RHC Conference Call Minutes
June 13, 2002

On May 15th, the FCC published a Notice of Proposed Rulemaking (NPRM) for the Rural Health Care Support Mechanism. The FCC is seeking comments from any interested parties for making new rules for the program. The major points under consideration include:

1. Eligible entities - Health care providers such as nursing homes, hospices, and long-term care facilities have previously been considered ineligible for participation in the Rural Health Care Support Mechanism. The FCC is seeking comment as to whether such entities should be regarded as eligible.
   
2. Eligible services - The FCC is seeking comments regarding the addition of Internet access to the list of services eligible for support
   
3. Discount calculation - The FCC is seeking comments regarding the way in which support is calculated. Currently, the MAD is calculated as the distance between the health care provider and the farthest point of the nearest large city of 50,000 in the applicant's state. If an applicant's circuit distance is beyond the calculated MAD, support is truncated accordingly. Potential modifications could include increasing the MAD to allow the circuit to connect to any point in the state, or eliminating the MAD altogether.
   
4. Competitive bidding - One of the most important requirements of the Rural Health Care Support Mechanism is its requirement that all applicants post their requests for services for 28 days on the RHCD website and consider all bids. Because of the isolated location of many rural health care providers, only one telecommunications service provider is available to them, and thus they receive few, if any, competing bids. The FCC is seeking comment on whether the 28-day period should be eliminated for cases where no competition is available.
   
5. Most cost-effective services - How to evaluate the most cost-effective service is under consideration.

These are only the main points of the NPRM; the FCC is seeking comment on these or any aspect of the Rural Health Care program. The full text of the NPRM is available on this website. Instructions for filing comments are found within the document.

For Funding Year 2001, RHCD has issued $8 million in Funding Commitment Letters to rural health care providers. Since Funding Year 2001 ends on June 30th, any FCC Form 465s that are yet received for Funding Year 2001 cannot complete the required 28-day posting and cannot receive support unless they have an RHCD-approved "evergreen" contract. Applicants are urged to submit Funding Year 2002 Form 465s as soon as possible, so their eligible support state date can be started after the 28-day posting.

RHCD would urges applicants to use the new electronic certification option for FCC Forms 465 and 467. Qualified applicants using e-certification will save time and effort by submitting these forms, since they are electronically pre-filled and it avoid any mail delay in RHCD's receipt of the forms.

To streamline the application process for both service providers and applicants, RHCD is examining potential changes to the process. Ideas discussed included the posting of urban rates on RHCD's website, to aid in processing and reduce the amount of information needed from applicants and service providers. Other ideas included elimination of FCC Form 468, or pre-populating Form 468 electronically and making it available from the website. Call participants voiced various opinions on these ideas.