Comments in response to the FCC's public notice on health care issues are due December 4, 2009.

The Federal Communications Commission (FCC) has formally requested comments from the health care sector on ways in which broadband and other advanced communications services can be used to promote better health outcomes and the more efficient delivery of health care services.

The FCC intends to use these comments to assist in its development of a National Broadband Plan to be presented to Congress in February 2010. Among other things, Congress has directed the FCC to include in its National Broadband Plan "a plan for the use of broadband infrastructure and services in advancing health care delivery."

According to the FCC, broad use of health information technology applications—such as telemedicine, electronic health records, remote patient monitoring and real-time video consultations—"has the potential to improve population health, expand access to affordable care, increase the efficiency of care provision, reduce unnecessary health care costs, prevent medical errors, increase administrative efficiencies and decrease paperwork."

The FCC is therefore requesting comments from the health care sector on how broadband infrastructure and services—including fiber, wireline, and wireless infrastructure and services—"could help achieve efficient implementation of health IT applications." The FCC also seeks to "further understand gaps between current connectivity infrastructure and the connectivity requirements for various health IT applications across the healthcare ecosystem."

Specific issues on which the FCC is requesting comment include the following:

The current state of internet connectivity in various settings in both urban and rural areas, including hospitals, community health clinics and outpatient centers, physician offices, long-term care facilities, home, emergency medical responders, and government and tribal health agencies

The type of commercial or private infrastructure necessary to support current and emerging health IT applications

"Real world" examples of the value case for health IT applications

Drivers and barriers to the use (or availability) of internet connectivity and the adoption of health IT applications

Data security issues for health IT applications.

Comments in response to the FCC's public notice on health care issues are due December 4, 2009. The FCC will continue to accept comments and filings on these issues after this date through its ex parte filing procedures, and interested parties may also request meetings with FCC staff and officials to discuss their issues and concerns directly. However, there is limited time available for even these options, since the FCC is required to provide its final report to Congress by February 17, 2010.

In a separate proceeding that could also affect the health care sector, the FCC is considering whether its proposed "net neutrality" rules should include special rules or exceptions for "managed" or "specialized" network services, such as those used for telemedicine and health care IT. Additional information about this proceeding may be found here.

The McDermott Difference

Please let us know if you have any questions or would like to discuss the FCC's consideration of health care issues in the development of the National Broadband Plan. We would also be pleased to assist you in apprising the FCC of your views regarding the issues raised in this proceeding

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