The FCC's application portal for the COVID-19 Telehealth Program is open as of noon on Monday, April 13. Services and devices purchased on or after March 13, 2020 will be eligible for support. While the COVID-19 program will provide full funding for eligible services and devices, the FCC expects to limit funding to $1 million per successful applicant. Funding will be awarded on a rolling basis until all $200 million is awarded. Interested providers should file their applications as soon as possible.

Guidance on eligible services and devices

The FCC has released a public notice that lists services and devices the FCC expects to be able to fund. The list is illustrative, not exclusive:

  • Internet connected devices and equipment: Covered devices include smartphones; tablets; connected devices to receive connected care services at home (such as blood pressure monitors); and telecommunications kiosks or carts at the provider's location.
  • Voice and internet services: These services would be funded for both providers and patients.
  • Other information services: These services would include remote patient monitoring platforms; reported outcome platforms; services that store and forward patient information; and synchronous video consultation.

Services and devices purchased on or after March 13, 2020, will be eligible for support. While the COVID-19 program will provide full funding for eligible services and devices, the FCC expects to limit funding to $1 million per successful applicant. Funding will be awarded on a rolling basis until all $200 million is awarded.

Information for the application

The application will request the following information:

  • Medical services to be provided: The FCC expects providers to request funding for patient-based, internet-connected remote monitoring; other monitoring; video consults; voice consults; imaging diagnostics; other diagnostics; and remote treatment as eligible for funding. Providers may also request funding for services not on this list.
  • Conditions to be treated with COVID-19 telehealth funding: The application asks whether the provider will treat COVID-19 patients directly and whether it will treat patients without COVID-19 symptoms or conditions (and what symptoms or conditions will be treated). If the provider will treat patients without COVID-19 symptoms or conditions, it must explain how using the COVID-19 program funding to treat patients without COVID-19 symptoms or conditions would free up resources that will be used to treat COVID-19.
  • Devices: If requesting funding for devices, providers must include a description of the devices, how the devices are integral to patient care and whether the devices are for patient use or for the healthcare provider's use.

Prerequisites for any application

Before any healthcare provider can apply for COVID-19 program funding, it must complete certain steps:

  • It must have an FCC Registration Number (FRN) to file a funding application. Applicants that do not already have an FRN can obtain one from the FCC.
  • It must have an eligibility determination from the Universal Service Administrative Company (USAC). Applicants that already have an eligibility determination do not need to reapply, but any applicant that does not have one must file FCC Form 460 with USAC before filing an application. Providers can apply for the COVID-19 program while an eligibility determination is pending.
  • It must register with the federal System for Award Management (SAM) to receive funding. This process does not need to be completed to submit an application, but no payments can be made until the registration process is completed. Applicants that already are registered with SAM do not need to re-register.

Application process

The application can be accessed at the FCC's dedicated page for the COVID-19 Telehealth Program. The FCC's webpage also contains an explanatory video that discusses how to complete the application.

Eligibility and participation

Cooley's original alert on the COVID-19 program includes other important information on what entities are eligible to apply for funding, how the FCC will evaluate applications and other important elements of the application process. Lawyers in the Cooley communications practice can assist in preparation of applications and related materials.

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