The Federal Communications Commission (“FCC”) established the COVID-19 Telehealth Program (the “Telehealth Program”) on April 2, 2020 in response to the COVID-19 pandemic. The Telehealth Program provides $200 million in funding, appropriated by Congress as part of the CARES Act,[1] to assist certain non-profit and public healthcare providers in making telehealth services available to patients who cannot be seen in person.

Specifically, the Telehealth Program will distribute funds to eligible healthcare providers responding to the COVID-19 pandemic by fully funding their telecommunications services, information services, and devices necessary to provide critical connected care services.[2] Notably, the Telehealth Program’s funding covers only devices and services that are connected to the healthcare provider (i.e., devices that deliver information between the patient’s location and the healthcare provider via a broadband internet connection); the FCC will not fund devices and services that provide information that patients must manually report to their healthcare providers. The Telehealth Program will also not provide reimbursements for telehealth services that were existing before March 13, 2020, unless, in some cases, they were upgraded specifically in response to COVID-19. These funds will continue to be available to applicants who are approved by the FCC until they run out or until the COVID-19 pandemic has ended.

Eligible healthcare providers include the following non-profit and public providers:

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

Unfortunately, private and for-profit entities are not currently eligible to receive this funding; nor are vendors of eligible services and devices. In other words, only not-for-profit and public healthcare providers are eligible to receive funding from the Telehealth Program. Eligible healthcare providers must complete the FCC’s application process,[3] and must also meet other criteria to receive funding.

A link to the application for the FCC’s Telehealth Program is here, and useful FAQs to assist with the application process can be found here. It is important to note that the Telehealth Program is not a grant program; in other words, to obtain committed funds after a healthcare provider’s application is approved, that healthcare provider is required to submit invoices and a Request for Reimbursement form, as well as any relevant receipts and documentation, on at least a monthly basis.[4] 

The FCC is reviewing and approving applications on a rolling basis as they are filed. As of June 3, 2020, the FCC has approved applications for 238 healthcare providers in 41 states plus Washington, D.C., for a total of $84.96 million in funding.[5] Only three healthcare providers in Oregon and seven in Washington have been approved to receive funding from the Telehealth Program; sixteen California providers have been approved.[6] No providers in Alaska have been approved.[7] 

If you are a non-profit or public healthcare provider that fits into one of the categories listed above and are in need of advice or assistance completing the application, or determining whether you may be eligible to receive funding from the FCC’s Telehealth Program, our attorneys are available to answer your questions.

[1] CARES Act, Pub. L. No. 116-136, 134 Stat. 281, H.R. 748-251, 116th Cong. (2020).
[2] Wireline Competition Bureau Provides Guidance on the COVID-19 Telehealth Program Application, Public Notice, WC Docket No 20-89 (April 8, 2020) (available at, scroll to “Files” and click either “Docx,” “Pdf,” or “Txt” next to the bullet point for “Public Notice”).
[3] Before applying, prospective applicants are required to take three steps, if they have not done so already: (1) create an FCC registration number; (2) obtain an eligibility determination from the Universal Service Administrative Company; and (3) register with the federal system for award management.
[4] See (click “Invoices and Reimbursements” tab).
[5] See (last accessed June 5, 2020).
[6] See (last accessed June 5, 2020).
[7] See (last accessed June 5, 2020).

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