Policy Discussions Archive
Updated and expanded: Telemedicine position statement
Discussion Ended on 04/27/2023
NCMB will accept feedback on the proposed draft of the Telemedicine position statement through 5 p.m. on Thursday, April 27. Access the draft position statement, as well as the existing position statement, under References at the right of the page.
References
Comments
April 27, 2023
The Honorable Michaux R. Kilpatrick
President, North Carolina Medical Board
3127 Smoketree Court
Raleigh, NC 27604
RE: ATA ACTION COMMENTS ON THE DRAFT TELEMEDICINE POSITION STATEMENTDear President Kilpatrick and members of the North Carolina Medical Board:
On behalf of ATA Action, I am writing to provide our comments on the draft Telemedicine Position Statement published by the Medical Board.
ATA Action, the American Telemedicine Association’s affiliated trade association focused on advocacy, advances policy to ensure all individuals have permanent access to telehealth services across the care continuum. ATA Action supports the enactment of state and federal telehealth policies to secure telehealth access for all Americans, including those in rural and underserved communities. ATA Action recognizes that telehealth and virtual care have the potential to truly transform the health care delivery system – by improving patient outcomes, enhancing safety and effectiveness of care, addressing health disparities, and reducing costs – if only allowed to flourish.
ATA Action supports the Board’s efforts to update the current Telemedicine Position Statement, which was last amended in 2019. The last couple of years have revolutionized the delivery of telehealth care; we believe the updates to the Telemedicine Position Statement are rational and ensure the Board’s policies are consistent with modern delivery of telehealth services. We are supportive of several provisions in the new position statement, including its modality neutral approach and holding telemedicine providers to the same standard of care as in-person care. ATA Action would also encourage the Board to promote greater access to care by endorsing cross-state licensure frameworks and to remove or clarify the requirement for telemedicine providers to disclose their location.
ATA Action appreciates the modality neutral definition of telemedicine provided by the draft position statement which will allow providers, in consultation with the patient, to use their professional discretion to choose the technology that will best meet the standard of care. ATA Action also supports the Board’s adoption of the patient originating site definition, stating that the practice of medicine occurs where the patient, not the provider, is located.
Furthermore, our organization supports the exceptions in the licensure section that enable telehealth providers licensed in other states to provide services in North Carolina under specific circumstances. However, ATA Action recommends that the Board go further. The Board’s influential platform could advocate for the adoption of interstate licensure compacts for a range of health professions. Reducing geographic barriers to licensed healthcare services will help more patients receive access to care, fill in health workforce shortages and improve areas of care that may be lacking healthcare providers across the state or in certain areas.
Finally, our organization encourages you to remove or provide more clarity regarding the requirement for the licensee to provide their location to the patient. The term location is undefined and could create confusion for providers as to the level of detail they must provide to patients regarding their location. Telehealth frameworks also establish that the patient encounter occurs at the originating site, or the patient’s physical address. This means that there is little clinical or functional need for the provider to include their address within the patient encounter. This requirement could also become a safety concern if telehealth providers would have to give to patients the provider’s personal home office address. ATA Action does not believe this would be appropriate and could expose providers who work with patients that may take inappropriate advantage of this information. However, if there is a preference to keep the location disclosure requirement, ATA Action suggests allowing providers to provide their “professional business” address or a non-specific “geographic location.”
Thank you for your support for telehealth. We encourage you and your colleagues to consider changes to the draft NCMB Telemedicine Position Statement to best ensure access to high-quality medical care for North Carolina patients. This new position statement could be just the first step in enacting meaningful policy change in the Tarheel State. Please let us know if there is anything that we can do to assist you in your efforts to adopt practical telehealth positions in North Carolina. ATA Action is available as a resource to you and your members throughout this process. If you have any questions or would like to engage in additional discussion regarding the telehealth industry’s perspective, please contact me at .(JavaScript must be enabled to view this email address).Kind regards,
Kyle Zebley
Executive Director
ATA ActionBy Tom Mann on Apr 27th, 2023 at 2:25pm
Teladoc Health appreciates the opportunity to offer comments in support of the North Carolina Medical Board’s (Board) revised telemedicine position statement. The proposed draft updates and expands the Board’s existing position statement on telemedicine to accommodate clinically proven, safe, and effective virtual care practices in a technology-neutral way. This is an important step to ensure North Carolinians continue to enjoy access to the full suite of telemedicine technologies available. We respectfully urge the Board to approve the position statement as currently drafted.
By way of introduction, Teladoc Health is the world’s largest telehealth company and has more than 5,000 employees, delivers health care in 175 countries and in more than 40 languages, and partners with employers, hospitals, health systems, and more than 50 health insurance plans in all 50 states, including in North Carolina, to transform health care delivery. Teladoc Health provides health care services to more than 40 percent of Fortune 500 employers, as well as thousands of small businesses, labor unions and public-sector employers, which offer our virtual care services to their employees. In North Carolina specifically, Teladoc Health is offered as a benefit by over 25,000 employers, covering over 2.3 million patients.
We commend the Board for aligning its position statement closely with the Federation of State Medical Board’s (FSMB) recently updated model guidance on “The Appropriate Use of Telemedicine Technologies in the Practice of Medicine.” Doing so ensures the Board’s position on telemedicine remains consistent with recognized standards of medical practice and ensures patients will receive safe, efficacious health care. Importantly, by using the standard of care to determine the appropriateness of a telemedicine visit, the Board will empower North Carolina-licensed physicians to use their discretion and expertise to determine whether telemedicine is an appropriate method for delivering care to the patient.
Throughout the last decade, we have witnessed the tremendous growth and capabilities of telemedicine. The Covid-19 pandemic spurred a dramatic increase in the use of this technology, and based on continued research and reporting, it is fair to assume that this form of health care delivery is here to stay. Given this reality, it is crucial that professional licensing boards develop – and update as necessary – their guidelines on the use of telemedicine to ensure patient safety. Teladoc Health appreciates the Board’s intent to do so in a technology-neutral way that avoids placing arbitrary restrictions on certain telemedicine modalities. Thank you for the opportunity to provide comments on this important proposal. It is our hope that the Board will approve the current language without delay.
By Claudia Duck Tucker, SVP, Teladoc Health on Apr 4th, 2023 at 2:33pm
