THE UNIVERSITY OF
ARIZONA
HEALTH SCIENCES CENTER

April 11, 1996

Office of the Secretary
Federal Communications Commission
Washington, D.C. 20554

Dear Commission Members:

The following comments are offered in relation to your proposed mechanisms for universal service, per the 1996 Telecommunications Act.

First, I suggest that "Universal Service" is too loosely defined in Section 254. The rules indicate that "Universal service is an evolving level of telecommunications services that the Commission shall establish periodically under this section." I am concerned that this definition can ultimately affect the specificity of services provided, in particular to remote areas of our State, and recommend some tightening of the definition.

Secondly, I am concerned that in implementing universal service, public and private services may have separate rules and procedures and that this separation might cause for increased rates to be applied to rural communities.

The following narrative addresses specific areas in which the commission requests comment.

III Support for Rural, Insular and High-Cost Areas and Low-Income Consumers.

A. Goals and Principles:

1. Touch-tone services should be included among the supported services.

2. Single party service should be included among services receiving universal support. In Arizona, party-lines are still utilized widely, especially in remote rural areas, including Native American lands.

3. Enhanced 911 services should be included in universal service. This is particularly important to rural residents whose residences are located sizable distances from health care facilities.

4. Access to operator services should also be included among universal services.

B. Health Care Providers

91. The kinds of telecommunications necessary to provide health care services in rural communities: We need access to broad-band digital communications networks in order to provide consultations in specialties such as radiology, pathology, psychiatry, neurology, pediatrics, emergency medicine, surgery, obstetrics and gynecology, dermatology, and general medical practice.

93. "Instruction relating to health care services": This is particularly important in bringing educational opportunities and health care practice opportunities to rural communities of Arizona. With T-3 cable installed in remote areas, connected to urban teaching sites such as the University of Arizona in Tucson, computer access to teaching and learning opportunities can be actualized. It is now difficult to send medical students and residents to many remote sites, as their curriculum requires that they return to Tucson for further didactic work on a weekly basis. If the infrastructure were in place to simplify computer access to distance education, this travel could be avoided. We would be able to provided the didactic work to medical students through data, audio and video connections, as well as provide the required supervision of medical residents, and other health care professionals in this same manner. Pharmacy and nursing students are also rotated into rural communities. Providing on-line supervision and didactic opportunities would allow for rotation of more students into remote sites.

Who Is Eligible For Support:

It is recommended that state offices of rural health be added to the listing of rural health providers. These offices are located throughout the Nation and many provide direct health care services through mobile clinics, as well as continuing education opportunities for health care practitioners located in remote sites. They also act as advocates for rural communities, and provide liaison between rural communities and urban resources.

Sincerely,

Alison M. Hughes, MPA

Associate Director