The Federal Communications Commission (FCC) has released a new Order that will reform its Rural Health Care (RHC) program, including a constituent of the RHC known as the Healthcare Connect Fund (HCF). These changes will impact such things as how the HCF’s program administrator prioritizes the allocation of discounts, rurality criteria for consortia like NCTNA, and application filing windows. The new Order will not affect any Funding Year 2019 funding requests.
The Federal Communications Commission established its permanent Healthcare Connect Fund (HCF) in July 2013. A $400m cap was allocated to the HCF, which has been increased based on inflation. HCF provides 65% discounts to eligible healthcare providers for broadband services. NCTNA is the consortium leader for many of North Carolina’s healthcare providers who participate in the HCF through NCTNA and receive these discounts. The new Order will affect NCTNA’s operations and may impact discounts for some of its member healthcare providers.
Most importantly, the Order changes the way in which discounts will be prioritized and prorated. Until the Order, all discount applications were treated the same. Regardless of the size or location of the request and the member, the discount request would be given the same priority, and if the funding cap for the program was eclipsed by the demand for funding, all applicants would receive the same prorated reduction in discount funds. With the Order, the program administrator (USAC) will prioritize funding (where demand exceeds available funding) based on what are called “rurality tiers” and whether or not the requesting healthcare provider is in a Medically Underserved Area. Essentially, the more rural a site the higher priority it will be given, and highly rural sites that are also in Medically Underserved Areas will receive the highest priority. What this means in practical terms is that the highest priority requests will receive funding first and can expect full funding. Lower priority sites are less likely to receive full funding should funding demand exceed the program cap. NCTNA is currently researching how this change may affect its members and will provider updates.
Consortia like NCTNA have played a central role in the evolution of the HCF, enrolling most of the participating healthcare providers. A key feature of Consortia is that they can enroll both rural and non-rural sites. This means that they, or NCTNA in particular, can link rural healthcare providers directly to academic medical centers and other tertiary care healthcare providers. Through such things as health information exchanges and telehealth, these direct connections enable rural providers to provide their patients with service comparable to that in urban centers.
Under the old rule, Consortia must ensure that at least 50% of their member sites are rural, and if not, they would have three years to bring their rural membership to 50%. In the new Order, the three year grace period has been ended, and for each year when the demand for funding exceeds the funding cap, the rurality percentage goes up by five percent to a max of 75%. About 60% of NCTNA’s sites are currently designated as rural sites, and NCTNA will work to increase this percentage over the next few years.
Finally, an ongoing issue for many consortia and their members has been the delay in funding approvals. In some cases the delays extended so far into the funding year that projects/operations could not be implemented, and the approved funds were returned. To help address this issue and to give applicants more time to complete the complex filing application, the new Order requires the program administrator to open the initial filing window with an end date no later than 90 days prior to the start of the funding year. The FCC expects this change to give the program administrator time to begin processing submitted applicants prior to the start of the funding year and as a result, to expedite their funding decisions.
To review the new Order in its entirety please go to: https://docs.fcc.gov/public/attachments/FCC-19-78A1.pdf
