Round 2 Invoicing FAQs
- 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 firstname.lastname@example.org.
- 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.
- 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:
- Round 2 Request for Reimbursement Form; and
- 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 email@example.com.
- 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
- There is language about requirements for reporting subaward and executive compensation at the end of the Funding Commitment Letters for Round 2 of the COVID-19 Telehealth Program, but this language was not included in the Funding Commitment Letters for Round 1. Why?
The Federal Funding Accountability and Transparency Act of 2006 (FFATA), as amended, (codified at 31 U.S.C. § 6101 note), requires disclosure of all entities and organizations receiving federal awards through a single publicly accessible website, USASpending.gov. The FFATA regulations, however, requiring disclosure of executive compensation and subrecipient awards were not updated until August 2020, becoming effective in November of 2020. Guidance for Grants and Agreements, 85 Fed. Reg. 49506 (August 13, 2020) (including revisions Parts 25, 170, 183 and 200 of Title 2 of the Code of Federal Regulations). Because this was after the COVID-19 Telehealth Program Round 1 applications were processed, the updated regulations were not referenced in the Round 1 Funding Commitment Letters. In contrast, Round 2 applications were processed after the effective date of the new rules. Thus, the FCC explained these requirements in FCC 21-39 and included the required information in the award letters (Funding Commitment Letters) in the format prescribed by Appendix A to Part 170. 2 CFR § 170.220. Section 170.220(a) in particular requires the awarding agency to include the terms detailed in Appendix A of 2 CFR Part 170 in each federal award to a recipient for which the total funding awarded is anticipated to equal or exceed $30,000 in federal funding.
- How and to whom does the requirement to report executive compensation apply?
Executive compensation reporting requirements are detailed at 2 CFR 170 at Appendix A to Part 170—Award Term – I. Reporting Subawards and Executive Compensation, and at the end of an funding recipient’s Funding Commitment Letter. This applies to all program awardees that have received $30,000 or more from the COVID-19 Telehealth Program in Round 2 and that also meet the other criteria listed. I. Reporting Subawards and Executive Compensation (b) Reporting total compensation of recipient executives for non-Federal entities. This section requires that a funding recipient in Round 2 of the COVID-19 Telehealth Program must report total compensation for each of its five most highly compensated executives for the preceding completed fiscal year, if –
- The total Federal funding authorized to date under the Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320;
- in the preceding fiscal year, it received –
- 80 percent or more of its 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
- $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,
- 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.)
- When and where should I report executive compensation?
In terms of when and where to report, as stated in the Funding Commitment Letter, a funding recipient must report total compensation for each of its five most highly compensated executives for the preceding completed fiscal year:
- As part of its registration profile at https://www.sam.gov.
- By the end of the month following the month in which this award is made, and annually thereafter.
- In what scenarios are funding recipients required to report subawards in the COVID-19 Telehealth Program?
The funding amount listed on a Funding Commitment Letter in the COVID-19 Telehealth Program is issued to the program applicant who is considered the funding recipient or program awardee. See also 2 CFR § 200.1. Any funding received by an applicant on behalf of eligible health care provider(s) must be provided to such health care provider(s) to reimburse them for their respective eligible costs incurred under the COVID-19 Telehealth Program. During invoicing, recipients must list any of the health care providers that are receiving the program funding on their Request for Reimbursement forms. Because they are seeking reimbursement on behalf of other eligible health care provider sites, they must also provide a Letter of Authorization from each health care provider listed on the Request for Reimbursement form in order to receive reimbursement on behalf of those sites.Although the program structure has set up the relationships between the awardee and other program health care provider beneficiaries under the awardee’s application partially described above, the FCC is unable to determine all of the possible individual factual scenarios where a subaward might occur in the COVID-19 Telehealth Program. As a result, we were required by Part 170 to include the language about subaward reporting in the Funding Commitment Letter regardless of the fact that aspects of the letter might be immaterial to the particular awardee. One potential example of a subaward in the program might be when an applicant receives program payments from the U.S. Department of Treasury and with this funding distributes payments to the eligible health care providers; such payments may be construed to be “pass-through” payments and subawards under the program. Funding recipients that have determined that they are issuing subawards are advised to consult and follow the directions provided at the end of their Funding Commitment Letters – Appendix A to Part 170—Award Term – I. Reporting Subawards and Executive Compensation – in order to comply with the 2 CFR requirements listed therein. See also Guidance for Grants and Agreements, 85 Fed. Reg. 49506 (August 13, 2020).
- Where can I go for further guidance about whether about whether financial activities regarding my COVID-19 Telehealth Program award are subject to subaward reporting requirements?
The FCC advises program applicants to refer to Appendix A to Part 170—Award Term – I. Reporting Subawards and Executive Compensation, the definitions listed in Appendix A and any links to other 2 CFR sections that are related to this section. For example, 2 CFR 200.331 provides further guidance on the determination of whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient and provides characteristics which support the classification of the non-Federal entity as a subrecipient.
- Do the reporting requirements regarding subawards apply when awardees do not pass through payments to the health care providers that receive the services and equipment funded by the COVID-19 Telehealth Program under the award?
Where the eligible health care providers are not receiving payments from the program either directly from Treasury or from the awardees filing on their behalf, the eligible health care providers would be considered program beneficiaries and the awardees in these scenarios would not be issuing subawards of program funds. These non-awardee health care providers are receiving services and equipment as beneficiaries of the program but are not receiving an award that equals or exceeds $30,000 in Federal funds that would qualify as a subaward.
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.
- 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.
- 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.