The COVID-19 pandemic dramatically accelerated the adoption of telehealth services. In response to this urgent need, the Federal Communications Commission (FCC) launched the COVID-19 Telehealth Program. This initiative, backed by a $200 million fund from the CARES Act, aimed to support healthcare providers in delivering telehealth services to patients remotely. This guide provides a detailed overview of the Telehealth Care Program, addressing key aspects from its purpose and eligibility to application procedures and eligible services.
Purpose and Scope of the COVID-19 Telehealth Program
The COVID-19 Telehealth Program was established as an emergency measure to bolster telehealth capabilities during the public health crisis. Unlike a traditional grant, this program operates on a reimbursement basis. Approved healthcare providers can receive funding to cover eligible expenses incurred in providing telehealth services. It’s crucial to understand that this program is not an ongoing grant but a targeted response to a specific emergency, focusing on supporting immediate telehealth needs.
Key Objectives of the Program
- Rapid Deployment of Telehealth Services: The primary goal was to quickly enable healthcare providers to offer telehealth services, ensuring continuity of care during lockdowns and social distancing measures.
- Support for Remote Patient Care: Funding was specifically intended to facilitate healthcare delivery to patients at their homes or temporary locations, bridging geographical barriers and minimizing in-person contact.
- Financial Assistance for Telehealth Infrastructure: The program provided financial resources to eligible providers to acquire the necessary telecommunications services, information services, and connected devices for effective telehealth operations.
Navigating the Application Process for Telehealth Funding
While the initial application window for the COVID-19 Telehealth Program is now closed due to high demand, understanding the application process remains valuable for potential future telehealth funding opportunities. The process involved several key steps:
Prerequisites for Application
Before initiating an application, healthcare providers needed to fulfill specific prerequisites:
- USAC Eligibility Determination: Obtain an eligibility determination from the Universal Service Administrative Company (USAC) by filing FCC Form 460. This form verifies that the healthcare provider meets the program’s eligibility criteria.
- FCC Registration Number (FRN): Acquire an FRN through the FCC’s Commission Registration System (CORES). This number serves as a unique identifier for the applicant within the FCC systems.
- System for Awards Management (SAM) Account Registration: Begin the registration process for a SAM account. This federal system is required for receiving any disbursements from the program.
Step-by-Step Application Submission
The application process was conducted online through an FCC portal. Here’s a breakdown of the steps involved:
- CORES Account and FRN Registration: Create a CORES account and register for an FRN via the FCC CORES website. This involves setting up a username and password and providing organizational details to generate the FRN.
- Online Application Portal Access: Access the COVID-19 Telehealth Program application portal through the FCC website.
- Application Form Completion: Fill out the online application form, ensuring all mandatory fields are completed accurately. For detailed responses, applicants were advised to attach documents and reference them in the relevant fields.
- Application Submission: Submit the completed application through the portal. Upon successful submission, an automated confirmation with an application ID (starting with “GRA”) was generated.
Troubleshooting Application Issues
Applicants encountering difficulties during submission were advised to:
- Verify Mandatory Fields: Ensure all required fields in the application form were filled.
- Attachment for Lengthy Responses: For extensive narrative responses, upload them as attachments and indicate “See attachment [filename]” in the corresponding field.
- FRN Drop-down Selection: When entering the FRN, use the drop-down menu to select the registered FRN instead of manual typing to avoid errors.
For technical issues with CORES or the application portal, the FCC provided resources such as CORES FAQs, video tutorials, and a help desk support line.
Eligibility Criteria for Healthcare Providers
The COVID-19 Telehealth Program was specifically designed for non-profit and public eligible healthcare providers. Private, for-profit entities were not eligible to receive funding. The eligible categories aligned with section 254(h)(7)(B) of the 1996 Act and included:
- Post-secondary educational institutions offering healthcare instruction
- Teaching hospitals and medical schools
- Community health centers or health centers serving migrants
- Local health departments or agencies
- Community mental health centers
- Non-profit hospitals
- Rural health clinics (both rural and non-rural clinics were eligible under this program)
- Skilled nursing facilities
- Consortia of healthcare providers comprising one or more of the above entities
Determining Eligibility
To confirm eligibility, healthcare providers needed to obtain a determination from USAC by filing FCC Form 460 for each site seeking funding. Crucially, each healthcare provider site requiring funding needed its own eligibility determination and HCP number (Health Care Provider number), a unique identifier assigned by USAC upon eligibility approval.
Existing eligibility determinations under the FCC’s Rural Health Care Programs were also valid for this telehealth program, streamlining the process for providers already participating in those programs. Temporary or mobile locations of eligible providers were also considered eligible for support, broadening the program’s reach.
Applications from Multiple Healthcare Providers
The program accommodated applications from multiple healthcare providers, recognizing the collaborative nature of healthcare delivery.
