Federal Communications Commission	DA 21-1053



DA 21-1053
Released:  August 26, 2021

WIRELINE COMPETITION BUREAU AND OFFICE OF THE MANAGING DIRECTOR PROVIDE INVOICING GUIDANCE FOR ROUND 2 OF THE COVID-19 TELEHEALTH PROGRAM
WC Docket No. 20-89

In this Public Notice, the Wireline Competition Bureau (Bureau) and the Office of Managing Director (OMD) provide funding recipients of Round 2 of the Commission’s Coronavirus Disease 2019 (COVID-19) Telehealth Program (Telehealth Program) with guidance on the invoicing requirements and processes for Round 2 of the Program.

On March 30, 2021, the Federal Communications Commission (Commission) released the Second COVID-19 Report and Order COVID-19 Telehealth Program; Promoting Telehealth for Low-Income Consumers, WC Docket Nos. 20-89 and 18-213, Report and Order and Order on Reconsideration, 36 FCC Rcd 7141 (2021) (Second COVID-19 Report and Order).
 launching Round 2 of the Telehealth Program, established pursuant to the Coronavirus Aid, Relief, and Economic Security (CARES) Act. See Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No 116-136, 134 Stat. 281, 531 (2020) (CARES Act); Promoting Telehealth for Low-Income Consumers; COVID-19 Telehealth Program, WC Docket Nos. 18-213, 20-89, Report and Order, 35 FCC Rcd 3366 (2020) (First COVID-19 Report and Order).
  In the Second COVID-19 Report and Order, the Commission adopted additional requirements and processes for Round 2 to further fund telehealth and connected care services in response to COVID-19 pursuant to the additional funding and requirements in the Consolidated Appropriations Act, 2021 (Consolidated Appropriations Act). Consolidated Appropriations Act, 2021, Pub. L. No:  116-260, Division N-Additional Coronavirus Response and Relief, Title IX-Broadband Internet Access Service, § 903 “FCC COVID-19 Telehealth Program” (2020), https://www.congress.gov/bill/116th-congress/house-bill/133/text (Consolidated Appropriations Act).
  

From April 29, 2021, through May 6, 2021, the Universal Service Administrative Company (USAC) accepted applications for Round 2 of the Program. COVID-19 Telehealth Program, WC Docket No. 20-89, Report and Order, 36 FCC Rcd 1613 (2021) (expanding the responsibilities of the Universal Service Administration Company (USAC) to include the administration of the COVID-19 Telehealth Program).
  USAC will review the applications with oversight from the Bureau. See Wireline Competition Bureau Announces Application Filing Window for Round 2 of COVID-19 Telehealth Program Will Open April 29, 2021, WC Docket No. 20-89, 36 FCC Rcd 7321 (WCB 2021) (Application Public Notice).
  Upon approval of awards by the Bureau, the Bureau will issue Funding Commitment Letters for the initial commitment phase to Round 2 funding recipients based on Program procedures and evaluation metrics adopted by the Commission.

