Takeaways

Eligible fund recipients include nonprofit and public health care organizations.
Program funding will support certain telehealth services for eligible health care providers.
The application window is open through December 7.

The FCC recently issued a Public Notice (following guidance released in September) announcing that the application filing window for its Connected Care Pilot Program (Pilot Program or Program) will be open until December 7, 2020. The Pilot Program will provide up to $100 million over three years to eligible health care providers to offset certain costs of delivering connected care services, with a focus on serving low-income and veteran patients. Although the Pilot Program is distinct from the FCC’s COVID-19 Telehealth Program launched earlier this year (previously summarized here), the Program complements broader efforts to expand telehealth services in light of the COVID-19 pandemic.

Eligible Health Care Providers

The FCC has limited eligibility to nonprofits and certain public health care providers in both rural and non-rural areas. Specifically, the following entities are eligible for Pilot Program funds:

  • Post-secondary educational institutions offering health care instruction;
  • 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; or
  • Consortia of health care providers consisting of one or more entities falling into the seven categories listed above.

Eligibility Determination

In order to access the Pilot Program application, interested parties must have first submitted Form 460 to the Universal Service Administrative Company (USAC) and received an eligibility determination. Note, however, that parties USAC has already deemed eligible to participate in the Rural Health Care Program or the COVID-19 Telehealth Program will be considered eligible and therefore do not need to complete another Form 460.

Eligible Program Costs

The Pilot Program will provide up to $100 million over three years to eligible health care providers to support 85% of the cost of the following:

  • Patient broadband internet access services;
  • Health care provider broadband data connections;
  • Other connected care information services; and
  • Certain network equipment necessary to support a broadband connection (e.g., routers).

The Pilot Program does not fund end-user devices, such as tablets, smart phones, or remote patient monitoring equipment, medical equipment, health care provider administrative costs, network deployment, network construction, or services facilitating connectivity between health care provider sites.

Fund recipients will be required to follow the applicable competitive bidding procedures for eligible items purchased with Program funds.

Program Application

The application is available on USAC’s website and can be submitted electronically via the USAC online portal. In terms of the application form itself, interested parties should be prepared to provide the following information:

  • Name, address, service area, Health Care Provider Number, Form 460 eligibility determination (each participating location must file an FCC Form 460), FCC Registration Number, and other contact information associated with the applicant organization.
  • Contact information for the individual responsible for the management and operation of the proposed pilot project.
  • Information regarding the health care provider sites included in the request, including patient population served, the health care provider designated lead, health care provider contact information for the various sites included in the proposal, rural or non-rural designations for each participating site, and other eligibility and site specific information.
  • Information on the conditions to be treated with Pilot Program funding, the participating providers’ experience treating such conditions, and specific services the providers propose offering. Additionally, information on goals, objectives, and metrics (including how participating health care providers will collect such metrics) for the proposed pilot must be described. Such goals and objectives must address plans to reach new patients, improve health outcomes, and how the project will benefit patients, providers or the overall health care industry.
  • Description of the costs for which Pilot Program funding is being requested (i.e., patient broadband internet access services, health care provider broadband data connections, information services needed to provide connected care services, and network equipment). The description provided must include details such as the required broadband speeds and technologies needed for the proposed project and an estimated number of patients that lack adequate broadband service for telehealth services. If the applicant is seeking support for an information service used for the delivery of connected care, a description of the primary function of the service and other technical information is required.
  • An overview of the participating health care providers’ experience providing telehealth services, existing community partnerships, and plans for implementing the proposed pilot project. Applicants must also provide documentation of the participating health providers’ financial health.
  • Information on whether the health provider applicant site serves a rural area. Alternatively, if the applicant is not located in a rural area, additional information on whether the health care provider will primarily serve veterans or low-income patients in rural areas, along with details on the services the project proposes to deliver, must be provided.
  • An estimate of total project costs, including costs eligible for support through the Pilot Program, as well as information on whether any of the participating health care providers have previously applied for and received funding through any of the FCC’s programs. Additional information on the cost of the project, including other anticipated sources of financial support and the applicant’s share of the cost, and whether a waiver of FCC rules may be needed for applicants to participate in the program, is also required.

Applicants should familiarize themselves with the Pilot Program rules and requirements and carefully review application materials prior to submission to ensure all components are accurate and complete. For additional information on the Pilot Program and application process, attorneys in Pillsbury’s Communications Practice Group are available to answer questions and to assist with the preparation of application materials.

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