RHC Program Updates

RHC Program Filing Window Extended

On March 26th, the FCC issued an Order extending the Rural Health Care (RHC) program application window until June 30th, 2020 for both Telecom and Healthcare Connect Fund (HCF) filings, allowing more time for filing and competitive bidding documents (FCC Forms 460, 461 or 465). These forms require a posting period of at least 28 days before selecting and committing to a service provider and filing funding requests (FCC Forms 462 or 466). 

Tip: Do not wait until the last minute to file (if possible) – USAC is reviewing competitive bidding forms in detail and some applicants have waited weeks for their form to be posted to the USAC website. The 28-day waiting period does not begin until USAC posts a 461 or 465.

Multiple Deadlines Waived or Extended

In addition to extending the filing deadline, the FCC extended other deadlines, including (1) responses to USAC information requests; (2) certain Service Delivery deadlines and (3) the HCF Invoicing deadline. We encourage you to review the Order or the USAC RHC website for detailed information.

Tip: While USAC is allowing more time to complete deadlines, prompt responses are always appreciated and support USAC in its efforts to review funding requests as quickly as possible. We appreciate the efforts of our customers during this time and are available to assist (to the extent allowed by the RHC program rules) with any requests.

Evergreen Contracts Extended

The FCC is permitting healthcare providers whose Evergreen contracts expire in funding year 2019 to extend those contracts through funding year 2020. If this situation describes your contract status, please review the USAC website or the FCC Order to discover more about this opportunity.

Bidding and Posting Period Reminders

As part of filing a 461 or 465, applicants agree to a posting period for the competitive bidding process. The posting period defaults to 28 days (although it can be adjusted when submitting the form online). 

Recent USAC training provided guidance that only bids received during the posting period, or existing contracts being considered as bids, are eligible for consideration in your process. If an HCP receives a bid outside of its posting period, it may need to refile a 461 or 465 in order to consider that bid.

Tip: The FCC allows applicants to request a Best and Final Offer or other pricing clarifications from bidders after the posting period.

Use of the HCF $10k Competitive Bidding Exemption

The RHC Program rules support several exemptions from competitive bidding.  One such exemption, specific to the HCF Program, is known as the $10K exemption.

If an applicant is seeking to use the $10K exemption, please note a couple tips:

  1. You can only seek support for $10,000 or less of total undiscounted eligible expenses in a single year.
  2. You are allowed $10,000 across all vendors. You cannot use it multiple times in a year for different vendors.
  3. This exemption cannot be used for services in a multi-year contract. It can only be a month-to-month contract or a contract for the current funding year.

Firewall Services Now Eligible

Firewall services have been determined to be eligible under the HCF program. If you are interested in getting HCF funding for your firewall services, we recommend that you specifically request firewall services in your HCF bidding process to ensure a fair and open competitive bidding process and allow all vendors a chance to bid.

Please note that firewall services remain ineligible under the Telecom program.

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