Impact Insights

FCC COVID-19 Telehealth Program Funding Opportunity

Dan Golder

Applications for this program open today (April 13, 2020) at Noon EST at https://www.fcc.gov/covid-19-telehealth-program


UPDATE: APPLICATION PORTAL NOW AVAILABLE

The FCC application portal is now functioning and available for submissions

IF YOU HAVE ALREADY SUBMITTED A FILLABLE PDF APPLICATION, you DO NOT need to apply again. Your application is already under consideration by the FCC and they will contact you if they need any additional information.

IF YOU HAVE ALREADY DOWNLOADED AND STARTED A FILLABLE PDF APPLICATION, you can still complete it and email it to the mailbox at TelehealthApplicationSupport@fcc.gov. The FCC will still consider PDF applications and will contact applicants if they need any additional information.

New applicants are likely better off using the online portal. The video referenced below describes how to use the portal, and the application website still references the PDF form (FCC Form 5636) , instructions for its completion, an email address for submission, and an email address for questions.

We will update this blog post as more information becomes available.


On April 2, 2020, the Federal Communications Commission (FCC) released details on its “Promoting Telehealth for Low-Income Consumers COVID-19 Telehealth Program.” Two programs are established, the “COVID–19 Telehealth Program” and the “Connected Care Pilot Program.”

COVID–19 Telehealth Program

This program provides $200 million in assistance available from Congress as part of the CARES Act, (with a planned maximum of $1 million for any given organization), “to help eligible health care providers maximize their provision of connected care services during the COVID-19 pandemic.”

The support available from this program is targeted to specifically help eligible health care providers purchase telecommunications services, information services, and devices necessary to provide critical connected care services, whether for treatment of coronavirus or other health conditions during the coronavirus pandemic.

Connected Care Pilot Program

In addition to the COVID–19 Telehealth Program, the FCC has also established a parallel “Connected Care Pilot Program (Pilot Program)” (funded differently as a part of the Universal Service Fund (USF)) with an additional $100 million of available funding (over three years), to be used for similar (but longer-term) initiatives, particularly for low-income Americans and veterans.

Specifics for this program will be detailed in a subsequent blog post.

COVID–19 TELEHEALTH PROGRAM

When to Apply

Applications for this program open today (April 13, 2020) at Noon EST at https://www.fcc.gov/covid-19-telehealth-program


UPDATE: APPLICATION PORTAL NOW AVAILABLE

The FCC application portal is now functioning and available for submissions

IF YOU HAVE ALREADY SUBMITTED A FILLABLE PDF APPLICATION, you DO NOT need to apply again. Your application is already under consideration by the FCC and they will contact you if they need any additional information.

IF YOU HAVE ALREADY DOWNLOADED AND STARTED A FILLABLE PDF APPLICATION, you can still complete it and email it to the mailbox at TelehealthApplicationSupport@fcc.gov. The FCC will still consider PDF applications and will contact applicants if they need any additional information.

New applicants are likely better off using the online portal. The video referenced below describes how to use the portal, and the application website still references the PDF form (FCC Form 5636) , instructions for its completion, an email address for submission, and an email address for questions.

We will update this blog post as more information becomes available.


Applications can be submitted via a dedicated application portal at https://www.fcc.gov/covid-19-telehealth-program and are administered by the Wireline Bureau who has issued a public notice announcing the 4/13/20 date when COVID–19 Telehealth Program applications will be accepted and instructions for filing applications with the Commission. Information will also be available via the Commission’s Keep Americans Connected website.

To assist applicants in preparing their applications, an explainer video will also be posted on Monday on the FCC’s website at https://www.fcc.gov/covid-19-telehealth-program. Questions specific to the application process should be directed to EmergencyTelehealthSupport@fcc.gov.

Who is Eligible

The COVID–19 Telehealth Program will provide eligible health care providers (whether located in rural or non-rural areas) support to purchase telecommunications, information services, and connected devices to provide connected care services in response to the coronavirus pandemic.

What will be Funded

The COVID–19 Telehealth Program will provide selected applicants full funding for eligible services and devices.

