common reasons for a PARTIAL answer
- Awareness exists for well-known differences but not for more specific or recent evidence. — Evidence in this area continues to develop, and awareness needs to stay genuinely current.
- Guidelines are known but not consistently applied under time pressure. — Consistent application under real conditions is what gives awareness genuine protective value.
- Evidence gaps are acknowledged but staff default to general population assumptions rather than flagging genuine uncertainty.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current awareness of population-specific evidence-informed guidelines. |
| Week 2 | Establish access to current, relevant guidelines for staff. |
| Week 3 | Train staff on specific, genuine population differences relevant to practice. |
| Ongoing | Refresh awareness as evidence in this area develops. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Guideline awareness review | Reviews whether staff have access to and awareness of population-specific evidence-informed guidelines. |
| ASK | Population-difference interview | Asks staff to describe a specific way this population's health needs differ from the general population. |
| OBSERVE | Practice adaptation check | Checks whether practice genuinely reflects population-specific evidence where it exists. |
Supervisor tips
- Ask staff for a specific example of a practice adaptation based on population-specific evidence. — A real example reveals genuine application, not just familiarity with the concept.
- Ask how staff would handle a genuine evidence gap for this population. — A thoughtful, honest answer reveals genuine engagement rather than a default assumption.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Staff Reflective Practice, Bias Awareness, and Self-Care in Migration Contexts
Non-Negotiable
In plain terms: Staff actively reflect on their own biases and culture, the telemedicine service supports this through structured practice, and staff working with traumatised patients are looked after.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | N/A | Full | Adapted | Full |
Why this matters
Every clinician has assumptions about people from other cultures, and most are unaware of them. The nurse who assumes a refugee is exaggerating pain, the doctor who is impatient with a patient who will not make eye contact, the receptionist who is curt with someone who does not understand the form — each is acting on bias, and each affects care. Reflective practice — structured time to examine one's reactions — reduces this. The second element is staff wellbeing: hearing accounts of torture and loss every day takes a toll, and staff who are burned out become staff who withdraw. Supervision, peer support, and access to counselling are not luxuries in a telemedicine service serving refugees.
What good looks like
- A structured reflective practice process genuinely exists and is used, not just assumed.
- Genuine, accessible psychological support exists and staff actually use it.
- Staff can describe specific, real examples of both bias adaptation and vicarious trauma awareness.
Common failure modes
- No structured reflective practice process exists beyond an assumption of individual self-awareness.
- Psychological support exists only nominally, with no evidence staff actually access it.
- Staff cannot describe any specific example of adapting practice or recognising vicarious trauma.
Worked example
If you are starting from zero — do this first
- Listen in the break room. What do staff say about refugee patients when they think no one is listening?
- Arrange one implicit bias workshop with an NGO or university.
- Start monthly reflective practice sessions with a facilitator.
- Arrange confidential counselling access for staff.
Self-assessment questions
Evidence: Reflective practice process description
Evidence: Psychological support access record
Evidence: N/A — tested directly
Common reasons for a PARTIAL answer
- Reflective practice happens informally but is not structured into any genuine, regular process. — Individual good practice does not reliably generalise without a defined, shared process.
- Support exists but is genuinely difficult to access given remote staff working independently across locations. — A benefit's existence does not guarantee genuine, comfortable access to it, particularly for a dispersed remote team.
- Support exists for acute incidents but not for the cumulative emotional weight of this work over time.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current training content and support access for genuine coverage of bias and staff wellbeing. |
| Week 2 | Establish a structured reflective practice process feasible for a remote or dispersed team. |
| Week 3 | Identify genuine, accessible psychological support options appropriate to remote practice. |
| Ongoing | Revisit reflective practice and wellbeing periodically, using real case examples where appropriate. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| DOCUMENT | Reflective practice process review | Reviews the service's structured process, if any, for staff reflective practice on bias and cultural awareness. |
| DOCUMENT | Support access review | Reviews what psychological support and debrief structure genuinely exist and whether they are actually used. |
| ASK | Staff example interview | Asks a staff member for a specific instance of recognising and adapting for their own bias, and how they process the emotional weight of this work. |
Supervisor tips
- Ask for a specific personal example, not a general statement of awareness. — A concrete instance distinguishes genuine reflective practice from familiarity with the concept.
