Washington, D.C. 20554
In the Matter OfFederal-State Joint Board on CC Docket 96-45 Universal Service
Comments By the Nebraska Association of Hospitals and Health Systems
IV. Schools, Libraries, and Health Care Providers
C. Health Care Providers
What Services to Support
Communications technology is currently used most frequently to support the following information needs: electronic claims transmission, EKG transmissions, lab data transfer, online library services, telephone conferences, transcription services patient information management, drug information, continuing education, E-mail, Internet access, teleradiology, telemedicine, conferences/meetings, student education, cellular telephone, two-way, one-way radio and pagers. Many of these needs may be met by voice grade circuits capable of 28.8 kilobyte per second speed.
Telemedicine, teleradiology, video educational and conferencing applications, and remote computer control of equipment require considerably greater band width. At a very minimum, telemedicine requires 384KBPS. In our rural environment, telemedicine is certain to grow both in frequency of use and the breadth of procedures for which it is utilized. As the demand for real time, high resolution grows, it is reasonable to expect the need to grow to at least 1.544MBPS.
The above-identified band widths are tempered with the knowledge that while rural health care providers are being asked to do more, they are being asked to do it with less funding. Even with subsidized access to the above circuits, we need to keep the cost to an absolute minimum. Access to relatively high speed circuits will be essential to effective rural telemedicine. However, that access is very likely to be quite sporadic and of varying duration. In order to make such service cost effective, it needs to be done in such a way as to allow the sharing of the circuit to the extent possible, without compromising security of the information being sent over the circuit. Rural health care providers are not likely to be able to afford the lease of dedicated lines which sit idle most of the time.
Discounts limited to outgoing services will not well serve rural health care providers. Much of the utility of video link up will be for educational and conference purposes. Those situations will, in many cases, be incoming for rural hospitals.
How to Implement
While all facilities in Nebraska "serve persons who reside in rural areas," it is reasonable to define all hospitals in the more densely populated counties of Lancaster and Douglas as urban, and hospitals in all other counties as rural
To help assure appropriate rates, we would encourage compliance with rate guidelines as a condition of eligibility for telecommunications carriers to receive interstate support for telecommunications services provided to rural health care providers under Section 254(h).
V. Enhancing Access to Advanced Services for Schools, Libraries, and Health Care Providers
How to Implement
Given the expense of the circuits and the sporadic demand, it makes sense for the hospital to make their circuits and equipment available to physicians and other health care providers in the community. It does not make sense for each physician's office or other health care provider to have all of the equipment and circuits to do telemedicine in place and receive educational or conference material. It also makes sense for the hospital to be able to charge its cost to those who wish to utilize the hospital's equipment. The above is in no way intended to preclude any health care provider who might wish to have access on their premises from doing so.
Who Is Eligible for Support
Given the fiscal pressure under which all hospitals are now operating, we would encourage al I providers (not just rural) be covered.
The Nebraska Association of Hospitals and Health Systems submits these comments in response to the Notice.
Respectfully submitted,
Ted Schultz
Vice President for Administrative Services
Nebraska Assoc. of Hospitals and Health Systems
1640 L Street, Suite D
Lincoln, Nebraska 68508-2509
(402) 476-0141
Dated: April 5, 1996