  • The COVID–19 Telehealth Program will only fund monitoring devices (e.g., pulse-ox, BP monitoring devices), that are themselves connected.
  • The COVID– 19 Telehealth Program will not fund unconnected devices that patients can use at home and then share the results with their medical professional remotely.
  • The COVID–19 Telehealth Program will not provide funding for administrative costs associated with participating in the COVID–19 Telehealth Program or other miscellaneous expenses.

The Commission emphasizes that COVID–19 Telehealth Program funds may only be used for services and devices covered under the CARES Act. The costs of ineligible items must not be included in the reimbursement request for the COVID–19 Telehealth Program.

Funds ($200 million in total) will be available until they are expended or until the current pandemic has ended.

The Commission does not anticipate awarding more than $1 million to any single applicant.

Support will be awarded to eligible applicants based on the estimated costs of the supported services and connected devices they intend to purchase, yet awardees may use awarded support to purchase any necessary eligible services and connected devices, and are not limited to purchasing only the services and connected devices identified in their applications.

Applicants that have exhausted initially awarded funding may request additional support.

How to Apply

Applications can be submitted via a dedicated application portal at https://www.fcc.gov/covid-19-telehealth-program.

There are two separate application processes, a streamlined one for the for the COVID–19 Telehealth Program, and a second longer application process for the broader Connected Care Pilot Program.

Applications will be reviewed by the Wireline Competition Bureau, in consultation with the FCC’s Connect2Health Task Force and its medical and public health experts.

Selected participants and funding amounts for each selected applicant will be announced as rapidly as possible on a rolling basis, and additional applications will continue to be reviewed until funding is exhausted or the pandemic has ended.

Funding Preferences

Funding will be targeted towards areas that have been hardest hit by COVID–19, yet the Commission will not target specific medical conditions, patient populations, or geographic areas for the COVID–19 Telehealth Program.

The Commission recognizes that some health care providers may have been under preexisting strain (e.g., large underserved or low-income patient population; health care provider shortages; rural hospital closures; limited broadband access and/or internet adoption) and encourage applicants to document such factors in their applications.

The Bureau will seek to select as many applicants as reasonably possible within the COVID-19 Telehealth Program’s limited budget.

Funding Uses

The Commission strongly encourages selected applicants to target the funding they receive through the COVID–19 Telehealth Program to high risk and vulnerable patients to the extent practicable.

While health care providers may use the COVID–19 Telehealth Program to treat patients that have COVID–19, the program is not limited to treating those types of patients as long as program funds are used ‘‘to prevent, prepare for, and respond to coronavirus.” for example, by using telehealth services to remotely treat non-COVID patients and thereby provide additional hospital capacity for those affected by the coronavirus.

Eligible Providers

Limited to nonprofit and public eligible health care providers in the following categories:

(1) post-secondary 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
(8) consortia of health care providers consisting of one or more entities falling into the first seven categories.

Interested health care providers that do not already have an eligibility determination can obtain one by filing an FCC Form 460 with the Universal Service Administrative Company (USAC). Note that candidates can still submit applications for the COVID–19 Telehealth Program while their FCC Form 460 is pending.

Application Specifics

Applications must contain at a minimum the following information (see Appendix for additional specifics):

Contact Information

Names, addresses, county, and health care provider numbers (if available), for health care providers seeking funding through the COVID–19 Telehealth Program application.

The lead health care provider for applications involving multiple health care providers.

Contact information for the individual that will be responsible for the application (telephone number, mailing address, and email address).

Description of Services

  • Description of the anticipated connected care services to be provided, the conditions to be treated, and the goals and objectives.

This should include a brief description of how COVID–19 has impacted your area, your patient population, and the approximate number of patients that could be treated by the health care provider’s connected care services during the COVID–19 pandemic.

If you intend to use the COVID–19 Telehealth Program funding to treat patients without COVID–19, describe how this would free up your resources that will be used to treat COVID–19 and/or how this would otherwise prevent, prepare for, or respond to the disease by, for example, facilitating social distancing.

  • Description of the estimated number of patients to be treated.
  • Description of the telecommunications services, information services, or ‘‘devices necessary to enable the provision of telehealth services’’ requested.
  • The total amount of funding requested.
  • The total monthly amount of funding requested for each eligible item.