Invoicing and Reimbursement Process

With Bureau and OMD oversight, USAC will use the reimbursement structure for Round 2 established for Round 1 of the COVID-19 Telehealth Program, which allows for efficiency and continuity in the reimbursement structure by utilizing existing invoicing systems, processes, and procedures that are currently in place from Round 1. Second COVID-19 Report and Order, 36 FCC Rcd at 7174, para. 73.
  In order to receive reimbursement, funding recipients must first pay the vendor or service provider for the costs of the eligible services and/or connected devices received before requesting reimbursement for those costs from the Program. As explained in the Second COVID-19 Report and Order, the Commission takes seriously its responsibility to prevent waste, fraud, and abuse of Program funding, and believes that verifying each applicant’s purchase of eligible services and connected devices prior to reimbursement is an important part of this responsibility.  Id. at 7174, para. 73 n.225.
  Consistent with Round 1 of the Program, disbursements will be issued directly to the funding recipients rather than to the service providers or vendors that have provided the eligible services and/or connected devices to participating health care providers. See Second COVID-19 Report and Order, 36 FCC Rcd at 7174, para. 73.
  Simply put, the Program will not directly pay a provider or vendor of health care equipment or services.  
Following the eligible health care provider’s receipt of, and payment for, eligible services and/or connected devices, funding recipients may begin to submit requests for reimbursement on a COVID-19 Telehealth Program Round 2 Request for Reimbursement Form and required supporting invoice documentation for those eligible services and/or connected devices, on at least a monthly basis, against the amount indicated in their funding commitment letter. The Application Public Notice provides websites for more information about the services and connected devices eligible to receive funding support through the COVID-19 Telehealth Program. See Application Public Notice, 36 FCC Rcd at 7321-22. See also Second COVID-19 Report and Order, 36 FCC Rcd at 7184, Appendix B (providing further guidance on eligible services and devices; attached as Appendix A to this Public Notice). 
  Any funding received by a funding recipient on behalf of other eligible health care provider(s) shall be provided to such eligible health care provider(s) to reimburse them for their respective costs incurred under the Program.
Round 2 funding recipients must submit their requests for reimbursement and supporting invoice documentation, and any necessary subsequent information (to include any information necessary to satisfy the Commission’s oversight responsibilities and/or agency-specific/government-wide reporting obligations associated with the appropriation by Congress) CARES Act, Public Law 116-136 (Mar. 27, 2020), DIVISION B, entitled “Emergency Appropriations for Coronavirus Health Response and Agency Operations,” Title V, Sec. 15011.  
 through the Invoice Processing Platform (IPP), which is part of the U.S. Department of the Treasury’s Bureau of Fiscal Services. The IPP is already used by the Commission to accept invoices from and make payments to the Commission’s program partners.  The IPP is Treasury-supported, approved by the Office of Management and Budget, and is provided free of charge. 
  USAC will review, with Commission oversight, the Round 2 Request for Reimbursement Forms along with all supporting documentation, to ensure compliance with Program rules including, but not limited to: (1) ensuring that funding is only awarded to eligible health care providers after receiving documentation that demonstrates the eligibility of the requested items and substantiates the cost of those items; and (2) rejecting any requests for reimbursement that do not complete the required certifications as part of the Round 2 Request for Reimbursement Form to ensure that Program funds are used for their intended purpose. As with Round 1, OMD and the Bureau found that it remains in the public interest, and good cause continues to exist, to waive the Commission’s Red Light Rule for Round 2 of the Program.  See Office of Managing Director and Wireline Competition Bureau Suspend the Red Light Rule for the COVID-19 Telehealth Program, WC Docket No. 20-89, Public Notice, 35 FCC Rcd 3685 (WCB and OMD 2020) (Red Light Rule Waiver COVID-19 Public Notice).  This waiver does not affect the Commission’s right or obligation to collect any debt owed by an applicant by any other means available to the Commission, including by referral to the U.S. Treasury for collection.
    
