Round 2 Invoicing FAQs

General Information

• What is the Round 2 deadline for purchases and implementing services? How do we demonstrate compliance?
  The deadline for purchases and implementing services is October 31, 2022. (An extension to February 28, 2023, has been announced for all awardees in Florida, South Carolina, North Carolina and Puerto Rico. These waivers of rules are related to Hurricanes Fiona and Ian. This does not affect any other deadlines.) To comply with the purchase/implementation of services deadline, awardees must have entered into a purchase agreement by this date. Awardees do not need to have received the device by the deadline. Additionally, if the eligible service is a recurring monthly cost, then only the first month’s payment must have been made by October 31, 2022, and payments for that service may continue past October 31, 2022. Note that there is no requirement to submit purchase/implementation documentation, unless requested by FCC staff. Rather, related records are to be retained for six years past the last date of delivery of services or connected devices and may be requested as part of any follow-up audit. (For more information about records retention and audits, see paras. 79-80 in the Second COVID-19 Report and Order).
• When is the deadline for all awardees to submit their invoices and complete their requests for reimbursement for Round 2 of the COVID-19 Telehealth Program?
  On July 29, 2022, the Federal Communications Commission released a Public Notice that extended the  deadline to October 31, 2023 for all awardees to submit their invoices and complete their requests for reimbursement for Round 2 of the COVID-19 Telehealth Program. We also remind all awardees that they have until October 31, 2022 to order eligible devices and services in order for those items to be eligible for reimbursement. If you have any questions, please contact Round2Telehealthapplicationsupport@fcc.gov or round2telehlthinvoicsupp@fcc.gov.
• How do I access or login to the IPP?
  After you receive your notification of COVID-19 Telehealth program funding from the FCC, you should receive two emails from the IPP (from this email address). These emails will notify you of your access to the IPP Collector module. The first email contains your IPP User ID. The second contains your temporary password. Please use these to login to the IPP for the first time.
• I haven’t received an e-mail from IPP regarding steps to enroll in the platform. What should I do?
  If you do not receive the emails from the IPP with you User ID and temporary password (as mentioned in the answer to the question above), please check your email spam folder or check with your organization’s IT administrator to see if the emails may have been blocked by system settings. If you still are unable to locate the email, or if you have other questions about the IPP site, please contact the IPP Customer Support Helpdesk via email or by phone: (866) 973-3131. Telephone support for the IPP is available Monday through Friday from 8:00 am to 6:00 pm ET.
• If I did not submit the Round 2 COVID-19 Telehealth program application on behalf of my organization, will I receive the emails to enroll in IPP?
  The contact person for your organization that was listed on your application and funding commitment letter will be sent the IPP enrollment emails. However, your organization may already be enrolled in the IPP. If so, the FCC will notify you by email of the name of the IPP Administrator for your entity if your IPP Administrator is not the same person that submitted a COVID-19 Telehealth program application on behalf of your organization.The Identified Administrator is the designated person in your organization who can access the IPP and submit invoices. If you would prefer that a different person or persons have the responsibility for submitting the funding recipient’s COVID-19 Telehealth program invoices, your IPP Administrator can set up IPP access for this person(s).If the Identified Administrator is no longer in the position that required them to be the IPP Administrator but is still with your organization, they should add new IPP Administrators (at least two are recommended). The IPP Help Desk can assist with the transfer of the IPP Administrator role to another person.Telephone support for the IPP is available Monday through Friday from 8:00 am to 6:00 pm ET.  Any questions regarding IPP enrollment, may be directed to the IPP Customer Support Helpdesk via email or by phone: (866) 973-3131.

