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Nation’s health informatics experts see broadband as social determinant of health, argue for use of exemptions

BETHESDA, MD – In comments submitted to the House Energy & Commerce Subcommittee on Communications and Technology, the American Medical Informatics Association (AMIA) urged lawmakers to view broadband access as a social determinant of health, warranting a more nuanced approach to managing Internet traffic through tiered pricing, known as paid prioritization.

The Federal Communications Commission (FCC) has finalized a rule, effective April 23, 2018, known as the Restoring Internet Freedom Order, that eliminates existing prohibitions on paid prioritization, blocking, and throttling of Internet traffic by Internet Service Providers (ISPs). Critics of the rule worry that these prohibitions have protected consumers from deceptive practices and upheld an ethos long-considered fundamental to the evolution of the Internet. Proponents see the rule as a way to engender competition and innovation, lower costs, and lead to expanded broadband coverage.

AMIA applauded Congress for delving into the contentious and uncertain issue of paid prioritization. The organization’s comments were submitted as part of a subcommittee hearing, “From Core to Edge: Perspective on Internet Prioritization,” which was held Tuesday to help lawmakers understand the tensions related to paid prioritization.

AMIA noted that (1) access to high-speed broadband greatly determines the trajectory of individuals’ health; (2) increasingly, care is delivered outside the four walls of our traditional healthcare system and more data are being exchanged across geographic and organizational boundaries to support such care; and (3) individuals are being empowered and incentivized to leverage consumer technologies to prevent and manage disease through Internet-connected devices.

“Together, these factors presage a need to ensure a robust health broadband economy driven by public policy that encourages low-cost broadband options with open access and transparent terms of service,” AMIA said. “This is especially needed for medically underserved Americans, who are more likely to reside in poor and rural areas of the country where existing broadband options are inferior.”

“When viewed through the prism of health, Broadband access becomes a prerequisite,” said Douglas B. Fridsma, MD, PhD, FACP, FACMI, AMIA President and CEO. “Healthcare has gone digital, so the means to access and benefit from this system will, increasingly, require both digital connections and digital competencies.”

Because the issue of net neutrality is so contentious and the evidence base so scant, AMIA established a foundational position that the role of public policy should be one that encourages low-cost, open access broadband options with transparent terms of service. Such services would not include additional costs to connect to specific kinds of applications and content, and the services would clearly state their performance expectations.

While AMIA understood the basic rationale behind paid prioritization, the organization questioned why existing policy mechanisms, such as exemptions, were not viewed more favorably. Under the existing Open Internet Order, specific kinds of Internet traffic, such as data in service of telehealth, can already apply for an exemption by declaring itself non-Broadband Internet Access Services, or non-BIAS data services.

“AMIA recommends a thoughtful examination of exemptions, rather than wholesale removal of the prohibition, as a reasonable and responsible next step. Congress could review the number and nature of exemption applications, as well as consider the impact of the exemptions once granted.”

“For many Americans, Internet access is fast, responsive, consistent, and ubiquitous,” said Jeff Smith, MPP, AMIA Vice President of Public Policy. “But as care becomes more distributed and virtual, and demand for data-intensive applications increases, we must ensure that public policy – or the lack thereof – does not worsen health disparities.”


AMIA, the leading professional association for informatics professionals, is the center of action for 5,500 informatics professionals from more than 65 countries. As the voice of the nation’s top biomedical and health informatics professionals, AMIA and its members play a leading role in assessing the effect of health innovations on health policy, and advancing the field of informatics. AMIA actively supports five domains in informatics: translational bioinformatics, clinical research informatics, clinical informatics, consumer health informatics, and public health informatics.