Funding recipients (the entity that submitted the application and receives the funding disbursements) can prepare to submit their reimbursement requests and receive payments for Program funding by taking the following steps: (1) review, prepare and gather documentation required to seek reimbursement, including the Round 2 Request for Reimbursement Form and Instructions, which are available on USAC’s COVID-19 Telehealth Program webpage at https://www.usac.org/about/covid-19-telehealth-program/invoicing/ or the FCC’s webpage at https://www.fcc.gov/covid-19-telehealth-program and any supporting invoice documentation (for those applicants that sought funding on behalf of other eligible health care provider sites, this must include documentation (e.g., a Letter of Authorization) that authorizes the funding recipient to receive funding on their behalf and provide such funding to the health care providers to reimburse them for their respective costs incurred under the Program); and (2) if not already enrolled in the IPP, become familiar with this platform and follow the instructions for enrollment that are sent by email from the IPP.  These steps are explained in further detail below.
Prepare to Submit Request for Reimbursement 
Funding recipients seeking reimbursement for services and/or connected devices eligible for Program funding must seek reimbursement through IPP.  As part of this process, funding recipients must upload the following documents as attachments to their invoice submission in IPP:  (1) a completed and certified Round 2 Request for Reimbursement Form (the form is available https://www.usac.org/request-for-reimbursement-form/ and the instructions to the form are available at https://www.usac.org/wp-content/uploads/about/documents/covid-19-telehealth-program/Request-for-Reimbursement-Instructions.pdf); (2) an invoice from its service provider or vendor showing, at a minimum, receipt of the service and/or connected devices identifying the eligible services and/or connected devices purchased and received, and price paid (Note: a purchase order, vendor quote, or other similar documentation does not demonstrate payment for the services and/or connected devices); (3) if applicable, a Letter of Authorization (see Sample Letter of Authorization) for those applicants that sought funding on behalf of other eligible health care provider sites in order to receive reimbursement for those sites; and (4) any additional documentation supporting reimbursement for the eligible cost of the services and/or connected devices. 
If the reimbursement request is incomplete and does not contain all the necessary information to process the request, then payment will be delayed until all required information is submitted.  Thus, funding recipients are strongly encouraged to ensure that their invoices support the eligible expenses listed on the Round 2 Request for Reimbursement Form.  If their invoices list both eligible and ineligible items, funding recipients should only request reimbursement for the costs of the eligible items (including any taxes and shipping costs attributed to eligible items) on their Round 2 Request for Reimbursement Form.  USAC cannot adjust the amounts recipients request in IPP or on their Round 2 Request for Reimbursement Form.  Funding recipients that submit the incorrect amount in either IPP or on the Round 2 Request for Reimbursement Form, will be required to cancel and resubmit that request for reimbursement.
Additionally, the Round 2 Request for Reimbursement Form includes several certifications to ensure program integrity and compliance with Program rules, requirements and procedures, the CARES Act, CARES Act, 134 Stat. at 531.
 and any other applicable federal and state laws.  The certifications must be made and signed by the authorized person (generally, the primary contact for the application) who is making the certifications in order to receive reimbursement for eligible expenses.  Round 2 Request for Reimbursement Forms that are not certified and/or are unsigned, will be deemed incomplete and will need to be resubmitted.   
IPP Access and Use
The IPP is a service provided by the U.S. Department of Treasury’s Bureau of the Fiscal Service.  This platform is provided at no cost to entities doing business with a participating government agency and approved third-parties.  As the designated Administrator of Round 2, USAC will use IPP to facilitate the receipt of reimbursement requests and supporting documentation for Program funding. See supra n.4.  Payments will be transmitted from the U.S. Department of Treasury after being approved in the Commission’s financial system.  The payments will be sent by Automated Clearing House (ACH) to the bank account on file associated with the funding recipient.  You must provide your banking information when you register with the federal System for Award Management (SAM).
 We provide guidance below for seeking reimbursement of Program funding using IPP and provide some additional information for users that may be new to IPP functionality. 