Letter of Authorization and Request for Reimbursement

• When does a Letter of Authorization need to be filed?
  Applicants that received a funding commitment on behalf of other eligible HCP sites must have a Letter of Authorization (see Sample Letter of Authorization) on file in order to receive reimbursement for those sites. The Letter of Authorization is required from each HCP site that will receive devices or services as part of your funding commitment. The Letter of Authorization should be uploaded with the first monthly invoice submission to the IPP. The Letter of Authorization only needs to be uploaded once; thereafter, the FCC will have it on file for use in reviewing future reimbursement requests.  We strongly encourage you to use the FCC’s Sample Letter of Authorization. If not, your Letter of Authorization, at a minimum, must contain the required authorizations provided in the FCC’s sample Letter of Authorization for each eligible HCP site that will receive devices or services as part of your funding award.
• Where do I find the Request for Reimbursement Form and the Letter of Authorization?
  Links to the Round 2 Request For Reimbursement Form, instructions for completing the Round 2 Request For Reimbursement Form, and a sample Letter of Authorization can be found here. Additional information on invoicing and reimbursements can be found on this page and at the Invoices and Reimbursements tab of USAC’s COVID-19 Telehealth Program
• Which location should be listed as the service or delivery location for eligible services and connected devices provided to patients, or used by our health care professionals to provide telehealth services outside of the HCPs’ brick and mortar location?
  The eligible HCP site for which the eligible connected devices or services were purchased must be listed as the service or delivery location.  You must not list individual patient addresses or non-brick and mortar sites where telehealth services are being provided as the service or delivery location.

Eligibility of Services and Connected Devices

• How do I know what expenses are eligible for reimbursement under the COVID-19 Telehealth program?
  General guidance regarding eligible services and/or connected devices can be found on page 44 in Appendix B of the Commission’s Round 2 Report and Order.COVID-19 Telehealth Program funding will provide eligible HCPs support to purchase telecommunications, information services, and connected devices necessary to provide telehealth services to patients in response to the coronavirus pandemic. The program will fund only devices (e.g., pulse oximetry, blood pressure monitoring devices, etc.) that are themselves connected, and will not fund unconnected devices that patients can use at home and then manually report the results to their medical professional. Connected devices may include devices with Bluetooth or Wi-Fi connectivity, including devices that connect to a consumer’s phone, for example. Devices for which funding is requested must be integral to patient care.

Below are examples of eligible services and connected devices that COVID-19 Telehealth program applicants may seek funding for:

• Telecommunications Services: Voice services, for HCPs or their patients.
• Information Services: Internet connectivity services for HCPs or their patients; remote patient monitoring platforms and services; patient reported outcome platforms; store and forward services, such as asynchronous transfer of patient images and data for interpretation by a physician; platforms and services to provide synchronous video consultation.
• Connected Devices/Equipment: Tablets, smart phones, or connected devices to receive connected care services at home (e.g., broadband-enabled blood pressure monitors; pulse oximetry monitors) for patient or HCP use; or telemedicine kiosks/carts for HCP sites.

Below are examples of items ineligible for COVID-19 Telehealth Program support:

• Services or devices purchased or implemented prior to March 13, 2020 (NOTE: you may not seek reimbursement for services or connected devices until after they have been implemented or received).
• Administrative costs, e.g., personnel expenses, consultant fees, payroll, training, customer service, project management, records management, and doctor’s costs, etc.
• Back-up power equipment, e.g., back-up batteries, redundant power cords, Uninterruptible Power Supply (UPS), and surge protectors, etc.
• Separate costs for non-connected items, e.g., cases, mouse pads, cable clips, laptop bags, tablet stands, and charging stations, etc.
• Non-connected medical devices or supplies, e.g., non-connected digital thermometers, testing strips, lancets, disposable covers, and personal protective equipment, etc.
• Smart watches and fitness trackers.
• Non-telehealth items, e.g., office furniture and supplies, security systems, incidental expenses, etc.
• Construction costs, e.g., fiber, ethernet, cable network build out, facility alterations, and temporary site location structures, etc.
• Technical support, maintenance costs, warranties, support services, and protection plans. If the description on the invoice documentation uses this terminology and the expense is for more than just these costs, please provide a detailed description on the Request for Reimbursement Form or attach a separate statement with your invoice submission in IPP so that we can better determine eligibility of items sought for reimbursement.
• Carts or stands that will only be used as a workstation or desk on wheels are not eligible for support. These costs should not be included on the Request for Reimbursement Form or the request will be rejected and will need to be resubmitted excluding these costs to receive reimbursement. Telemedicine carts are eligible for support, whether bought ready-to-use from a vendor or bought piecemeal from various vendors. If you are requesting support to build your own telemedicine cart, please let us know that you are seeking to build your own telemedicine cart(s) as part of your invoice submission.

