The CARES Act - COVID-19 Telehealth Program

By Gerald Buggs, MSJ

The CARES Act (March 2020) has considerably expanded telehealth services and reimbursement eligibility for providers, including the relaxation of licensure and certification requirements and the waiver of Medicare rural site requirements. Along with these provisions, the CARE Act allocated $200 million to the Federal Communications Commission to support the FCC telehealth and RPM response efforts to COVID-19. Specifically, the CARES act created the COVID-19 Telehealth Program, a grant program offering up to $1 million per healthcare provider to fully–fund telehealth programs through the COVID-19 pandemic.

Program Eligibility

Eligibility for the COVID-19 Telehealth Program is limited to nonprofit and public eligible healthcare providers including:

    • Post-secondary educational institutions offering healthcare instruction, teaching hospitals and medical schools
    • Community health centers or health centers providing healthcare to migrants
    • Local health departments or agencies
    • Community mental health centers
    • Not-for-profit hospitals
    • Rural health clinics
    • Skilled nursing facilities
    • Consortia of healthcare providers consisting of one or more entities falling into the first seven categories

For-profit hospitals are not eligible to apply. To determine eligibility health care providers must receive an official eligibility determination from the Universal Service Administrative Company (USAC) for each provider site included within the grant application. Provider sites already deemed eligible (through prior participation in the Rural Health Care (RHC) Programs). Filing an official FCC Form 460. You can access the FCC Form 460, here.

Aside from basic contact and provider information, such as NPI code, a FCC Form 460 will require a brief explanation supporting the provider’s eligibility under section 254(h)(7)(B) of the Communications Act. After determining eligibility, all applicants must register for a FCC Registration Number (FRN) in the Commission Registration System (CORES). Here, you can begin filing with the FCC on behalf of your agency.

Services & Devices

Eligible healthcare providers can apply for funding for any telecommunications and/or telemedicine equipment purchased after March 13, 2020. Additionally, COVID-19 Telehealth Program funds will be available to eligible providers for services that require monthly recurring charges, such as broadband connectivity or RPM devices, through September 30, 2020.

    • Video consultation platforms and services
    • Remote Patient Monitoring platforms and services; patient reported outcome platforms
    • Store and forward services; asynchronous transfer of patient images and data for physician interpretation
    • Telecommunications Services and Broadband Connectivity Services: Voice consultation and Internet connectivity services.
    • Internet Connected Devices/Equipment: tablets, smart phones, or connected devices to receive connected care services remotely (broadband-enabled blood pressure monitors, pulse-ox, etc.); telemedicine kiosks/carts.

Application Information

The COVID-19 Telehealth Program application will again require basic contact, provider, and facility information including applicant title and email address, facility type and address, FCC Registration Number (FRN), National Provider Identifier (NPI), and more. In addition, the application requires clinical details regarding the application of telehealth and patient population. Required information includes:

    • Description of the services to be provided, the conditions to be treated and the goals and objectives.
    • Description of how COVID-19 has impacted the geographic area and any pre-existing strains on the community (under-served communities, wealth disparities, HCP shortages, limited broadband access, etc.)
    • Description of total patient population, and estimate of the number of patients that could be treated through grant funding.
    • Description of estimated number of patients to be treated
    • Description on the necessity of services/devices to improving patient care or relieving resource strain
    • Timeline for deployment of services and/or devices and a summary of the factors the applicant intends to track to measure program impact
    • Total funding requested and documentation supporting the necessity of those costs, such as a vendor or service provider invoice
    • Verify HIPAA compliance

 

COVID-19 Telehealth Program applications must reference WC Docket No. 20-89, which you can access, here. Application must be filed electronically through the FCC's Electronic Comment Filing System (ECFS) and also sent via email.

For more information, contact please contact Hayley Steffen, Hayley.Steffen@fcc.gov or at (202) 418-1586.

*** Note of Receiving Payments: To receive payments through the COVID-19 Telehealth Program, applicants must be registered with the Federal System for Award Management. Many providers may already be registered and will not have to re-register, but you can check your organizations registration status, here.

 

Tags: reimbursement, COVID-19

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