Protecting and Promoting the Open Internet – Net Neutrality Comments Filed

CTN filed reply comments with the FCC on September 10, 2014

The California Telehealth Network (“CTN”) provides HIT solutions to improve the integration and delivery of healthcare services across a wide variety of practices. CTN emphasizes improving delivery to medically-underserved communities, including safety net clinics as well as critical access and rural hospitals. Without the broadband facilities and telehealth services provided by CTN, thousands of patients would not have access to any specialty diagnosis or care, let alone other telehealth services. Thus, CTN, the clinics and doctors it serves and the patients receiving telehealth services as a result of CTN are all stakeholders in the Internet ecosystem for telehealth and have an interest in how the Commission defines the open Internet for telehealth in this Notice of Proposed Rulemaking (“NPRM”).

CTN is concerned that the discussion of regulating management practices of the ISPs might be decided in the context of the debate over “net neutrality.” The NPRM does not directly ask for comments on the relationship between telehealth and the open Internet. Although the Commission asks generally for comment on “developments in the
Internet’s ecosystem since 2010,” the specific questions posed in the NPRM are limited to important issues concerning free expression, competition for entertainment and information content, and education applications. CTN files these reply comments in response to the NPRM out of concern that the record thus far does not describe fully the
“use case” for telehealth.