AAFP Tells FCC Telehealth Pilot Should Encompass Broad Scope

Program Would Help Defray Cost of Broadband Internet Access

September 04, 2019 11:41 am News Staff – In a recent letter to the Federal Communications Commission, the AAFP expressed conditional support for a proposed $100 million telehealth initiative. Key to the three-year pilot program's success, the Academy advised, would be ensuring that it isn't limited to rural physicians and patients.

The pilot program outlined in the proposed rule would help eligible health care professionals offer connected care technologies to low-income patients and veterans by defraying the costs of broadband internet access. Initially, it would focus on health conditions that typically require extended care, including behavioral health, opioid dependency and chronic issues such as diabetes, kidney disease and heart disease.

The FCC solicited comments on several potential aspects of the program, including the following.

Who and Where

The Academy called on the FCC to make the pilot available for rural and urban patients "in all geographies" and for different types of health care providers rather than focusing on rural populations and limiting participation to nonprofit or public health care facilities.

"The pilot should not be restricted to specified geographic regions (urban or rural) or to specified health professional shortage areas or nonmetropolitan statistical areas," the letter added.

Citing a November 2018 CMS document on Medicare telehealth, the letter noted that although rural populations must often travel long distances to access primary care, low-income urban populations face their own set of challenges, including child care, bus transfers, inconvenient office hours and absenteeism from work or school.

"We caution that inequitable expansion of access to telehealth services may further broaden disparities in care and health outcomes among vulnerable populations," the Academy said.

Story Highlights

Standard of Care

"The AAFP firmly believes that telehealth technologies can enhance patient-physician collaborations, increase access to care, improve health outcomes by enabling timely care interventions and decrease costs when utilized as a component of, and coordinated with, longitudinal care," said the letter, drawing from Academy policy on telehealth and telemedicine.

With that in mind, the letter added, achieving the standard of care and protecting the existing physician-patient relationship must take precedence over policy and technological capacity.

"The treating physician within a telemedicine care encounter should bear the responsibility for follow-up with both the patient and the primary care physician or medical home regarding the telemedicine encounter."

Terminology

The Academy signaled support for the FCC's definition of telemedicine as "using broadband internet access service-enabled technologies to support the delivery of medical, diagnostic and treatment-related services, usually by doctors."

But the agency's proposed definition of "connected care" as "a subset of telehealth that is focused on delivering remote medical, diagnostic and treatment-related services directly to patients outside of traditional brick-and-mortar facilities" should be clarified to avoid added administrative complexity, the letter said.

"If this verbiage is used, then stand-alone/direct-to-consumer telemedicine and telehealth services should not be referred to as providing 'connected care,' because those services are often not connected to the patient's usual source(s) of care or medical home," the Academy wrote.

The letter expressed further concern that the term, as the FCC currently defines it, "may inappropriately be applied to all telehealth services occurring across the landscape," including those that support siloed, disjointed episodic care rather than continuous, comprehensive longitudinal care.

The word "rural" must also be clearly defined, the Academy said. But regardless of definition, it would be "unnecessary and unproductive" to limit the pilot program to rural areas.

"On a near-constant basis, not just clinical professionals but all types of American professionals now rely on email, teleconferencing, videoconferencing and other tools to conduct business and serve clients regardless of whether they are based in a rural or urban setting."

Coordination

"In general, the lack of coordination and alignment among agencies typically creates unnecessary complexity," the Academy wrote in response to a question about how best to ensure adequate coordination between the FCC and other federal agencies, such as CMS.

"Not all telehealth services focused on delivering remote medical, diagnostic and treatment-related services directly to patients outside of traditional brick-and-mortar facilities are providing truly connected care supportive of care continuity and longitudinal health," the letter added.

The AAFP again pointed out that the term connected care carries connotations beyond a simple technology bridge linking patients to physicians and other health care professionals for medical, diagnostic and treatment-related services.

"This is especially true in terms of CMS and private-payer initiatives to advance toward value-based care and payment models that promote coordinated care and effective resource utilization management," the Academy said.

Related AAFP News Coverage
Telehealth Rules Must Protect Continuous Care, AAFP Tells CMS
(1/7/2019)

AAFP to FCC: Improve Rural Telehealth to Support Primary Care
(2/5/2018)