Documenting and Reporting Appropriate Use of your New Connection

Early adopters of telemedicine and health information technology like you and the State of Oregon are paving the way for the future of health care delivery and access. By using an OHN connection to support the health care of tomorrow, OHN participants are able to experience a wealth of direct and indirect revenue enhancing and cost savings benefits—all while improving the lives of the patients and health care students that you serve.

The purpose of the FCC RHCPP program (and OHN) isn’t just to provide you with a subsidized broadband connection and to manage the billing process. We want to make sure that you make full use of, and experience the greatest value and benefit from your new OHN connection. That said, with any subsidy or grant, you will be required to participate in random audits of your new connection, proving that you’re using the connection per FCC requirements (eligible services and demonstrated benefitted use).

As Oregon’s RHCPP subsidy recipient and your partner, OHN is here to make sure that you meet/exceed the documentation, reporting and use requirements of the subsidy.

Documentation

OHN has invested in many tools to ensure that you have the best user experience, including the development of our web-based Sharepoint Site Portal. This portal houses core documentation tools necessary for a future audit. By using this tool, you can educate your team to ensure that the OHN connection is used to the fullest to improve the quality, delivery and access of care. Documents that are already organized and readily accessible on your Site Portal includes copies of your:

• Form 465 Package: Letter of Agency, Site Eligibility & Network Diagram
• Form 466: Vendor Contract/Service Order
• Form 467: Support Acknowledgement Letter
• Funding Commitment Letter (FCL)
• Telecommunications provider vendor invoices/15% payments & supporting documentation
• OHN Participation Agreement & Addendum
• OHN administration has all supporting back ground communication with USAC, your accreditation information, your RFP and a copy of your JACO report
  

The Universal Services Administration Company (USAC) is the third-party vendor that manages the FCC’s RHCPP, and will be responsible for scheduling/coordinating audits. Since the contract for subsidized RHCPP/OHN services exists between you and your approved vendor, USAC will contact you directly for an audit. When you are contacted, you have the comfort of knowing that all your core documentation is already available and organized within your OHN Site Portal.

Reporting

OHN is required to submit quarterly reports on the current and future known uses of the subsidized connections. The value of this activity is not only for you and OHN to pass audit, but truly to assist the FCC in identifying the trends and future demands of their intended nation-wide health network deployment. Therefore, OHN staff will be reaching out to you and your team on a regular basis to understand the core uses of the network and the anticipated improved outcomes associated with them, so that the FCC can itself prove the importance/value of broadband support mechanisms within health care such as what’s been provided through the RHCPP and standard Rural Health Care program.  To assist us in this process, please download a copy of our Site-Use Survey at  http://www.oregonhealthnet.org/content/ohn-participant-survey-network-use - and forward on to Monica Koiv at mkoiv [at] oregonhealthnet [dot] org.

Appropriate Use

All healthcare related services including administration, images, patient records, distance learning/education, etc. that support patient care or provider/student education provided by an eligible, non-profit, facility fits in one or more of the below categories:

• Community health centers or health centers providing health care to migrants
• Local health departments or agencies including dedicated emergency departments of rural for-profit hospitals
• Community mental health centers
• Not-for-profit hospitals
• Rural health clinics, including mobile clinics
• Consortia of health care providers consisting of one or more of the above entities:
  • Part-time eligible entities located otherwise in-eligible facilities
  • Other emergency services
  • Post-secondary education facility

General

Equally important to using the connection(s) for the appropriate type of services, is in making sure that your connection is in fact being used. Having dormant or very low use of your connection will most likely not be viewed favorably in the eyes of the FCC.

Additional information surrounding the FCC/USAC audit process is available in the OHN Welcome User Guide and Audit Flier. Furthermore, if you have any detailed questions surrounding the USAC audit process, please contact USAC’s Internal Audit Division via e-mail: auditinquiry [at] usac [dot] org
 
OHN strongly advises that internal audit procedures are followed per your outside auditor’s advice. OHN has provided audit information to your site per USAC’s instructions in order to provide good customer service and is not meant to be inclusive. OHN is not responsible for your site’s audit compliance or the results/findings of an audit conducted by USAC or the FCC.