Tough Verification Requirements Will Mean Low Participation in Healthcare Program, AHA Says

"We urge the Commission to further streamline the eligibility and application processes used to award the available funds,” AHA said. “We are concerned that a program that is too administratively burdensome will be unable to provide support where it is most needed. Previous experience with the Rural Health Care Pilot Program and the current Rural Health Care Internet Access Program provides ample evidence that heavy administrative burdens limit participation.” AHA noted that in 2009 only $60.7 million was spent, out of the $400 million available in the program.

The structuring and management of communications services are not a “primary” focus of any hospital, AHA said. “Funding programs must, therefore, avoid complex application processes and provide support for administrative, consulting and legal expenses incurred in the management of the supported projects,” the group said. Hospitals in areas where broadband is otherwise available shouldn’t be left out of the program, AHA said: “Health care providers choosing to undertake the construction of facilities under the Health Infrastructure Program will have given great weight to any existing broadband alternatives available. Even where some facilities do exist, they may be insufficient for health care purposes, including factors of reliability and quality of services from existing providers."

Verizon and Verizon Wireless said the FCC should keep the rural health program at its current size, explore support “in areas where sufficient broadband facilities are unavailable and not where such facilities are already in place” and consider reimbursing service providers directly instead of as an offset against universal service contributions. “Keeping the program capped at existing levels is a sensible approach,” Verizon said. “Demand for … support has historically been far below the program cap. The Commission’s pilot program for … infrastructure projects caused demand to inch up in recent years, but the program still distributes less than $70 million per year.” Verizon questioned whether any funds should flow to areas that already have broadband service, in opposition to the AHA comments. “It is difficult to conceive of a case where it could actually be less expensive to build and operate an entirely new rural broadband network versus purchasing services from an existing provider that already has facilities in place,” the carrier said.

TIA supported creation of a permanent program to bring healthcare and technology benefits to underserved communities, as called for in the National Broadband Plan, and also said the FCC should fund the rural healthcare support mechanism at its full $400 million level. “TIA has advocated for a permanent rural health care program for some time because of the success of the [pilot program] in bringing critical health care opportunities to long-underserved communities,” TIA said. “TIA has previously documented a number of key projects that are bringing important medical services to rural America across the country, from West Virginia to California, from Minnesota to Tennessee, and in many other locations in between.” Expanded use of broadband “will allow patients in medically underserved communities to receive health care locally and have access to state-of-the-art diagnostic tools typically available only in the largest and most sophisticated medical centers,” TIA said.

The program also must fund both wireless and wireline projects, TIA said. “Section 254 of the Communications Act … requires that competitively neutral rules govern access to advanced telecommunications and information services for health care providers,” the group noted. “TIA also encourages the Commission to incorporate flexibility if it adopts performance measurement rules. Any broadband speed or reliability thresholds deemed necessary for the rural health care programs should recognize that meaningful health care applications can be deployed using wireline, fixed wireless, and mobile wireless platforms and architectures, which have a wide range of achievable performance."

Motorola urged the FCC to set 10 Mbps as the minimum broadband speed for projects under the program, as proposed in the rulemaking notice. “As the Commission correctly states, the focus of the health infrastructure program is to support the creation of dedicated networks, which were defined in the National Broadband Plan as networks capable of speeds of 10 Mbps or more,” the company said. Motorola noted that broadband based technologies are winning acceptance in medical centers across the U.S.: “Further acceptance and use of these technologies, which help reduce medical errors and speed diagnosis and treatment through positive patient identification (PPID), will be hampered if patients and health care professionals are unable to transmit sensitive health-related information over broadband networks due to a lack of high speed infrastructure."

Qualcomm said the FCC’s rules should take into account the big role that wireless can play in rural healthcare. “In fact, cellular wireless networks have some important advantages over wired solutions,” Qualcomm said. “Today’s 24/7 wireless medical monitoring tools can give the rural patient freedom of movement, the attending physician access to real-time patient data, and the patient’s loved ones peace of mind. … Wireless broadband technologies, which are already in heavy use in much of America, in many cases offer the most cost-effective means of deploying broadband connectivity to rural health care providers."

States Weigh In

Montana Independent Telecommunications Systems criticized the Health Information Exchange of Montana for wasting public money in its use of pilot program funds. “It has completed the first stage of … the HIEM network, a 185 mile fiber backbone across the Continental Divide…” including “service to healthcare clinics in Eureka, Montana.” But the entire Eureka exchange -- including the two healthcare facilities -- already has broadband access and has had access since 2001 thanks to InterBel Telephone Cooperative, MITS claimed in its filing. “InterBel … has indicated to HIEM its strong opposition to the proposed wasteful construction of a network that would duplicate existing telecommunications infrastructure.”

"It appears that in some instances, while well-intended, the RHCP Pilot Program has been the springboard for some health care providers to venture beyond their core business of healthcare delivery and into areas that include the design, construction, maintenance, and provisioning of telecommunications services over telecommunications networks,” MITS said in its filing.

But HIEM said its project is “a critical 185 mile segment of fiber backbone across the Continental Divide” that will connect seven healthcare facilities this year, with more to come next year. HIEM and its cohorts in the pilot program “have a unique and valuable perspective on the commission’s efforts to promote broadband infrastructure for health care in rural areas. … This real-world experience deserves considerable weight in this proceeding.”

The New England Telehealth Consortium said the commission should expand the subsidy to big cities. “It is very important that urban hospitals receive subsidy so they are incented to be a part of a network that connects to rural sites in Maine, New Hampshire and Vermont. NETC believes that non-profit urban healthcare sites that will be connected to rural healthcare sites should receive a Health Broadband Services Program subsidy of 85 percent, similar to the Rural Health Care Pilot Program."

The University of Hawaii Telecommunications and Information Policy Group said in its filings that there had been confusion in the program. “It maybe the nature of a ‘pilot’ program but the rules and interpretation of the original FCC order varies from project coaches and managers,” the university filing said. “We recommend that the [Universal Service Administrative Company] officials be given authority to a certain degree to review, approve and expedite special requests/waivers. At a minimum we support the formation of a working group to provide recommendations to the commission to expedite the decision-making process."

TeleQuality Communications CEO Tim Koxlien said the pilot program has offered “a mix of success and missed opportunities.” “The pilot program has, in many cases, funded unnecessary telecommunications network redundancies. … Is this cost of network duplication something that is in the public interest?"

Satellite Concerns Expressed

The rulemaking notice includes two rules that could potentially prevent access to fixed and mobile satellite technologies, “thereby eliminating a valuable alternative for providing high quality health care to citizens in rural and remote areas when no other reliable alternative exists,” said Inmarsat. Imposing a minimum speed of 4 Mbps downstream could impede the use of satellite networks, it said. Inmarsat’s network can support 0.5 Mbps to antennas on mobile units, proving valuable connectivity below the proposed threshold, it said. The rules should include a process for healthcare providers to apply for funding to cover costs for technologies that can provide the best communications service available, it said. Proposed rules also require healthcare providers to demonstrate satellite is the most cost-effective option available, it said. The rule would cap the discount for satellite services, which are often more expensive than terrestrial, at the equivalent cost of terrestrial services, it said. The rule would impose a “discriminatory burden” on satellite services, Inmarsat said. While more expensive, satellite could facilitate savings, for instance, by allowing an ambulance to transmit a diagnosis, resulting in faster actions and savings, it said.