If requesting funding for devices, description of all types of devices for which funding is requested, how the devices are integral to patient care, and whether the devices are for patient use or for the health care provider’s use.

As noted previously, monitoring devices (e.g. pulse-ox, BP monitoring devices) will only be funded if they are themselves connected.

  • Supporting documentation for the costs indicated in their application, such as a vendor or service provider quote, invoice, or similar information.
  • A timeline for deployment of the proposed service(s).
  • A summary of the factors the applicant intends to track that can help measure the real impact of supported services and devices.

Required Certifications

COVID–19 Telehealth Program applicants will also be required, at the time of submission of their application, to certify, among other things:

  • Compliance with the Health Insurance Portability and Accountability Act (HIPAA) and other applicable privacy and reimbursement laws and regulations
  • Applicable medical licensing laws and regulations, as waived or modified in connection with the COVID–19 pandemic
  • All applicable COVID–19 Telehealth Program requirements and procedures, including the requirement to retain records to demonstrate compliance with program requirements and procedures for three years following the last date of service, subject to audit.
  • All applicable federal and state laws, including the False Claims Act, the Anti-Kickback Statute, and the Civil Monetary Penalties Law, as waived or modified in connection with the COVID–19 pandemic.
  • Applicants are not already receiving or expecting to receive other federal or state funding for the exact same services or devices for which they are requesting support under the COVID–19 Telehealth Program (which would include simultaneous funding for the Connected Care Pilot Program).

Requesting Funding, Invoicing & Disbursements

After receiving the eligible services and/or equipment, providers will submit invoicing forms on a monthly basis and supporting documentation to the Commission to receive reimbursement.

Disbursements will be issued directly to the participating health care providers rather than to the applicable service providers or vendors. Providers will be required to certify that funds will be used for their intended purpose.

Documentation Requirements

Waivers

Due to the time sensitivity associated with the COVID pandemic, a competitive bidding process to solicit and select eligible services or devices is not required, although applicants are strongly encouraged to purchase cost-effective eligible services and devices.

Similarly the normal prohibition for participating providers receiving gifts or things of value from service providers valued at over $20, including, but not limited to devices, equipment, free upgrades, or other items has been waived.

Document Retention: 3 years

Participants must maintain records related to their participation in the COVID–19 Telehealth Program to demonstrate their compliance with the program requirements (and to help guard against potential waste, fraud, and abuse) for at least three years from the last date of service.

Audits

Providers participating in the COVID–19 Telehealth Program may be subject to compliance audits in order to ensure compliance with the rules and  requirements, and to help guard against potential waste, fraud, and abuse, and must provide documentation related to their participation in connection with any such audit.

Feedback

Within six months after the conclusion of the COVID–19 Telehealth Program, participants should provide a report to the Commission in a format to be determined by the Bureau on the effectiveness of the COVID–19 Telehealth Program funding on health outcomes, patient treatment, health care facility administration, and any other relevant aspects of the pandemic.

Specific information about how to provide feedback and associated deadlines will be provided to participants at a later time.

Appendix: Application Specifics

As described above, Wireline will be administering the COVID–19 Telehealth Program applications, and the following provides additional application-specific detail, including registration with various different required agencies, as recommended by Wireline:

FCC Form 460

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

Individual Provider Information Required:

  • Address and contact information
  • Health care provider type
  • Brief explanation as to why the health care provider is eligible under the categories in section 254(h)(7)(B) of the Communications Act
  • Health care provider identifying number, such as a National Provider Identifier (NPI) codeand/or taxonomy code
  • Supporting documentation demonstrating the health care provider’s eligibility

Consortium Applicants Information:

  • Lead entity (Consortium Leader)
  • Contact person within the lead entity (the Project Coordinator)
  • Health care provider sites that will participate in the consortium

FCC Registration Number (FRN)

https://apps.fcc.gov/cores/userLogin.do

All applicants, like all other entities doing business with the Commission, must register for an FRN in the Commission Registration System (CORES). An FRN is a 10-digit number that is assigned to a business or individual registering with the FCC.

