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5 Questions before the $250M FCC Telehealth Program Application Window Opens | April 19, 2021

Sid Kandan

Background on Historic $550M FCC Telehealth and Connected Care Program

The FCC’s Telehealth and Connected Care Program is the government’s largest investment into connected health to date. This Program fully funds telecommunications services, information services, and devices necessary to provide critical connected care services to patients at their homes in response to the COVID-19 pandemic. As seen by the vaccine rollout with elderly and disadvantaged populations, as channels to receive care change, it is critical to invest in connectivity for patients to ensure no one is left behind.

The first round was a critical success with over 539 Awardees receiving funds to improve connected care for their patients. We have personally seen this program benefit high-risk, vulnerable, and aging populations that never expected to receive connected care! The application window for Round 2 opens on April 29th and has the potential to connect one million high-risk patients with connected devices and services for a year. (more on round 2’s application process here)

First, we wanted to thank USAC and the FCC for all their hard work in rolling out this historic program! Given the accelerated timeline of the Round 1 roll out and the enormous number of submission (4000+), both organizations have performed a herculean feat with the first Round of FCC applications! Especially as this was all executed amidst a global pandemic. We can only imagine the magnitude of work involved in administering these funds. (more on our review here)

With the application window slated to open in less than 2 weeks, we had some questions regarding the outreach program and changes to the application and reimbursement forms. This review is provided in a spirit of collaboration across a complex and evolving industry which is vital to bridging the digital divide and providing access to care during this unprecedented time. We are excited by the potential for updates in Round 2 to maximize the number of connected patients!

Question 1: How is USAC / the Bureau determining eligible items when allocating funds to each awardee?

To ensure program funds were invested into improving connected care for patients, the FCC created FAQs (#27-31) to clarify eligible and ineligible devices and services.

(click images below to expand)

The FAQs and documents stressed that non-connected devices, staffing, professional, consulting services, and devices not critical for providing care to patients at their home would not be eligible.
However, due to the urgency of the first round, the following applications incorrectly listed certain requests as eligible:

For Round 2, how are these items filtered out when allocating funds to awardees?
With the $250M pool determining the number of awardees receiving funds, it's critical to ensure that funding isn't allocated or held for ineligible items. Imagine it will be difficult for USAC and the Bureau to verify the eligibility of requested items in this limited timeframe.
Can Vendors submit standardized forms to prove eligibility?
Or perhaps trusted and independent organizations can publish a review of eligible items?

Question 2: Clarifications on Round 2’s Report & Order
(Appendix B, pg.44 - Eligible Services and Devices)

“The costs for taxes, shipping, and installation or integration of eligible devices and services, are also eligible expenses” 


If the program is only for non-profits, in what situations would non-profits pay taxes?
Why are program dollars set to reimburse taxes?

How is USAC going to track and enforce when (permitted) “installation or integration” cost transitions to (ineligible) “admin costs, labor, training, support, maintenance, warranties, protection”?
How are they defining the difference between installation and integration vs. IT Staff and admin expenses or development of a new system/platform?

What’s USAC’s process to identify if vendors and applicants include staff, travel, labor and consulting costs under “integration” fees?
Would systems and vendors need to break down consulting and services fees under installation and integration line items? Is there proof of installation or integrations required to be shown?

Question 3: What is USAC's / the Bureau's process for tracking accessibility and adoption by vulnerable patients? How is USAC / the Bureau tracking how technology for staff-only benefits patients?

The intention of the program is to fund better care to vulnerable populations and communities. The new scoring process also validates awarding funds to those vulnerable patients.

However, in our Round 1 analysis, we found that over 50% of awardees requested equipment for staff-only.
This may change channels of care, but does not guarantee patients access to those channels. Especially vulnerable populations.

Are there limits or requirements to ensure that funding doesn't end up going to non-healthcare solutions when so many patients are in need of connectivity?

Question 4: During the reimbursement review process and award outcomes, which Agency is responsible for tracking eligibility and usage?

For example, this awardee received $909,560 for in-patient fall sensors.

“Alert units which are virtual patient monitoring devices were installed in patient rooms, enabling remote monitoring of vitals of patients”

Please note - We do not blame the awardee or USAC/FCC for this award, as the vendor's advertising and timing of the first rounds probably contributed to this confusion.

Curious how vendors and systems can demonstrate eligibility in the reimbursement form process moving forward? Would be great to understand how these metrics also help other government sponsored programs to bridge the digital divide.

Question 5: How is USAC and the Bureau tracking cost-effectiveness of solutions?

Is there consideration to setting limits on costs for devices and services for requested solutions?

For example, we have seen massive variations with the following:

Remote patient monitoring -
Non-tablet and cellular (non-broadband dependent) solutions:

Remote patient monitoring -
Tablet and broadband dependent solutions:

Remote patient monitoring -
Vitals Device Only (for patients with compatible smartphones + tech literacy):

Remote patient monitoring -
Other Devices:

Equipment for Staff Only:

More on our review of the Round 1 Awarded Applications: https://www.stel.life/blog/fcc-telehealth-round1-review