For questions related to eligibility of connected devices and/or services, please send an email to Round2TelehlthInvoicSupp@FCC.gov.

• Can I invoice for existing services and/or connected devices?
  Eligible HCPs may apply to receive funding through the COVID-19 Telehealth program for eligible services and connected devices purchased on or after March 13, 2020. Invoices that include costs for existing services that were not purchased in response to COVID-19 must be removed from your request for reimbursement because retroactive services are ineligible for funding. However, if existing services were upgraded on or after March 13, 2020 to respond to COVID-19, the costs of the upgrade may be included.
• Can I seek reimbursement for recurring services?
  You may seek reimbursement for up to twelve months of expenses for eligible recurring services as long as those services began on or after March 13, 2020. Existing services that were not purchased to respond to COVID-19 (e.g., services purchased prior to March 13, 2020) are not eligible for funding. Costs thus incurred prior to March 13, 2020 must be removed from your request for reimbursement. However, if existing services were upgraded on or after March 13, 2020, to respond to COVID-19, the costs of the upgrade may be included.
• Can I submit a request for reimbursement for items that I have paid for but have not yet received due to vendor delivery backlogs? 
  You cannot submit a request for reimbursement for services and/or connected devices that have not yet been received. Upon receipt of services and/or connected devices by the eligible HCP(s), please submit your request for reimbursement and supporting documentation.
• If an invoice from the service provider or vendor includes ineligible items, what do I need to do when submitting the invoice submission?
  Be sure to clearly indicate in your invoice submission the items on the invoice that are eligible (e.g., by crossing out the ineligible items on the invoice). On the Request for Reimbursement Form, use the column “Description of Service/Device(s) Purchased” and indicate where on the invoice the reviewer can find the relevant information for that line item.

Post-Invoice Submission

• How do I know if the invoice submission was received?
  You can use IPP’s self-service and drill-down capabilities to check the status of an invoice. If the status for an invoice reads “Pending Approval,” the invoice has been received and is under review.
• Can I make updates or corrections to an invoice submission once submitted?
  Once an invoice is submitted, you cannot make updates or corrections to the invoice submission. However, if the status of your submitted invoice is “Pending Submission,” “In Exception,” or “Draft,” you can void the invoice and submit a new invoice with the updates or corrections. Otherwise, the invoice submission will first need to be rejected by the FCC in order to allow any updates or corrections. You will need to contact the FCC at Round2TelehlthInvoicSupp@FCC.govto make this request.
• If the invoice submission was rejected, what do I need to do?
  This depends on the reason for the rejection, which will be provided in the messaging that accompanies your invoice submission rejection. A note accompanying a rejection may read, “Your invoice lacks information necessary to process. Please resubmit with:
  1. Round 2 Request for Reimbursement Form; and
  2. Letter of Authorization. After correcting the reason for the rejection, please resubmit your invoice submission with the missing information. You will not have re-enter all the information you previously entered, just the missing information and/or any corrections to your previous submission.

If your invoice is rejected and you do not receive a message with an explanation, send an email to Round2TelehlthInvoicSupp@FCC.gov. Please provide the Applicant Name and Funding Commitment Number in the subject line of the email and, in the text of the email, reference the invoice at issue.