Steps required:

  • Create a username and account in the FCC User Registration System.
  • Verify account email address by responding to automated email titled “FCC Account Request Verification.”
  • Once the user is logged in to CORES, the user should select the “Register New FRN” or “Associate Username to FRN” option as applicable.
  • Provide the information as prompted by CORES, including the Taxpayer identification number or TIN.
  • Once the required information is provided, click “Submit.”
  • CORES will then generate a new FRN or associate the user’s existing FRN with its account.

Federal System for Award Management

https://www.sam.gov/SAM/

To receive payments through the COVID-19 Telehealth Program, applicants must be registered with the federal System for Award Management. Applicants are encouraged to start now because it may take up to 10 business days for registrations to become active and an additional 24 hours before registrations are available in other government systems.

Only applicants registered through the System for Award Management will be able to receive COVID-19 Telehealth Program funding.

The following information is needed:
(1) DUNS number
(2) Taxpayer Identification Number (TIN) or Employment Identification Number (EIN)
(3) Your bank’s routing number, your bank account number, and your bank account type (checking or savings), to set up Electronic Funds Transfer (EFT).

You will receive a confirmation email once the registration is activated.

Required Application Information for the COVID-19 Telehealth Program

Applicant Information

  • Applicant Name
  • Applicant FCC Registration Number (FRN)
  • Applicant National Provider Identifier (NPI)
  • Federal Employer Identification Number (EIN/Tax ID)
  • Data Universal Number System Number (DUNS)
  • Business Type (from Data Accountability and Transparency (DATA) Act Business Types) – Applicants may provide up to three business types
  • DATA Act Service Area – This information will be required for each line item for which funding is requested. Applicants must enter name of the applicable state(s) or “nationwide.”

Contact Information

  • Contact name for the individual that will be responsible for the application
  • Position title
  • Phone number
  • Mailing address
  • Email address

Health Care Provider Information

  • Lead health care provider name (if part of a consortium)
  • Facility name
  • Indicate whether facility is a hospital
  • Street address, city, state, county
  • FCC Registration Number (FRN)
  • Healthcare provider number
  • Eligibility type
  • National Provider Identifier (NPI)
  • Total patient population
  • Estimated number of patients to be served by the funding request (and supporting documentation)

Medical Services to be Provided (applicants will check all that apply)

  • Patient-Based Internet-Connected Remote Monitoring
  • Other Monitoring
  • Video Consults
  • Voice Consults
  • Imaging Diagnostics
  • Other Diagnostics
  • Remote Treatment
  • Other Services

Conditions to be Treated with COVID-19 Telehealth Funding

  • 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
    • Routine, Non-Urgent Care
    • Mental Health Services (non-emergency)
    • Other conditions
  • How using 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

Additional Information Concerning Requested Services and Devices

  • Goals and objectives for use of the COVID-19 Telehealth Program Funding
  • Timeline for deployment of the proposed service(s) or devices funded by the COVID-19 Telehealth Program
  • Factors/metrics the applicant will use to help measure the impact of the services and devices funded by the COVID-19 Telehealth Program
  • How COVID-19 has affected health care providers in your area
  • Any additional information about the geographic area and population serve by the applicant. Indicate whether the geographic area you serve has been under any pre-existing strain (e.g., large underserved or low-income patient population; HCP shortages; rural hospital closures; limited broadband access and/or Internet adoption). If so, describe such factors.
  • Whether the applicant plans to target the funding to high-risk and vulnerable patients. If so, describe how.
  • Any additional information to support the application and request for funding

Requested Funding Items

  • Total amount of funding requested
  • Whether funding for devices is being requested. If so:
    • How are the devices integral to patient care?
    • Are the devices for patient use?
    • Are the devices for the health care provider’s use?

Supporting Documentation

  • An applicant should provide supporting documentation for the costs indicated in its application. Such supporting documentation should summarize the expected costs of the eligible services and devices requested and may include documentation such as an invoice or quote from a vendor or service provider (or similar information). Such information should be specific enough to identify line-items to facilitate swift review of the application, and we encourage applicants to include information such as a description of the service or device, its eligibility category, the quantity ordered, the upfront and monthly expenses, and the service dates for recurring services.

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