USF Health Care Changes Urged as FCC Develops National Plan

“The federal government is both the major driver and a major barrier to the expansion of telemedicine services,” said the American Telemedicine Association (ATA), a nonprofit for health care institutions, health professionals and telemedicine companies. The government has driven telemedicine through grants and programs like the FCC’s Rural Health Care Pilot Program, and by providing telehealth to military, veterans, Indians and prisoners, the association said. But the government has been a barrier “due to the restrictive coverage and reimbursement for telehealth” in many federal health benefit programs, and a “fragmented telemedicine policy,” it said.

The FCC’s universal service program for rural health is “badly in need of an overhaul,” ATA said. The commission should expand the fund to support broadband for all health care professionals, simplify the application and administrative process, and encourage interconnections of remote health care networks, it said. The fund and other government subsidy mechanisms shouldn’t be restricted by geography or other non-medical reasons, ATA said. And the FCC should prioritize federally funded health facilities for federal reimbursement, it said. Also, ATA urged the FCC to recommend an administration-level mechanism to coordinate telehealth development, deployment coverage and reimbursement.

AT&T urged the FCC to revamp universal service by “phasing out the legacy and largely ineffective Rural Health Care Program and by improving and expanding the Rural Health Care Pilot Program model.” The pilot program, “with certain essential modifications, could provide meaningful support for deployment of innovative, broadband-based health care IT services.”

CTIA said mobile devices must play a major part in providing health care through broadband -- which it calls mHealth or mobile health. “Because of its mobility and unique nature of service to the person, for some mHealth services and applications, there simply is no substitute for wireless,” CTIA said. But it said to guarantee success, the FCC must identify and make more spectrum available for use by carriers, a key recurring CTIA theme. “Specifically, CTIA reiterates its call for the Commission to identify and reallocate at least 800 MHz of spectrum for licensed commercial wireless services,” CTIA said. The group also stressed that the FCC should recognize carriers’ need for “reasonable network management” practices and take steps to guarantee that universal service rural health care support is available to wireless.

CTIA offered several examples of how mobile health care is already in place. It cites the example of the EMMA system which links a patient’s home with the pharmacy and prescribing physician. Under the system, a medication delivery unit is installed in the patient’s home linked wirelessly to a physician’s office to allow for remote management. Another device CTIA cites is a wireless tablet that permits clinicians to access patient data wirelessly, in real-time from a portable medical chart.

Other mobile applications are made possible through the growing use of smartphones, CTIA said. “The Pill Phone Application, introduced by several wireless carriers in 2008, allows individuals to look up drug interactions via their mobile device and to schedule pill reminders,” CTIA said. “Separately, the National Institute on Aging and the National Cancer Institute funded the creation of eMedMobile, a smartphone application that works with “smart labels” on prescription medication bottles and sends alerts to caregivers when a medication is skipped.”

Net neutrality rules could impede health care goals, CTIA and AT&T said. Particularly in wireless networks, mandates could “undercut the ability of network providers to meet the very high Quality of Service standards … that are necessary for the effective provision of such services,” AT&T said.

The Public Safety Spectrum Trust said the most beneficial step the commission could take on broadband and health care is to facilitate the buildout of public safety networks in the 700 MHz band. “Any review of major crises such as 9/11 or Hurricane Katrina demonstrates how much the personal efforts and effectiveness of our nation’s first responders - police, firefighters, [emergency medical responders], and others - are diminished or undermined when the communications infrastructure that supports their life- saving efforts does not meet their mission-critical needs,” the PSST said.

Qualcomm and Alcatel Lucent also stressed the importance of wireless to health care, in separate filings at the FCC. “Qualcomm spends billions of dollars annually to develop innovative technologies extending to every aspect of wireless, including the health care field,” the company said. “Today, Qualcomm’s innovative technologies enable the use of 3G mobile broadband connectivity for chronic disease management, remote monitoring of diagnostic care, health and wellness, and fitness and aging.”

Harris urged the FCC “to commit to working with government stakeholders and other interested public and private sector parties on producing a comprehensive series of studies to better understand the gaps and strengths of current health IT infrastructure.” And the commission should include the health care community as it develops spectrum policy, Harris said. The FCC should look at specific application requirements to determine type of connectivity needed by health care, it said. And it should consider “the unique security challenges of the health care sector by balancing the privacy concerns of patients with the access needs of providers,” it said.

Inmarsat said the broadband plan should recognize that satellite broadband can fill mobile broadband gaps. Government funding programs like universal service “should encourage meaningful consideration of satellite-delivered mobile broadband in circumstances where a satellite solution would be more cost effective in serving hard-to-reach areas than building out terrestrial infrastructure.”

Health care representatives said the service level provided by commercial networks isn’t enough. “The use of commercially available, public-switched networks is usually the most economical approach” for telehealth applications, ATA said. “However, the lack of uniform connectivity throughout regions and the concerns regarding the quality of service with the public IP network have kept some users away. National efforts to assure quality and connectivity must be put in place to eliminate the need for private networks and drive down the cost of delivering health care thus raising the demand for more broadband services.”

To realize benefits of interoperable health IT, “health care facilities are going to require not only high-speed but also extremely reliable connections,” said the National Health IT Collaborative for the Underserved. “It is clear that health care organizations will need more bandwidth than a typical business of similar size; furthermore, due to the nature of the business, that bandwidth must always be available.” Hospitals and other emergency providers should be up and running 99.999 percent of the time, a reliability measure that “far exceeds” ISPs’ typical service level “and can require multiple, redundant connections,” the collaborative said.

ATA agreed reliability is critical. “Common requirements for all clinical applications are the need for guaranteed, continuous connectivity and quality of service as well as fast upstream and downstream speeds,” it said. “As the number of applications increase, whether using wired or wireless connectivity in rural or urban areas, such requirements are expected to expand.”