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c·r·'fhe Honmab _ Tom Wheeler 
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Chairman 
Federal Communications Commission 
445 12th Street, S.W. 
Washington, DC 20554 
Dear Chairman Wheeler: 
WASHINGTON, DC 20510 
August 21,2014 
We are writing to urge the Commission to clarify the meaning of "not-for-profit hospital" 
utilized by the Universal Service Administration Company (USAC) in making determinations 
for eligibility in the Healthcare Connect Fund (Program). We are concerned that the USAC's 
current interpretation of"not-for-profit" hospital fails to recognize the increased usage of 
integrated delivery models in the health care sector and undermines the goals ofthe Program by 
limiting the Commission' s desired development of a consortium approach to creating broadband 
health care networks. 
We understand that the USAC has interpreted "not-for-profit hospital" to mean a building with 
beds that is licensed to provide acute care services under state law. However, this interpretation 
ignores the fact that the integrated delivery models now utilized in the health care sector have 
significantly expanded the role of ambulatory care centers and hospital-employed medical staff 
offices as a means to care for the patient population. 
The USAC' s interpretation of"not-for-profit" hospital excludes many health care providers in 
our states who are considered part of non-profit facilities in other legal contexts. The exclusion 
of these providers undermines the Program' s desired objective of encouraging the creation of 
state and regional broadband health care networks comprised of providers that span the 
continuum of care from rural health clinics to urban specialist practices. 
As a result, we believe the Commission should clarify as soon as possible that the term "not-for­
profit hospital" within the Program would include all health care delivery locations of an entity 
licensed under state law that directly or indirectly operates one or more hospital facilities. This 
clarification would provide the certainty necessary to allow health systems in our states and 
across the country to move forward with the planning and design of their respective broadband 
networks. 
Thank you for your full and fair consideration of this important matter. 
Sincerely, 
Senator Dan Coats Senator Rob Portman