Starting at 9 AM Pacific on April 13, 2020, the FCC will begin to accept applications for its COVID-19 Telehealth Program, funded by $200 million dollars allocated by the CARES ACT. This program will fully fund telecommunications services, information services, and devices necessary to provide critical connected care services.

The FCC does not expect to award more than $1 million to any single applicant. Healthcare providers may use the funds for purchases made on or after March 13, 2020, and such funds may be used for monthly recurring charges through September 30, 2020.

Applicants must obtain (1) an eligibility determination from the Universal Service Administrative Company (USAC); (2) an FCC Registration Number (FRN) through CORES - https://apps.fcc.gov/cores/use...; and (3) register with System for Award Management - https://www.sam.gov/SAM/. The healthcare provider sites which the USAC has already deemed eligible to participate in the Rural Health Care Programs may rely on that determination for this program. Applicants that have yet to receive an eligibility determination from the USAC may still apply while the USAC reviews the FCC Form 460.

The Telehealth Program allows participation of the following types of healthcare entities: (1) postsecondary educational institutions offering health care instruction, teaching hospitals, and medical schools; (2) community health centers or health centers providing health care to migrants; (3) local health departments or agencies; (4) community mental health centers; (5) not-for-profit hospitals; (6) rural health clinics; (7) skilled nursing facilities; and (8) consortia of health care providers consisting of one or more entities falling into the first seven categories.

The FCC provided the following examples of eligible services and devices:

  • Telecommunications Services and Broadband Connectivity Services: Voice services, and Internet connectivity services for health care providers or their patients.
  • Information Services: Remote patient monitoring platforms and services; patient reported outcome platforms; storage and forwarding services, such as asynchronous transfer of patient images and data for interpretation by a physician; platforms and services to provide synchronous video consultation.
  • Internet Connected Devices/Equipment: tablets, smart phones, or connected devices to receive connected care services at home (e.g., broadband enabled blood pressure monitors; pulse-ox) for patient or health care provider use; telemedicine kiosks/carts for health care provider site.

The FCC application will include the following categories (including how telehealth funding can help free up resources that can then be used to treat COVID-19 patients):

Types of medical services:

  • Patient-Based Internet-Connected Remote Monitoring
  • Other Monitoring (e.g. pulse-ox, BP monitoring)
  • Video Consults
  • Voice Consults
  • Imaging Diagnostics
  • Other Diagnostics
  • Remote Treatment
  • Other Services

Note that the Program will only provide funding for monitoring devices that are connected, not devices that patients can use at home and then share the results with their healthcare provider remotely. The FCC will not require applicants to purchase only those services or devices identified in their applications. Health care providers may use funds to purchase any necessary eligible services and connected devices. Further, applicants may request additional support funds after they have exhausted the initial award.

Conditions to be awarded funds under this Program funding include:

  • Whether the applicant will treat COVID-19 patients directly
  • Whether the applicant will treat patients without COVID-19 symptoms or conditions (applicants will check all that apply):
    • Other infectious diseases
    • Emergency/Urgent Care o Routine, Non-Urgent Care
    • Mental Health Services (non-emergency)
    • Other conditions
  • How using the COVID-19 Telehealth Program funding to treat patients without COVID-19 symptoms or conditions would free up resources that will be used to treat COVID-19.

The FCC Order on April 2, 2020 also launched the Connected Care Pilot Program “to help defray health care providers’ qualifying costs of providing connected care services, with a primary focus on providing these services to low-income or veteran patients.” The funding of this program includes $100 Million over three years, and will cover 85% of the eligible costs of broadband connectivity, network equipment, and information services necessary to provide connected care services to the intended patient population. Applications for this Pilot Program are not due for 45 days from the effective date of the Pilot Program rules, or 120 days from the release date of the FCC order (whichever is later).

For more information about applying for funding, deploying telecommunications services (including software, fiber, and DAS contract review), and telehealth, please contact Elana Zana at 206-442-1308 or ezana@omwlaw.com.

Relevant Resources:

FCC Webinar & Application Materials on COVID-19 Telehealth Program: https://www.fcc.gov/covid-19- telehealth-program

FCC Guidance on COVID-19 Telehealth Program: https://docs.fcc.gov/public/attachments/DA-20- 394A1.pdf

FCC Form 460: https://www.usac.org/rural-health-care/resources/forms/

FCC Order (April 2, 2020): https://docs.fcc.gov/public/attachments/FCC-20-44A1.pdf

To see more COVID-19 updates, visit our COVID-19 Info Hub.

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