OFFICE OF
STATE HEALTH OFFICER
701-328-2372
FAX 701-328-4727

April 1, 1996

Office of the Secretary
Federal Communications Commission
1919 M Street NW
Washington, DC 20554

RE: Informal Comments - CC Docket No. 96-45

Gentlemen:

As the State Health Officer in North Dakota concerned about access, quality and cost of health care, I appreciate the opportunity to provide comments about the Act and its affect on telemedicine and health care providers. Telemedicine is viewed by our office as effective, efficient access for the many rural residents in our state. We feel every effort should be made to make their health care comparable to the urban residents of our state. We are actively involved in licensure, quality, reimbursement and malpractice issues related to telemedicine.

In response to some of the specific paragraphs:

Section IV.A., paragraph 71: In addition to course services discussed in section III, rapid line services for the rural health providers are becoming a necessity. Rural telemedicine services include two-way video service with consulting specialists in the urban area and patients from the remote rural area. High-speed telecommunications capability at this time include asynchronous transfer mode and integrated systems digital network technologies. The definition here must be fluid as the technologies and availability of technologies and cost- effectiveness of technologies are constantly changing and advancing.

Paragraph 73: North Dakota is an extremely sparsely populated state with population density of nine people per square mile. There are four population centers with specialty care services available. To provide necessary health services in this state, there should be adequate access to specialty services. Access to these services should not require a 3-hour travel over a highway. Transmission of pictures, sound, images such as x-rays or electrocardiograms and other laboratory information should be available and should connect the urban areas to the rural service providers.

Section C.1., paragraph 90: In addition to those services mentioned above, continuing medical education services are necessary in the rural areas and appropriate communications equipment and technology should be supported for these areas. open to a reviewing agency on a periodic basis so that it can be assured that the service is being used appropriately.

Section 3. Who is Eligible For Support: no comment.

Section V. Enhancing Access to Advanced Services for Schools, Libraries, and Health Care Providers, A. Goals and Principles: no comment.

B. How to Implement, paragraph 110: I feel that this paragraph is somewhat problematical. We are attempting to enhance services to the rural areas and provide access to services. If these services can be utilized by the private sector to improve the efficiency and use and make this more cost-effective, this should be allowed. The services should be prorated so that those services that are provided for the institution are provided at an institutional rate and those services provided to the private sector are provided at the private rate. I do not think that this separation would be unduly burdensome. It would require only two rates, but would enhance the use of equipment that is being encouraged in the rural area rather than allowing it to stand empty and unused.

Paragraph 111: It is possible to conclude that the provision of enhanced services to the rural health care providers will be provided by other health care providers; therefore, all health care providers are involved and all will benefit. Those that benefit the most are the patients.

I thank you for the opportunity to comment. If you have any specific questions about my comments, please feel free to contact me.

Jon R. Rice, M.D.
State Health Officer

JRR:Irr
cc: Public Service Commission
Center for Rural Health, Grand Forks

NORTH DAKOTA
LEGAL SERVICES
P.O. Box 217 Main Street
New Town, North Dakota 58763

April 10,1996

Ms. Susan Wefald Commissioner ND Public Service Commission State Capitol Bismarck, ND 59505

RE: Telephone Service and low income people

Dear Commissioner Wefaid:

This letter is a follow up to an inquiry from PSC staff attorney Illona Jeffcoat-Sacco people in North Dakota

Back in 1990 and 1991, I worked very hard to change a bad regulation in North Dakota that allowed local telephone companies to deny or disconnect local service to a customer because that customer had a delinquent long distance bill. This regulation resulted in thousands of low income North Dakotans going without essential local telephone service.

The PSC ultimately ended that practice. Because of that effort, I ended up working closely with the telephone industry in North Dakota and particularly Reservation Telephone Cooperative of Parshall, North Dakota. While I certainly do not claim to be an expert on telephone service for low income people, I do have some experience in that area.

As you are well aware, local telephone service is far more than a modern convenience. To the elderly man in Watford City with heart disease, to the single parent with a two month old infant in Devils Lake, to the battered victim of domestic violence, to the farmer injured in this field south of Strasburg, a local phone is a necessity, a life line. Be it the 91 operator, the police station, local hospital, ambulance service, the family, doctor, medical help, police assistance, life saving aid is just minutes away -- if one has a local telephone.

Phone: (701)627-4719 Fax:(701)627-4122

James P. Fitzsimmons
Executive Director

Vickie D. Fox
Paralegal

Jamie Rogers
Secretary

Clarine Jackson
Admin. Assistant.