Ding, Ding: Round 2 of the Telehealth Program Begins

Kelley Drye & Warren LLP
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The application window for Round 2 of the COVID-19 Telehealth Program opened today at 12PM ET and will close at 12 PM ET on Thursday, May 6, 2021. As we have covered, the first round of funding was quickly distributed to over 200 applicants in over 40 states, with all funding exhausted by July 2020. Then, in December 2020, Congress authorized additional money to support telehealth services provided by non-profit and public healthcare organizations during the pandemic.

As with Round 1, this opportunity provides up to $1 million per application for equipment and services used for pandemic-related telehealth purposes. Specifically, the funding can be used “to support efforts of healthcare providers to address coronavirus by providing telecommunications services, information services, and devices necessary to enable the provision of telehealth services.” But there are three major differences this time:

  1. Applications will be reviewed as a group, rather than on a rolling basis, as they were in Round 1. The FCC has established the filing window for applications to run between 12PM ET on Thursday, April 29 through 12PM ET on Thursday, May 6. All applications must be submitted by the close of this filing window and will be evaluated based on the FCC’s criteria.
  2. The second major difference is that the FCC will be using the Universal Service Administrative Company (“USAC”), which administers other FCC funding programs, to evaluate applications. USAC evaluates the FCC’s Rural Health Care Program and will be bringing that expertise to this process
  3. Finally, the FCC has provided more detailed criteria for evaluating applications, with the goals of prioritizing certain types of applications and fair geographic distribution.

Providers must complete the FCC’s two registration requirements that must be met before an application is submitted. These tasks should get prospective applicants’ immediate attention given the short window.

  • File Form 460 with USAC to confirm the that the application’s lead site is eligible for the program
  • Register with the federal portal for payments, the System for Award Management

Next, providers should review the FCC’s final rules and the Public Notice to ensure that the equipment and services that they are requesting are eligible and meet the FCC’s requirements. Then, assemble the necessary information regarding the services and equipment that you want to purchase and the healthcare purposes for which they will be used. USAC, unlike last year, will notify applicants of any deficiencies and provide a 10-day period to cure the problem before denying an application.

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