By Andrew Wilber and Kate Hickner

The Federal Communications Commission (FCC) recently established the COVID-19 Telehealth Program (the “Program”) to support the provision of telehealth services during the COVID-19 pandemic. Under the Program, the FCC will distribute $200 million to eligible healthcare providers for telecommunications services, information services and devices necessary for connected care services. (Please note that the Program will only fund monitoring devices that are connected—not unconnected devices that patients use at home and then share the results with their medical professional remotely.) On Monday, April 13, 2020, the FCC’s Wireline Competition Bureau began accepting applications for the Program through its online application portal.

In order to apply for funding under the Program, applicants must complete three steps:

  • obtain an eligibility determination from the Universal Service Administrative Company (USAC);
  • obtain an FCC Registration Number (FRN); and
  • register with System for Award Management.

Eligibility Determination

The first step in applying for funding under the Program is to obtain an eligibility determination for each health care provider site that the health care providers include in their application.

Only the following nonprofit and public health care providers are eligible to participate in the Program:

  • post-secondary educational institutions offering health care instruction, teaching hospitals and medical schools;
  • community health centers or health centers providing health care to migrants;
  • local health departments or agencies;
  • community mental health centers;
  • not-for-profit hospitals;
  • rural health clinics;
  • skilled nursing facilities; and
  • consortia of health care providers consisting of one or more entities falling into the first seven categories.

Health care providers that do not already have an eligibility determination may obtain one by filing an FCC Form 460 (Eligibility and Registration Form) with USAC. Health care providers can submit an application with the FCC while their FCC Form 460 is pending with USAC.

FCC Registration Number

Interested health care providers must also must register for an FRN in the Commission Registration System (CORES). FRNs are unique, 10-digit numbers used to identity registrants’ business dealings with the FCC.

Registration With the System for Award Management

Although interested healthcare providers do not need to be registered with the System for Award Management before they submit an application, they will not receive payments until they are registered. For many healthcare providers, this step will not pose an issue, because most are already registered with the System for Award Management. But if you are not registered, you should begin that process as soon as possible. It may take up to 10 business days for your registration to become active and an additional 24 hours before that registration information is available in other government systems.

Application Process

The application to participate in the Program, available through the Program’s online portal, is an eight-page fillable PDF. The application requests general information regarding the applicant as well as information on how the applicant will spend the funds. Applicants are encouraged to provide supporting documentation for how the funds will be spent, such as an invoice or quote from a vendor or service provider.

The FCC will award funding based on the applicant’s response to the following criteria:

  • The conditions to be treated using the Program funding.
  • The goals and objectives for use of the Program funding.
  • The timeline for deployment of the proposed service(s) or devices funded by the Program.
  • The factors/metrics the applicant will use to help measure the impact of the services and devices funded by the Program.
  • The geographic area and population served by the applicant and whether that geographic area has been under any pre-existing strain (e.g., large underserved or low-income patient population; health care provider shortages; rural hospital closures; limited broadband access and/or Internet adoption).
  • The health care providers’ targeting of funding to high-risk and vulnerable patients.

Although the FCC will be awarding funds based on the estimated costs of the supported services and connected devices, the FCC is not requiring that applicants only purchase the services and connected devices identified in their applications. Instead, applicants may use their award to purchase any necessary eligible services and connected devices. Further, use of funds is not limited to treatment of patients that have COVID-19, as long as the funds are used “to prevent, prepare for, and respond to coronavirus.” The FCC cites as an example the use of Program funds to treat other types of conditions or patient groups to free up resources to treat COVID-19.

If applicants exhaust their award, they may apply for additional support. However, in an effort to distribute the $200 million to as many eligible healthcare providers as possible, FCC does not anticipate that it will award more than $1 million to one applicant.

If you have any questions regarding the COVID-19 Telehealth Program or would like assistance in preparing an application, please contact Andrew Wilber at or 216.736.7298, Kate Hickner at or 216.736.7279, or any of our Healthcare attorneys.