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Frequently Asked Questions
1. Has the FCC released the rules yet for the second round?
No, FCC released proposed rules on January 6; we expect final rules to be released soon. The FCC has asked for comments on proposed rules by January 19.
2. If we participated in the first round, will we need to file a new application?
The FCC has not released the final requirements yet, but the proposed rules include a requirement that all applicants file a new application in the second round. The application format will likely be different and may not require the registration with USAC, which was part of round 1.
3. When is the deadline for filing applications in the new round?
The FCC has not yet established a filing deadline, but it has proposed that there will be an “application window” during which applications must be filed. In the first round, the FCC accepted applications on a rolling basis, and the timing of when an applicant filed was very important in determining success. We expect that timing will be less important in this round, although it is still a good idea to get the application in as soon as possible once the application window opens, which we predict will be in late January/early February.
4. Will the FCC give priority to applicants from the first round that did not win?
The FCC has not provided a statement on whether it will give priority to applicants from the first round which did not receive funding.
5. Am I disqualified from funding if I received funding in the first round?
The FCC has not given an opinion on whether prior funding will influence its decisions.
6. Has the FCC given any indication of what types of applications it will prioritize?
The legislation authorizing the $250 million disbursement called for “equitable” distribution among the 50 States and the District of Columbia (it did not mention territories such as Puerto Rico and US Virgin Islands), requiring that at least one application be granted in each state including Washington DC. Also, the FCC must inform each applicant of the rationale for a final funding determination and give it an opportunity to submit additional information in support of its application. Although the FCC has not published what metrics in addition to equitable distribution across the country it will use to evaluate applications, it has asked for comments on the following factors it is considering:
• If area served by the applicant is hard hit by COVID or a new strain of COVID
• Whether funding will be used to treat COVID patients
• Whether funding will be used to treat “at-risk” populations
• Whether applicant received funding in the first round
• Whether applicant applied and did not receive funding in the first round
7. Does it make sense to file comments with the FCC on January 19th?
If the success of your application might be affected by the decisions on the criteria being considered by the FCC (eg, if you would be helped if unsuccessful first round applicants were given priority), then it makes sense to comment. We can provide referrals to attorneys who can help with this process.
8. What types of providers qualify for the funding?
The FCC has not specified yet for the second round, but the same categories of providers will likely qualify as during the first round:
(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; or
(8) consortia of health care providers consisting of one or more entities falling into the first seven categories.
9. Are private, or for-profit health care providers eligible, such as a private physician’s practice?
Unless the FCC changes the rules for the second round, which is unlikely, private and for-profit entities, are not eligible to receive funding through the COVID-19 Telehealth Program. For example, a private physicians’ practice would not be eligible for support through this program.
10. Can I establish a password or other security to lock the device when not in use?What services and connected devices are eligible for COVID-19 Telehealth Program funding?
Unless the FCC changes the standards from the first round, COVID-19 Telehealth Program funding will provide eligible health care providers support to purchase telecommunications, information services, and connected devices necessary to provide telehealth services to patients in response to the coronavirus pandemic. Devices for which funding is requested must be integral to patient care.
The COVID-19 Telehealth Program will only fund devices (e.g., pulse oximetry, blood pressure monitoring devices, etc.) that are themselves connected, and will not fund unconnected devices that patients can use at home and then manually report the results to their medical professional. Connected devices may include devices with Bluetooth or WiFi connectivity, including devices that connect to a consumer’s phone, for example.
Examples of eligible services and connected devices that COVID-19 Telehealth Program applicants may seek funding for include:
• Telecommunications Services and Broadband Connectivity Services: Voice services, for health care providers or their patients.
• Information Services: Internet connectivity services for health care providers or their patients; remote patient monitoring platforms and services; patient reported outcome platforms; store and forward services, such as asynchronous transfer of patient images and data for interpretation by a physician; platforms and services to provide synchronous video consultation.
• Connected Devices/Equipment: Tablets, smart phones, or connected devices to receive connected care services at home (e.g., broadband-enabled blood pressure monitors; pulse oximetry monitors) for patient or health care provider use; or telemedicine kiosks/carts for health care provider sites.
11. Are personnel, IT, administrative, and training costs eligible for support?
No, unless FCC changes rules for the second round, funding will not be provided for personnel costs (including but not limited to costs for IT staff, project managers, or medical professionals), marketing costs, administrative expenses, or training costs. Vendors and service providers can elect to provide training and other IT support at no cost to health care providers participating in the program. Eligible health care providers should not include the cost of ineligible items in their funding application.
12. Will FCC fund the building of websites or the development of new platforms for providing connected care services?
No. Only eligible connected care services and devices may be funded by the COVID-19 Telehealth Program; the program is not intended to fund development of new websites, systems, or platforms.
13. Are retroactive costs eligible for funding?