For all funding recipients:  All Round 2 funding recipients will need to refer to their funding commitment letter for Program funding during the reimbursement process.  Funding disbursements under the Program will ultimately be made by the U.S. Department of Treasury to the entity listed on the funding commitment letter.  The letter will list a Funding Commitment Number.  When logging into IPP, the funding recipient should search for the Funding Commitment Number to seek reimbursement against the award amount.  The funding recipient should then fill in the invoice fields based on the invoice amounts and documentation received from their service providers and/or vendors and amounts paid for the eligible services and connected devices for which reimbursement is requested.  In order to seek reimbursement, as referenced above, the funding recipient must upload the Round 2 Request for Reimbursement Form, invoice documentation from the service providers and/or vendors, for funding recipients seeking reimbursement on behalf of multiple sites, a Letter of Authorization, and any additional documentation to support the reimbursement request.  To attach these documents, the funding recipient should navigate to the upper right-hand side of the submission where it is entering data and click the “Attachments” button.  From there, any attachments to be submitted with the request for reimbursement can be uploaded.  The attachments are required for USAC to process the reimbursement request. 
If you are already enrolled in the IPP:  Funding recipients that are already registered to use IPP, need not re-register in the IPP.  
If you are NOT already enrolled in the IPP:  Funding recipients not already registered to use IPP will receive registration emails from IPP to register the first time in IPP.  The first and last name, and email address of the funding recipient’s contact person on the Program application will be used to start the enrollment process.  Thereafter, the funding recipient will receive two emails from IPP Customer Support to enroll:
· The first email contains the initial administrative IPP User ID.
· The second email, sent within 24 hours of receipt of the first email, contains a temporary password.  Funding recipients must log in with the temporary password within 30 days.
Registration is complete when the user logs into the IPP web site with the User ID and password provided and accepts the rules of behavior. 
IPP User Training and Support:  IPP user training materials are available on the IPP.gov website at https://www.ipp.gov/vendors/training-vendors.  Also, once a funding recipient logs in to the IPP application, it will have access to user guides that provide step-by-step instructions for all IPP capabilities, ranging from creating and submitting an invoice to setting up email notifications.  For answers to frequently asked questions, visit the Vendor FAQ page on the IPP.gov website.  Further, telephone support for IPP is available Monday through Friday from 8:00 am to 6:00 pm ET.  Any questions regarding IPP enrollment, may be directed to the IPP Customer Support Helpdesk via email: IPPCustomerSupport@fiscal.treasury.gov or by phone: (866) 973-3131.
Program Reminders and Additional Information
We emphasize that Program funds must only be used for services and devices eligible under the CARES Act, See Second COVID-19 Report and Order, 36 FCC Rcd at 7170, para. 58. 
 thus the cost of ineligible items must not be included in reimbursement requests for the Program.  To guard against potential waste, fraud, and abuse, we reiterate that participating health care providers are prohibited from selling, reselling, or transferring services or devices funded through the Program in consideration for money or any other things of value. First COVID-19 Report and Order, 35 FCC Rcd at 3382, para. 30.
  Moreover, we remind funding recipients that they cannot use Program funding to pay for the non-discount share of services purchased under the Rural Health Care Program.  Further, we remind applicants that they must certify, under penalty of perjury, that they have not received and may not receive duplicative funding for the same services from state, local, or federal sources twice.  For example, applicants may not receive funding from both the Program and the Connected Care Pilot Program for the same services or connected devices.  
Finally, we remind funding recipients that to receive payments through the Program, they must be registered with the federal System for Award Management. The System for Award Management is a web-based, government-wide application that collects, validates, stores, and disseminates business information about the federal government’s partners in support of federal awards, grants, and electronic payment processes.  
  Only applicants registered through the System for Award Management will be able to receive COVID-19 Telehealth Program funding.  To register with the system, go to https://www.sam.gov/SAM/.  The Bureau and OMD strongly recommend that any unregistered health care providers start that registration immediately because it may take approximately 10 business days before your registration becomes active and an additional 24 hours before that registration information is available in other government systems.  
For further information regarding this Public Notice, please contact Nathan Eagan, Attorney Advisor, Telecommunications Access Policy Division, nathan.eagan@fcc.gov or (202) 418-0991.  For more information about Round 2, refer to USAC’s website at www.usac.org/about/covid-19-telehealth-program.
For inquiries and support related to Round 2 invoicing, please contact Round2TelehlthInvoicSupp@FCC.gov. 
APPENDIX A
ELIGIBLE SERVICES LIST FOR COVID-19 TELEHEALTH PROGRAM:  ROUND 2