- Ask directly whether support has been used, not just whether it exists. — Genuine uptake, not nominal availability, is the real test.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Digital Privacy Concerns Specific to Displaced Populations Are Genuinely Addressed
Non-Negotiable
In plain terms: The service knows that displaced people have specific fears about digital privacy — surveillance, data reaching authorities or persecutors — and addresses them concretely, not with a generic privacy notice.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Adapted | Full |
Why this matters
A refugee who fled a state that surveilled her may reasonably fear that a video consultation is being watched. A migrant without legal status may fear that health data will reach immigration authorities. An LGBTQ+ asylum seeker may fear disclosure to their community. These fears are rational and they suppress care-seeking. Addressing them means: an explicit statement of what data is collected, who can see it, and — crucially — who cannot (immigration authorities, employers, home-country governments); the legal protections that apply; the option of minimal data collection; and a conversation, in the patient's language, that takes the fear seriously.
What good looks like
- The service genuinely recognises and addresses this population's distinct digital privacy concerns.
- Specific, honest communication clarifies what is and isn't shared with any authority.
- Staff are specifically trained on this documented, distinct concern.
Common failure modes
- This population's privacy needs are treated identically to general patients, with no specific recognition.
- Communication offers only vague, general privacy assurance, not specific clarity.
- Staff rely on general privacy training, with no specific coverage of this distinct concern.
Worked example
If you are starting from zero — do this first
- Ask five displaced patients what they fear about their data.
- Write a plain-language explanation that names who cannot see their data.
- Discuss it at intake in their language.
- Offer minimal-data or pseudonymous registration.
Self-assessment questions
Evidence: N/A — tested directly
Evidence: Patient privacy communication materials
Evidence: Staff training on migration-specific privacy concerns
Common reasons for a PARTIAL answer
- Recognition exists informally among some staff but isn't consistently, formally addressed across the whole team. — Every staff member interacting with this population deserves the same genuine, formal understanding.
- Communication is honest but not proactively offered, relying on the patient to raise the concern themselves. — A patient may not know to ask, and proactive communication reaches concerns that would otherwise go unaddressed.
- Training references data privacy generally but doesn't specifically name this population's documented, distinct concern.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current practice for genuine recognition of this population's distinct digital privacy concerns. |
| Week 2 | Build specific, honest, proactive patient communication addressing this concern directly. |
| Week 3 | Train all staff specifically on this documented, distinct concern, not general privacy training alone. |
| Ongoing | Revisit communication and training as the relevant regulatory landscape evolves. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Recognition interview | Asks staff whether they specifically recognise and address this population's distinct digital privacy concerns. |
| DOCUMENT | Patient communication review | Reviews materials for genuine, specific, honest communication about data sharing with authorities. |
| DOCUMENT | Staff training review | Reviews training records for specific coverage of this documented, distinct privacy concern. |
Supervisor tips
- Ask staff directly whether they've discussed this specific concern with patients from this population. — A specific, real answer reveals genuine recognition, not an assumption general privacy practice covers it.
- Ask to see the actual, specific language used to communicate this to a patient. — A real, specific example reveals genuine, honest communication, not a vague general assurance.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Legal Status Diversity Recognition
Core
In plain terms: The telemedicine service can name which legal status groups it serves — asylum seekers, recognised refugees, stateless people, internally displaced, undocumented — and knows what each group is entitled to.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | N/A | Full | Adapted | Full |
Why this matters
An asylum seeker in many countries is entitled to emergency care only. A recognised refugee has the same entitlements as citizens. A stateless person may have no entitlement at all under the letter of the law. An undocumented migrant may be entitled to nothing — or to everything, depending on the jurisdiction and the type of care. A telemedicine service that does not know these distinctions either turns away people who are entitled to care or treats people it cannot be reimbursed for without knowing it. Knowing the categories, the entitlements, and — critically — the telemedicine service's own policy on treating people regardless of entitlement is the foundation for consistent, fair, and legally defensible practice.
What good looks like
- Staff can name the specific legal status categories this service actually serves.
- Policy genuinely differentiates access considerations across status categories.
- A specific, defined process exists for verifying unclear status.
Common failure modes
- Staff have only a general sense that "migrants" are served, without specific categories.
- A single, uniform assumption about access rights is applied regardless of status.
- No process exists for verifying status when it's genuinely unclear.
Worked example
If you are starting from zero — do this first
- List the legal status categories that exist in your country for displaced people.
- Find out what each is entitled to — ask the Ministry or UNHCR.
- Write a one-page reference for registration staff.
