Telemedicine: Challenges and Opportunities

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David Harlow

Presented at the Massachusetts Bar Association Annual Health Law Symposium (May 20, 2016)

Healthcare

Telemedicine: Challenges
and Opportunities
David Harlow JD MPH
THE HARLOW GROUP LLC
blog • healthblawg.com
twitter • @healthblawg
Health Law Symposium
Boston
May 20, 2016

Dynamic Tension
One foot in the past,
one foot in the future.

Telemedicine Modalities
Synchronous Asynchronous
Remote
Monitoring
Mobile Health

Health Insurance Exchange -
Network Adequacy
• Colorado to recognize telemedicine
providers for network adequacy
requirements for some specialties
(2017)
• Seems to be isolated instance thus far,
even though NAIC has built
telemedicine providers into its model
approach to assessing network
adequacy
• Urban Institute report

Employee Benefits > Medicare > Medicaid
Employee
Health
Benefit
Medicare
Medicaid
2016
expansion
50-State Coverage & Reimbursement

Interstate
Medical
Licensure
Compact
licenseportability.org

Can practice limits imposed
by a medical board be an
antitrust violation?

North Carolina –
Teeth Whitening
Imagecredit:msgolightlyviaFlickrCC

The Supremes said:
“a state board on which a controlling number of
decisionmakers are active market participants in the
occupation the board regulates” may invoke the state action
defense only when two requirements are satisfied: first, the
challenged restraint must be clearly articulated and
affirmatively expressed as state policy; and second, the
policy must be actively supervised by a state official (or state
agency) that is not a participant in the market that is being
regulated. N.C. State Bd. of Dental Exam’rs v. FTC, 135 S. Ct.
1101, 1114 (2015).

Texas – Board Bars Prescription
Without F2F Encounter & Teladoc Sues
• This fight has dragged on for five years already …
• Initial bar: By letter … Eventually: By regulation
• Teladoc won in US District Court, Texas Medical
Board appealed to 5th Circuit Court of Appeals

Bringing up the rear …
• Indiana’s F2F rule for Rx
writing has been
eliminated (except for
controlled substances)
effective July 1, 2016.
• Alaska, Arkansas & Texas
still require F2F visit to
establish physician-patient
relationship

Massachusetts
• Prescribing physician must have physician-
patient relationship
• Rule arose in context of online
pharmacies
• State licensure required (not part of
compact)

Expanding into chronic and behavioral health

Services that are not
“health care services”
but rather
“informational”
services

Link to recent
reports
& discussion
Data privacy and security issues

for contact info
txt dharlow to 50500
or scan the QR code
harlowgroup.net
healthblawg.com
twitter.com/healthblawg
david@harlowgroup.net
Thank You
David Harlow JD MPH
THE HARLOW GROUP LLC

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