Joint Applications
Multiple eligible healthcare providers could apply together under a single application. In such cases, each provider site still needed its own USAC eligibility determination. One entity was designated as the lead healthcare provider, responsible for application submission, reimbursement requests, and fund distribution to participating providers.
Healthcare Systems
Healthcare systems could apply in a manner best suited to their structure, either through a consolidated application or individual applications from each entity. However, it was noted that the FCC did not anticipate awarding more than $1 million to a single applicant, regardless of the application structure.
Eligible Services and Devices for Telehealth Implementation
The COVID-19 Telehealth Program focused on funding specific services and connected devices essential for delivering telehealth services. Funding was intended for items integral to patient care and directly related to telehealth operations during the pandemic.
Categories of Eligible Services and Devices
- Telecommunications Services and Broadband Connectivity: This included voice services and internet connectivity for both healthcare providers and their patients to facilitate telehealth interactions.
- Information Services: Covered a range of digital health services, including:
- Internet connectivity for telehealth purposes.
- Remote patient monitoring platforms and services for tracking patient health data remotely.
- Patient-reported outcome platforms for collecting patient feedback and health status updates.
- Store-and-forward services for asynchronous transfer of medical images and data for physician review.
- Platforms and services enabling synchronous video consultations for real-time virtual appointments.
- Connected Devices/Equipment: Funding supported the acquisition of connected devices for telehealth delivery, such as:
- Tablets, smartphones, or dedicated connected devices for patients to receive telehealth services at home.
- Broadband-enabled medical devices like blood pressure monitors and pulse oximetry monitors for remote patient monitoring.
- Telemedicine kiosks or carts for healthcare provider sites to enhance telehealth capabilities within facilities.
It’s important to note that only connected devices were eligible. Unconnected devices where patients manually report data were not covered. Connected devices included those with Bluetooth or WiFi capabilities, including devices that could connect to a patient’s smartphone.
Ineligible Costs
Certain costs were explicitly deemed ineligible for funding, including:
- Personnel costs (IT staff, medical professionals, administrative staff).
- Administrative expenses, marketing costs, and training costs.
- Website development or platform creation costs.
- Retroactive costs for services or devices purchased before March 13, 2020, or after December 31, 2020.
- Non-connected accessories, warranties, and maintenance costs.
- Non-connected medical devices and supplies.
- Construction costs and non-telehealth related items like office furniture.
Funding Disbursement and Reimbursement
The COVID-19 Telehealth Program operated on a reimbursement model. Funding was disbursed after eligible services and devices were purchased and implemented.
Reimbursement Process
- Invoicing Submission: Funding recipients were required to submit monthly invoicing forms along with supporting documentation to the FCC.
- Reimbursement Approval: The FCC reviewed the submitted invoices and documentation for compliance and eligibility.
- Electronic Payment: Upon approval, reimbursement payments were issued electronically to the healthcare provider’s registered SAM account.
System for Award Management (SAM) Registration
Registration with the federal SAM system was mandatory for receiving payments. Providers needed to register (or ensure existing registration was active) and provide necessary banking information for electronic fund transfers.
Selection and Prioritization of Applications
The FCC evaluated applications based on several criteria to ensure funding was directed to areas with the greatest need and potential impact.
Evaluation Criteria
- Conditions to be Treated: The types of health conditions to be addressed using telehealth funding.
- Program Goals and Objectives: The applicant’s clearly defined goals for utilizing telehealth program funds.
- Deployment Timeline: The proposed timeline for implementing telehealth services and deploying devices.
- Impact Measurement Metrics: Metrics and methods for assessing the impact of the telehealth program.
- Geographic Area and Population Served: The geographic area and demographics of the patient population, considering factors like underserved populations, healthcare shortages, and broadband access limitations.
- Targeting High-Risk and Vulnerable Patients: The extent to which funding was directed towards high-risk and vulnerable patient groups.
The FCC prioritized applications that targeted areas heavily impacted by COVID-19 and demonstrated the potential for significant impact on addressing healthcare needs. The application submission date was not the sole determinant for funding approval.
Procurement and Cost-Effectiveness
While the program waived competitive bidding requirements due to the emergency context, applicants were strongly encouraged to prioritize cost-effective purchasing of eligible services and devices. The FCC did not provide vendor recommendations, leaving vendor selection to the discretion of eligible healthcare providers.
Conclusion: The Legacy of the Telehealth Care Program
The COVID-19 Telehealth Program played a crucial role in rapidly expanding telehealth access during a critical period. By providing targeted funding and streamlining the application process, the FCC facilitated the adoption of telehealth services across a wide range of healthcare providers. While the initial funding phase has concluded, the lessons learned and the infrastructure established through this program continue to shape the landscape of telehealth and remote patient care, highlighting the importance of telehealth care programs in modern healthcare delivery.
Alt text: Screenshot of the COVID-19 Telehealth Program application portal login page, highlighting the FRN field with a dropdown menu for selecting the FCC Registration Number.
