March 31, 2022

Jacqueline Ward, PhD
Assistant Director at White House Office of Science and Technology Policy
Office of Science and Technology Policy
Executive Office of the President
Eisenhower Executive Office Building
Attn: Community Connected Health
1650 Pennsylvania Avenue
Washington, D.C. 20504

RE: Connected Health RFI

Dear Dr. Ward,

CEO Action for Racial Equity (CEOARE) is pleased to respond to the request for information (RFI) on Strengthening Community Health Through Technology. We commend the Office of Science and Technology Policy (OSTP) on its commitment to enhance the health and well-being of Americans and its focus on exploring how technology and innovation can benefit community health for all Americans. It was also a pleasure to participate with you and several of our collaborators in “The Future of Healthcare Post-Pandemic” discussion. In this letter, we seek to provide our perspective and policy principles focused on applying a racial equity and health equity lens to telehealth and digital health policy.

About CEOARE

CEOARE is a Fellowship of over 100 companies that mobilizes communities of business leaders with diverse expertise, across multiple industries and geographies, to advance public policy in four key areas — healthcare, education, economic empowerment, and public safety.

Evaluating historically underserved populations, the CEOARE Fellowship has a policy portfolio focused on eight public policy issues that disproportionately and systemically impact the 47M+ Black Americans. Our mission is to identify, develop, and promote scalable and sustainable public policies and corporate engagement strategies that address systemic racism, social injustice, and improve societal well-being. Our two policy priorities applicable to OSTP’s Community Connected Health initiative are: Expanding Access to Telehealth and Closing the Digital Divide.

Below, we respond to the specific RFI questions that implicate access to telehealth for Black Americans.

5. Tools and Training needs

Many underserved communities continue to experience inadequate access to consistent, culturally appropriate, and comprehensive care. We support efforts focused on enabling culturally competent, user-centered telehealth design and implementation, for significant and clinically meaningful community health including:

• Promoting access to diverse providers via telehealth platforms
• Gathering insights and perspective from the community and health equity organizations around telehealth as a tool to combat health inequities
• Encouraging healthcare and technology industries to collaborate with and advocate for community health needs in telehealth product and service design

For sustainable program success from implementation, both patients and providers need appropriate and culturally competent training and education to not only access telehealth services, but also to efficiently leverage services for improved health outcomes. We support efforts focused on digital health literacy, which fosters adoption, trust, and accountability, including:

• Culturally competent patient marketing, outreach, and education, within underserved communities
• Culturally competent healthcare provider training, translation, and accessibility around digital health services

6. Proposed government action

Barriers to health care in underserved communities can lead to increased health disparities and lower quality of life outcomes. Telehealth is one channel to expand healthcare access for underserved Americans to overcome these barriers. Through a joint health equity and racial equity lens, CEOARE advocates for permanence and equity in federal telehealth legislation, regulation, and product and service design as a solution to address the multidimensional needs of America’s underserved populations. Below we highlight our policy principles related to actions the government can take to address the barriers in access to telehealth.

Medicare telehealth service constraints, geographic eligibility requirements, originating site restrictions, and distant site practitioner limitations severely hinder broader expansion of telehealth services. While we applaud Congress and the White House for including telehealth provisions in the recently passed omnibus legislation, we continue to support the elimination of inequitable restrictions and barriers to coverage for comprehensive telehealth services, including:

• Permanent coverage of telehealth flexibilities expanded, via waivers, during the Public Health Emergency (“PHE”) – particularly, the removal of geographic eligibility requirements and originating site restrictions
• Broadband and end-user technology expansion policies targeting the digital divide, with special focus on policies that promote equitable access, affordability and use of telehealth services and technology
• Promotion of equitable telehealth access – facilitated by coverage of audio-only, video, and asynchronous telehealth modalities, prioritizing clinical appropriateness and patient informed consent
• Support for community health centers, Federally Qualified Health Centers, and similar safety net providers as telehealth qualified distant sites
• Amplification of underserved community perspectives and patient voices in policy development and promotion

7. Health Equity

Data reported on telehealth usage, adoption, and outcomes need to be racially stratified and examined to understand the impact on underserved patients and to develop appropriate interventions to narrow health disparities. Preliminary results show promise, and it will be important to monitor and promote additional improvements in capturing the experience and perspective of underserved communities through data. We support enhanced research that demonstrates the impact of telehealth and digital health expansion for underserved patients, including:

• Evaluation of claims and other payer data (including modality, technology used) to assess telehealth utilization across populations based on race/ethnicity and other social and demographic factors
• Improvements in data collection, including adequate funding and infrastructure, to measure the effectiveness, utilization, quality, and outcomes of telehealth for underserved communities that include social factors
• Health equity research principles that provide a holistic understanding of utilization and barriers to telehealth/digital health access, and encourage evidence-based decision-making to guide future policy and enable equitable expansion of telehealth

Thank you for your leadership, and for the opportunity to provide a response to the community health request for information. If you have questions, please do not hesitate to contact Roz Brooks via email at Roslyn.g.brooks@ceoactionracialequity.com.

Sincerely,

CEO Action for Racial Equity