As a follow up, to our post from Thursday, April 9, 2020, today, the FCC announced that it will  begin accepting applications for its $200 million COVID-19 Telehealth Program (“Program”). Health care providers can submit applications at the FCC’s Program Webpage, but should be sure to follow previous guidance for pre- and post-filing requirements.  A full breakdown can be viewed in our previous post here.  The FCC has also released a filing guide and a webinar advising health care providers on the application process.

Health care providers should keep in mind that applications will be accepted on a rolling basis, and should aim to complete pre-filing requirements and file applications as quickly as possible.  Specific questions about the application process can be submitted to TelehealthApplicationSupport@fcc.gov or EmergencyTelehealthSupport@fcc.gov.

While the FCC has not provided any additional information regarding the related Connected Care Pilot Program (“Pilot Program”) at this time, prospective applicants should prepare by securing eligibility determinations from USAC.  Given the speed with which COVID-19 has prompted government action, this analysis represents our best interpretation of where things currently stand.  There is little additional guidance and uncertainty remains, but we will continue to monitor and update both Program and Pilot Program administration and requirements.

This article is not an unequivocal statement of the law, but instead represents our best interpretation of where things currently stand.  This article does not address the potential impacts of the numerous other local, state and federal orders that have been issued in response to the COVID-19 pandemic, but which are not referenced in this article.