- Decide and write down what you will do for people with no entitlement.
Self-assessment questions
Evidence: N/A — tested directly
Evidence: Status-specific access policy documentation
Evidence: Status verification process
Common reasons for a PARTIAL answer
- Staff can name the most common category served but not less frequent ones the service still encounters. — Even infrequent categories deserve genuine, specific awareness, not the risk of misapplied assumptions.
- Differentiation exists in one provider's own understanding but isn't shared with the wider team. — Every staff member interacting with patients benefits from the same genuine understanding.
- A verification process exists but staff are inconsistently confident applying it.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current staff awareness of the specific legal status categories actually served. |
| Week 2 | Build specific, differentiated access guidance for each relevant status category. |
| Week 3 | Establish a clear verification process for genuinely unclear status. |
| Ongoing | Refresh staff awareness periodically, particularly for less frequently encountered categories. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| ASK | Status category awareness interview | Asks staff to name the specific legal status categories this service actually serves. |
| DOCUMENT | Status-specific policy review | Reviews documentation for genuine differentiation across status categories, not a uniform assumption. |
| DOCUMENT | Verification process review | Reviews the process for verifying status when it's genuinely unclear. |
Supervisor tips
- Ask staff to name every specific legal status category the service has served recently. — Specificity reveals genuine, current awareness rather than a general assumption.
- Ask what happens when a patient's specific status is genuinely unclear. — A confident, specific answer reveals a genuine process, not improvisation.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.
Care Is Documented and Provided Regardless of Immigration or Legal Status
Non-Negotiable
In plain terms: Every patient receives the same care and the same documentation regardless of immigration status — no lower standard, no incomplete record, no 'informal' sessions.
| Facility category | Crisis | Transition | Small | Standard |
|---|---|---|---|---|
| Applicability | Full | Full | Full | Full |
Why this matters
The principle is the same across every facility type. In telemedicine, the temptation is to serve undocumented patients 'off the platform' to protect them — which leaves them with no record, no continuity, and no protection. The policy must be explicit: identical care and documentation; status not asked; data protections that actually prevent disclosure to authorities (8.8); funding handled separately.
What good looks like
- Care and documentation are genuinely consistent regardless of status.
- Staff are specifically trained on this principle, not assumed to understand it.
- Confidentiality protection is applied equally without exception.
Common failure modes
- Care or documentation practice differs based on a patient's known or assumed status.
- No specific training addresses this principle.
- Status-related information is handled less carefully than other confidential information.
Worked example
If you are starting from zero — do this first
- Ask providers whether any patients are seen off the platform. Why?
- Write the one-sentence policy.
- Confirm your data agreements do not allow disclosure to immigration authorities.
- Bring every patient onto the platform with a record.
Self-assessment questions
Evidence: N/A — tested directly
Evidence: Staff training record
Evidence: N/A — tested directly
Common reasons for a PARTIAL answer
- The principle is understood by treating providers but not consistently by administrative or scheduling staff. — A patient's first interaction is often with administrative staff, where the same principle needs to hold.
- Care is consistent but documentation habits vary informally based on individual staff assumptions. — Consistency needs to extend to documentation practice specifically, not only the clinical care itself.
- The principle is followed but has never been specifically, formally trained.
Implementation plan
| When | What |
|---|---|
| Week 1 | Review current practice for any differential treatment based on status. |
| Week 2 | Establish specific staff training on this principle, covering all staff, not only clinical roles. |
| Week 3 | Confirm documentation practice is genuinely consistent regardless of status. |
| Ongoing | Reinforce training periodically, particularly for new staff. |
How the Monitor verifies this
| Method | What | Detail |
|---|---|---|
| OBSERVE | Care standard observation | Observes whether care and documentation practice is genuinely consistent regardless of patient status. |
| DOCUMENT | Staff training review | Reviews training records confirming staff understand immigration status is never a basis for differential care. |
| ASK | Confidentiality practice interview | Asks staff how patient status information, where known, is protected. |
Supervisor tips
- Ask administrative or scheduling staff, not only providers, about this principle. — This reveals whether the principle genuinely extends beyond clinical staff.
- Ask how patient status information, where it becomes known, is protected. — A specific, confident answer reveals genuine practice, not just a stated value.
Evidence base
ASF training courses on GMJ Academy →
Foundation courses A-00 to A-03 are live. Criterion-specific modules are being developed and will link here when published.