The NC Telehealth Network Association (NCTNA) recently worked with the Schools, Health, and Libraries Broadband (SHLB) Coalition to respond to an FCC Notice of Proposed Rulemaking (FNPRM) that asked some great questions about how to improve the Rural Healthcare Program (RHC). I’m going to focus on the Healthcare Connect Fund (HCF) program and some of the great opportunities for feedback that this FNPRM provided. The HCF program provides up to a 65% discount to eligible healthcare providers for broadband related costs.
SHLB is an advocacy group made up of members across the US. See www.SHLB.org for a complete description of their broadband focus areas. Our work with SHLB on the HCF program has been awesome from the start. It’s been very encouraging to know that so many different organizations can work closely together for the benefit of the HCF program recipients. The fact that SHLB members represent an estimated 75% of all RHC funding dollars requested really helps to make sure that the FCC and USAC listen to us.
The FCC posts notices of proposed rulemaking on their programs to allow everyone to weigh in on the proposed changes. I actually find these very interesting to read because they include a mix of proposed changes, questions, and other opportunities to provide feedback. I always resort to a printed copy that includes good old-fashioned highlights, my scrawling handwriting complete with exclamation points and sarcastic comments, and my favorite post-it note flags. I’m guessing not everyone loves this stuff as much as I do, so I’ll narrow my comments to the most important aspects of the FNPRM for healthcare providers:
Increasing the overall cap
Reforming the sub-cap
Changing rurality definitions
A past-FCC commissioner told us how the original program cap of $400 million was set in 1997 without any review of program need. I seem to recall there was wine involved in the story. This cap is now up to $604 million and is adjusted for inflation each year. This is a big improvement, but still not based on any real numbers of healthcare provider sites. SHLB estimates the total need to be $2 billion based on the costs of providing adequate broadband connectivity for telehealth networks for 91,238 public and non-profit health care providers across the U.S. (urban and rural). It’s estimated that 90% of those sites would apply for funding if it were available and the program was administered correctly. The high demand for COVID-19 Telehealth and Connect Care dollars demonstrates an enormous need for greater funding.
There is also a sub-cap which is more difficult to explain. It is currently set at $161 million and is also adjusted for inflation each year. The initial FCC order that established the HCF expressed concerned that there may be gigantic new infrastructure construction that would use up all the funding without leaving enough for monthly-recurring costs. Somehow the rule ended up specifying that any discounts requested on a 3-year funding request (versus a one-year funding request) would be subject to this sub-cap. We recommended that this sub-cap either be eliminated or only applied to construction costs as it was originally intended to do. This would have the added benefit of enabling us to go back to requesting three years of funding at a time, which provides a lot more funding certainty for healthcare providers. We currently only request one year of funding at a time to make sure discounts don’t get reduced or eliminated due to the sub-cap. The limitations of one-year funding requests and slow funding approval process means that healthcare providers risk having temporary discount gaps each year.
The next most exciting section in the FNPRM were the questions about the existing rurality definition. Degrees of rurality are important because the more rural sites receive funding before less rural sites if either cap is reached. Although many healthcare provider sites participating in a consortium like NCTNA do not have to be rural to receive funding, health clinics must be rural. There are some nuances to this, such as an internet connection between a non-profit or public hospital and an urban clinic is eligible for discounts because the hospital qualifies the service for funding. You can take our eligibility quiz (see https://www.surveymonkey.com/r/QNKQMZN) if you’d like to learn more about sites that are eligible for funding or feel free to ask us for a free eligibility assessment. Currently, most people would be surprised to see which areas are considered rural and which are not. The HCF unique rurality criteria treats isolated rural towns the same as urban towns adjoining large metropolitan areas, relies on a population threshold of 25,000 regardless of proximity to a metropolitan area, and disqualifies large geographic areas in rural communities due to reliance on Census tracts rather than a smaller unit of measure. We recommended providing two ways of measuring rurality and allowing each healthcare provider to determine the best choice for their situation. One would rely on census blocks instead of tracts and use the standard Census designations for the classification of rurality. The other would utilize USDA RUCA codes, which work very well for most parts of the country. The result of these changes would be a larger number of rural sites.
The next step for this FNPRM is for the FCC to review the comments and then issue a new order with any program changes. In the meantime, we’ll continue to work with SHLB to make sure that the FCC and the HCF program administrator (USAC) understand that the HCF program is an integral part of mission-critical broadband for healthcare providers.