• What is the processing time for invoices once submitted?
  The FCC’s goal is to pay invoices on a timely basis; however, requests for reimbursement that contain incomplete information, or request funding for ineligible services or devices, may delay processing. (See Question #10 of the Round 1 FAQs for the COVID-19 Telehealth program.)  To ensure that the FCC can promptly provide reimbursement, please be sure to include all required information in the Round 2 Request for Reimbursement Form and supporting documentation.
• Which entity issues the payment, and where is the payment sent?
  The U.S. Department of the Treasury will issue the payments. The payments will be sent by Automated Clearing House (ACH) to the bank account on file associated with the funding recipient. Your banking information was previously provided when you registered with the federal System for Award Management (SAM).
• Is there a deadline for submitting invoices?
  On July 29, 2022, the Federal Communications Commission released a Public Notice that extended the deadline to October 31, 2023 for all awardees to submit their invoices and complete their requests for reimbursement for Round 2 of the COVID-19 Telehealth Program. We also remind all awardees that they have until October31, 2022 to order eligible devices and services in order for those items to be eligible for reimbursement. If you have any questions, please contact Round2Telehealthapplicationsupport@fcc.gov or round2telehlthinvoicsupp@fcc.gov.
• For health care providers subject to a single audit, what is the CFDA number?
  The CFDA number for the COVID-19 Telehealth Program is 32.006.

Reporting Subawards and Executive Compensation*

*Please note: The Reporting Subawards and Executive Compensation section was updated on October 17, 2022. The updated guidance supersedes the previous guidance.

• Why do Round 2 Funding Commitment Letters include an attachment labeled “Appendix A to Part 170,” regarding subawards and executive compensation?
  This is required by amendments to the Federal Funding Accountability and Transparency Act of 2006 (FFATA), (codified at 31 U.S.C. § 6101 note), which became effective in November 2020. Note that reporting executive compensation is the only requirement for Telehealth awardees – reporting of subawards is NOT required.
• In what situations does the executive compensation requirement apply?
  Your organization is exempt if gross income, from all sources, was under $300,000 in the previous tax year. Your organization is exempt if your Telehealth award is less than $30,000.
  
  All others should review the four criteria that trigger reporting requirements – See i, ii(A), ii(B), and iii under I.b.1 in Appendix A to Part 170.
  Appendix A to Part 170 – Award TermI.b – Reporting total compensation of recipient executives for non-Federal entities.

  1. Applicability and what to report. You must report total compensation for each of your five most highly compensated executives for the preceding completed fiscal year, if –
  2. The total Federal funding authorized to date under this Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320;
  3. in the preceding fiscal year, you received –

  (A) 80 percent or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards),

  and

  (B) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards);

  and,

  iii. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. (To determine if the public has access to the compensation information, see the U.S. Security and Exchange Commission total compensation filings at http://www.sec.gov/answers/execomp.htm.)

• How do I report executive compensation?
  Executive compensation must be reported in your registration profile at SAM.gov. Reports are due by the end of the month following your award (for example, a January 2022 award would require reporting by Feb. 28, 2022). Reporting should be updated annually.
  

Service Delivery Deadline

• When is the service delivery deadline?
  October 31, 2022 is the extended deadline for Round 2 COVID-19 Telehealth Program funding recipients to purchase eligible devices and implement eligible services. We encourage COVID-19 Telehealth Program funding recipients to purchase eligible devices and implement eligible services as soon as practicable. For more information, see the FCC’s Public Notice issued on July 29, 2022.

Acceptable Signatures

• We are experiencing difficulty adding a signature to the Request for Reimbursement (RFR) spreadsheet. What is an acceptable signature?                                                                                                                                                                                          A step-by-step guide for inserting a signature onto the Excel form is posted online.  The Commission will accept any legible signature on the spreadsheet, including, for example, a signature in an image file that has been pasted onto the RFR spreadsheet.  If necessary, the signature can be added to a duplicate of the RFR itself, as might occur, for instance, by signing with Docusign or signing by hand.                                                                                                                                                                                                                                                        IF A PDF COPY IS USED TO TRANSMIT THE SIGNATURE, special requirements apply:

• • The pdf version must be an exact copy of the RFR in Excel AND
  • All certification boxes on the RFR must be ticked AND
  • The RFR in Excel format must be submitted as well.

Additional Information

• Where can I find additional information?
  More information can be found on USAC’s COVID-19 Telehealth Program Questions specific to your Round 2 Request for Reimbursement Form and submission of invoices should be directed to Round2TelehlthInvoicSupp@FCC.gov.