The ERISA Industry Committee (ERIC) submitted comments to the Delaware Board of Speech/Language Pathologists, Audiologists and Hearing Aid Dispensers urging the Board to strike the proposed requirement that requires initial evaluations to be performed “face to face and not through telepractice” and instead use standards expressed in existing rules to maintain a high standard of care, and permit licensees to exercise their professional judgment on a case-by-case basis to determine whether telehealth is appropriate for an initial encounter. Similarly, ERIC asked the Board to strike the requirement that a patient be located within the physical boundaries of Delaware at the time telepractice services are provided. Existing rules, and the requirement that an applicable provider practicing within Delaware be licensed by the Board, should satisfy jurisdictional concerns without raising additional obstacles to care. ERIC believes by limiting barriers to services provided via telepractice, the Board accomplishes its goal of broader access to care without compromising professional standards of competence.
ERIC also submitted comments to the Arkansas State Medical Board. ERIC applaud the ASMB for acknowledging that the same standard of care should apply to provider-patient relationships. ERIC believes that there should not be artificial barriers that unnecessarily limit access to medical services provided through telemedicine when there are existing requirements in place to hold providers to a high standard of care, including limitations on how to establish a provider-patient relationship using telemedicine. By reducing barriers to services provided via telemedicine, the Board facilitates broader access to care without compromising the health, safety, and welfare of the people of the State of Arkansas.