The Federal Communications Commission (FCC) provides this list as guidance for applicants on the services and devices that are eligible for funding under the COVID-19 Telehealth Program (Program).  Pursuant to the CARES Act, the Program awards funds to eligible health care providers to support the purchase of “telecommunications services, information services, and devices necessary” to provide telehealth and connected care in response to the COVID-19 pandemic.  Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No 116-136, 134 Stat. 281 (2020) (CARES Act).  Congress appropriated $249.95 million in additional funding for the Program in December 2020.  Consolidated Appropriations Act, 2021, Pub. L. No:  116-260, Division N-Additional Coronavirus Response and Relief, Title IX-Broadband Internet Access Service, § 903 “FCC COVID19 Telehealth Program” (2020).  The Telecommunications services, information services, and connected devices funded through the Program must be integral to patient care.  
We caution applicants to carefully review all Program guidance.  Applicants are ultimately responsible for compliance with Program requirements, including all deadlines and eligibility requirements.  
Eligible Services and Devices
Consistent with Round 1, the Commission interprets the language regarding devices to include only connected devices but not devices that patients use at their homes that do not have a connection to the internet, even if those devices allow the patient to manually report information to their medical professionals remotely.  Promoting Telehealth for Low-Income Consumers; COVID-19 Telehealth Program, WC Docket Nos. 18-213, 20-89, Report and Order, 35 FCC Rcd 3366, 3376, para. 16 (2020).  Connected devices may include Bluetooth or Wi-Fi enabled devices, or that connect to the Internet directly, including devices/peripherals (e.g., web cameras, stethoscopes) that connect to a consumer’s phone or other connected device for purposes of providing telehealth services.  Network equipment needed to use telecommunications services, information services, or connected devices are also eligible.  The costs for taxes, shipping, and installation or integration of eligible devices and services, are also eligible expenses.
Examples of eligible services and connected devices include:
· Telecommunications Services and Broadband Connectivity Services:  Voice services and Internet connectivity services for health care providers or their patients.  These expenses are eligible for up to 12 months of funding.  
· Information Services:  Remote patient monitoring platforms and services; patient reported outcome platforms; store and forward services, such as asynchronous transfer of patient images and data for interpretation by a physician; platforms and services to provide synchronous video consultation.  These expenses are eligible for up to 12 months of funding.  
· Connected Devices:  Tablets, smart phones, or connected devices to provide telehealth services (e.g., broadband, Wi-Fi, or Bluetooth enabled blood pressure monitors; pulse-oximeters) for patient or health care provider use; telemedicine kiosks/carts for health care provider site.  General office scanners and printers are not considered connected devices for purposes of this Program.  
Ineligible Costs
The Program does not support funding for personnel costs, marketing costs, administrative expenses, training costs, or indirect costs.  Program funds are to support the purchase of telecommunications services, information services, and connected devices to provide telehealth services in response to the COVID-19 pandemic and are not intended to fund the development of new websites, systems, or platforms.  Applicants may still apply to receive retroactive funding for eligible services and connected devices purchased on or after March 13, 2020.  Such services or devices must have been purchased to provide telehealth or connected care services in response to the COVID-19 pandemic and can include pandemic-related upgrades to existing services.  Because the Program is a “Federal subsidy made available through a program administered by the Commission,” program funding may not be used to “purchase, rent, lease, or otherwise obtain any communications equipment or service . . . identified and published on the Covered List.”  See Protecting Against National Security Threats to the Communications Supply Chain Through FCC Programs, WC Docket No. 18-89, Second Report and Order, 35 FCC Rcd 14284, 14326, paras. 94-95 (2020); see also 47 CFR § 54.10; Public Safety and Homeland Security Bureau Announces Publication of the List of Equipment and Services Covered by Section 2 of the Secure Networks Act, WC Docket No. 18-89, Public Notice, DA 21-309 (PSHSB Mar. 12, 2021).
Examples of ineligible services and devices include:
· Services or devices purchased or implemented prior to March 13, 2020.
· Administrative costs, e.g., personnel expenses, consultant fees, payroll, training, customer service, project management, records management, reprocessing and logistics, and doctor’s costs, etc.
· Technical support, maintenance costs, separate costs for warranties and protection plans.
· Separate costs for non-connected accessories, e.g., cases, mouse pads, cable clips, laptop bags, tablet stands, wall mounts, and charging stations, etc.
· Smart watches and fitness trackers.
· Back-up Power Equipment, e.g., back-up batteries, redundant power cords, Uninterruptible Power Supply (UPS), generators, and surge protectors, etc.
· Non-connected medical devices or supplies, e.g., non-connected digital thermometers, testing strips, lancets, disposable covers, and personal protective equipment, etc.
· Construction costs, e.g., fiber/ethernet/cable network constructions, facility alterations, and temporary site location structures, etc.
· Non-telehealth items, e.g., office furniture and supplies, desks, security systems, and indirect costs, etc.

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