Telehealth Providers May Get a Financial Boost Under the FCC’s Connected Care Pilot Program

On April 2, 2020, the FCC adopted final rules to establish the Connected Care Pilot Program with the intent of helping defray the cost of providing certain telehealth services. The Connected Care Pilot Program will provide up to $100 million from the Universal Service Fund over a three-year period to support the provision of connected care services, with an emphasis on supporting these services for low-income Americans and veterans. On September 3, the FCC issued a Public Notice providing additional information and guidance for potential applicants interested in applying for the Connected Care Pilot Program. The FCC intends to provide additional, specific information regarding the Pilot Program in a separate, upcoming Public Notice.

Program Basics

The Pilot Program will use Universal Service Fund funding to help defray costs of connected care services for eligible health care providers, providing universal service support for 85% of the cost of eligible services and network equipment, which include: (1) patient broadband internet access services; (2) health care provider broadband data connections; (3) other connected care information services; and (4) certain network equipment. The Pilot Program will not provide funding for devices.

Eligible Health Care Providers

The Pilot Program is open to nonprofit and public eligible health care providers that fall within the statutorily detailed categories of “health care provider” in section 254(h)(7)(B) of the Telecommunications Act of 1996, whether located in rural or non-rural areas.

Such eligible providers include, for example:

• post-secondary educational institutions offering health care instruction, teaching hospitals, and medical schools;
• community health centers or health centers providing health care to migrants;
• local health departments or agencies;
• community mental health centers;
• not-for-profit hospitals;
• rural health clinics;
• skilled nursing facilities; and
• consortia of health care providers consisting of one or more entities falling into the first seven categories.

Application Window Not Yet Specified

The FCC is not yet currently accepting applications, and the FCC does not anticipate that Pilot Program applications will be accepted before November 2020.

Eligibility Determinations Required Before Applications Are Filed

Although applications are not yet being accepted, it is critical that any interested providers start seeking an “eligibility determination” now. An eligibility determination and HCP number are required for each health care provider site that will be included in an application for the Pilot Program.

• Eligible health care providers can take steps to obtain an eligibility determination by filing an FCC Form 460 with the Universal Service Administrative Company (USAC) in order to obtain a Health Care Provider (HCP) number and eligibility determination.
• Health care provider sites that USAC has already deemed eligible to participate in the FCC’s Rural Health Care Program or COVID19 Telehealth Program may rely on that eligibility determination for the Pilot Program.

Arent Fox can provide additional information about the Connected Care Pilot Program, as well as help health care providers navigate the eligibility process and, when finalized, the application process. More details on the Pilot Program also can be accessed at the FCC’s Connected Care Pilot Program webpage.