November 21, 2016
Confidential Executive Assistant
Louisiana State Board of Medical Examiners 630 Camp Street
New Orleans, Louisiana 70130
Sent via electronic mail to email@example.com
Dear Ms. Arceneaux,
The ERISA Industry Committee (ERIC) is pleased that the Louisiana State Board of Medical Examiners (Board) recognizes the potential benefits of telemedicine and welcomes the opportunity to share our enthusiasm and support for leveraging telemedicine to increase access to care. I want to thank you for thoughtfully developing your telemedicine rules to embrace this modern health care delivery tool, and to express large employers’ interests on this issue.
As the only national association that advocates for large employers on health, retirement and compensation public policies at the federal, state, and local levels, ERIC speaks in one voice for large employers on public policy issues relating to employee benefits. Our members have employees in every state across the nation, including many Louisianans.
ERIC’s members are committed to, and known for, providing high-quality health care benefits to millions of active and retired employees, and their families. ERIC has a strong interest in proposals that affect its members’ ability to deliver cost-effective benefits. Our members devote considerable time and resources to their benefit plan design, balancing the provision of high-quality, affordable health care with the need to contain costs for these programs.
ERIC members need consistent telemedicine policies around the country so that their employees and families can enjoy the same company benefits regardless of the state in which they live or work. It is imperative that funds to pay benefits are maximized and not diverted to administrative and compliance burdens stemming from a myriad of disparate and potentially conflicting state rules and regulations.
In addition to improved access to health care, employers support telemedicine for these reasons:
- Accessibility. Flexibility. Without barriers. Telemedicine gives employees and their families access to health care 24 hours a day, seven days a week, whether at home, in transit, or at work, without regard to standard office hours and proximity to a health care provider.
- Benefits for rural, urban, and working families. Telemedicine has long been seen as a means for providing access to care for rural populations. Urban underserved populations, retirees, the elderly, disabled employees, and those with language barriers, chronic conditions, or transportation barriers also stand to benefit from increased access to care, as well as working parents and others struggling to balance work and family demands.
- Increased workforce satisfaction. The response from employees who have used telemedicine services is very positive. Employees want to minimize the time spent attending to their health needs, or that of loved ones, and appreciate the opportunity to reach a health care professional at times and locations that are convenient to them. They like the service and want it to continue.
- Connection to workplace clinics, rural health centers and employer wellness initiatives. Telemedicine services can complement employer workplace clinics as well as rural health centers. Telemedicine also supports wellness initiatives that employers offer to further employee health and well- being.
- Cost-effective care. Employees, retirees, and their families need access to health care that they can utilize because it is provided at an affordable, cost-effective rate
ERIC respects and supports the role of the Board in protecting the health, safety, and welfare of the people of the Louisiana, with the goal of ensuring that the highest quality of care is provided in the state. We applaud the Board for acknowledging that the same standard of care should apply to telemedicine and in-person visits. We also appreciate the Board’s technology-neutral definition of telemedicine.
Ultimately, to achieve a balanced regulatory environment for telemedicine, ERIC encourages the Board, to the extent permitted by law, to:
- ADOPT licensing policies that facilitate inter-state practice so providers, located in or out of the state, who deliver high-quality care, can serve patients located in Louisiana;
- ADOPT technology-neutral requirements, permitting use of different types of technology platforms that are designed for telemedicine;
- AVOID restrictions that require patients to visit specific locations (e.g., “originating sites”) in order to access telemedicine services;
- AVOID imposing additional requirements on providers that offer telemedicine services that are not imposed on in-person visits; and
- CONSIDER the needs of patients to have better access to care that can be provided via telemedicine, either through a telemedicine visit or remote monitoring of health conditions.
Thank you for considering large employers’ interests as you finalize your telemedicine rules. ERIC is pleased to represent large employers with the goal of ensuring telemedicine benefits are accessible for millions of workers, retirees, and their families. For more information about ERIC’s work on telemedicine, please contact me at 202- 627-1925 or awils@ERIC.org. ERIC welcomes additional questions and opportunities to contribute to your rulemaking process.
Executive Director, State Programs Senior Director, Health Policy
The ERISA Industry Committee