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More Support for 2-1-1?

Groups Spar on Proper Use of Rural Healthcare Funds

The FCC faces no shortage of opinions on how best to move forward with its reform of the Rural Health Care Program, as telecom associations, healthcare providers and states offered suggestions in comments in docket 02-60 last week. Groups widely supported the program, and discussed the importance of exercising fiscal responsibility, but differed on whether the funds should be used for infrastructure buildout. Proposed reporting requirements also attracted disagreement.

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The commission must be “vigilant” in adopting and applying flexible eligibility and compliance rules, and maintaining technology neutrality, the Telecommunications Industry Association said (http://xrl.us/bnm28z). TIA said it supports the continued treatment of consortia as they are under the Rural Health Care Pilot Program; the inclusion of urban sites in the RHCP; the grandfathering of already funded urban sites in order to avoid wasted investment; and increased collaboration with other agencies to ensure that privacy and security requirements on the exchange of health data are in line with program requirements under a practical and flexible framework.

United Way Worldwide suggested the commission make 2-1-1 referral and information services eligible for universal service support through the RHCP (http://xrl.us/bnm3gg). The FCC approved 2-1-1 for nationwide use in 2000 to direct people to appropriate healthcare organizations. United Way runs or helps fund about 75 percent of the nation’s 246 2-1-1 systems, and has found that 2-1-1 funding and resources are “insufficient to reach all rural areas or to deliver the full potential of the service.” With support from the USF, 2-1-1 could provide broader and more extensive health services to rural America, United Way said.

The American Hospital Association wants quick action on a final rule to facilitate access to broadband services and infrastructure across the country (http://xrl.us/bnm36s). “As the nation moves forward with the adoption of electronic health records ... there is a growing digital divide between rural providers and their urban counterparts that must be addressed to ensure that all Americans can benefit from a broadband-connected health care system, regardless of where they live,” AHA said. The association wants simpler consortium applications, easier access to urban providers’ resources, and easier access to broadband service and last-mile facilities.

The National Telecommunications Cooperative Association cautioned the FCC that it might not be appropriate to provide funding to recipients to construct and own network facilities (http://xrl.us/bnm37a). “Funding infrastructure could create a substantial risk of unnecessary and wasteful overbuilding of existing networks,” NTCA said. “If the Commission were to end up going down this path, sufficient protections must be built into the program to ensure against inefficient use of limited resources.” Alaska Communications Systems emphasized the importance of reliable, long-term contracts (http://xrl.us/bnm27f), which several others also mentioned.

The FCC must continue “to permit the construction of facilities where it is less costly to do so,” said the Health Information Exchange of Montana, Inc., saying its “experience shows that failure to do so will waste limited universal service subsidies” (http://xrl.us/bnm24i). New construction should “rarely be necessary” but retaining that option “will conserve and stretch USF dollars; otherwise, the Commission risks perpetuating a system that has been effectively cutting blank checks to local service providers for many years,” the exchange said. “Limited construction of facilities will be needed,” said Colorado Health Care Connections and Rocky Mountain HealthNet (http://xrl.us/bnm28e).

Not all state groups agree on infrastructure, however. The Montana Telecommunications Association (MTA) “consistently has opposed the funding of infrastructure construction under the Rural Health Care Program,” which would hurt what it calls “anchor institutions,” it said (http://xrl.us/bnm2wv). The association argues the Telecom Act of 1996 doesn’t “authorize the use of universal service funds for the construction of health care network facilities.” MTA also fears construction efforts would be duplicated and finds it “hard to conceive of proper safeguards,” it said. The University of Arkansas for Medical Sciences “does not support the usage of Broadband Services Program funds for capital or construction costs,” it said (http://xrl.us/bnm27s).

Multiple state groups cited the need for sufficient money to handle operating costs and the importance of streamlining the program. Several suggested urban sites be included, cautiously and with limited funds. The California Telehealth Network wants the FCC to maintain the Broadband Services Program subsidy at the 85 percent level for recurring and non-recurring charges and wants to expand its eligibility (http://xrl.us/bnm25u). The Oregon Health Network notes “restricted eligibility of providers (for example, a for-profit provider that shares the same building as non-profit/eligible provider) has created administrative complexity and reduced the use of the investment that the FCC has made out to the physical location, out of the sheer fear of the providers” and recommends ways to expand eligibility (http://xrl.us/bnm29q). “Vendors and end-users need to have assurance that discount funds will be available at least 3-4 years into the future,” said the North Carolina TeleHealth Network (http://xrl.us/bnm28x).

Reporting requirements also attracted differing opinions. The Utah Telehealth Network supported much of the program but decried quarterly reporting as “too frequent” (http://xrl.us/bnm2zm). It backs annual reporting. The Iowa Rural Health Telecommunications Program agrees and supports “a minimum of annual reporting” (http://xrl.us/bnmjdv). The Western New York Rural Area Health Education Center accepts the idea of quarterly reporting but strongly urges an online system in which to do so to avoid “very lengthy” and repetitious reports (http://xrl.us/bnm28p). It also urges better online health record-keeping overall.

"We strongly disagree with the requirement to submit sustainability plans,” the Utah network said. It called the requirement “a hoop that needed to be jumped rather than a productive exercise towards viability” and described months of working toward what it felt were “vague requirements.”