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June 14, 2021

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7814), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 9 for FY 2021 was released on Thursday, June 10th, for a total of $57.5 million.  Cumulative commitments are $1.30 billion.  Nationwide, USAC has now funded 76% of the FY 2021 applications representing 44% of the requested funding.

As discussed in earlier newsletters, funding for the Emergency Connectivity Fund (“ECF”) is coming through the U.S. Treasury through Congressional appropriations, not via the Universal Service Fund (“USF”).  This funding source will require an ECF participant to register and receive a Commercial And Government Entity (“CAGE”) Code through the federal System for Award Management (“SAM”) system.

We have found that many E-rate applicants are already registered in SAM for other purposes.  Existing registrants should check that their CAGE Codes have not expired and renew their registration as needed; applicants not yet registered in SAM need to apply.  Neither process is overly burdensome, but the SAM.gov website was updated last week with additional authentication procedures requiring a little work.  With the first ECF application window set to open shortly — perhaps within the month — we recommend checking for active SAM registrations or applying for new ones before the end of June (see warning below).

The first thing you’ll see on the SAM.gov website is the announcement of the recent update stating:

SAM.gov announcement of the recent update

Click on the “OK” button to get to the new SAM Homepage, which includes the following section for registering, renewing, or simply checking registration status.

SAM.gov registration section

To proceed with any of these options, you will have to log into the SAM system, assuming that you already have an account established through login.gov — the “public’s one account for government.”  If you don’t have a login.gov account, you can register for one via the link on the SAM.gov sign-in page.

SAM.gov sig-in

For instructions from this point forward, see How do I register a new entity or update an existing entity registration in SAM.gov?  These instructions also explain how, if necessary, to replace a SAM Entity Administrator — the equivalent of E-rate’s EPC Account Administrator — if that person is no longer available.

Warning:  The argument for starting the SAM registration process as soon as possible is implicit in the following instructions:

Please allow up to 10 business days after submitting your registration for it to become active in SAM. Prior to becoming active, your SAM entity registrations must pass the TIN validation with the IRS and the CAGE validation/assignment with the DLA. The processing time may be longer if either party flags the registration data for manual validation.

If you notice your registration has a status of Submitted for 15 business days or longer, and have not otherwise been contacted by the IRS or DLA to correct or update the necessary information, please contact the Federal Service Desk.

We are hopeful USAC will allow ECF applicants to file without an active CAGE code and allow them to provide a valid code before USAC issues a commitment.

Upcoming E-Rate Dates:

June 18     Form 486 deadline for FY 2020 covering funding committed in Wave 43.  More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 44            06/25/2021
Wave 45            07/02/2021
Wave 46            07/09/2021
June 21 Due date for comments on Comcast’s FCC gift rule waiver request to provide its Lift Zone initiative to establish remote learning centers in seven selected library systems (see Comcast waiver request and FCC comment notice DA 21-597).  Reply comments are due July 6th.

EBB Enrollments and Claims:

USAC has posted an Emergency Broadband Benefit Program (“EBB”) Enrollments and Claims Tracker on its website.  Currently, the site is showing new and cumulative enrollment on a weekly basis.  Total enrollment as of June 6 was 2.3 million households.  As the internet suppliers begin to submit invoices for EBB discounts, the site will also show claim amounts — a critical factor in projecting the life of the EBB program that is capped at $3.1 billion.

USF Quarterly Contribution Factor Down From High:

The FCC announced that the Proposed Third Quarter 2021 Universal Service Contribution Factor (DA 21-676) will be 31.8% — below last quarter’s record 33.4% and back to the first quarter’s level.  Fortunately, the additional $7.1 billion needed for the Emergency Connectivity Fund  (“ECF”) and the $3.1 billion Emergency Broadband Benefit (“EBB”) program will be coming out of the U.S. Treasury directly, not out of the Universal Service Fund (“USF”)

USF Quarterly Contribution Factor Down From High

USAC’s Schools and Libraries News Brief of June 11, 2021, indicates that USAC’s One Portal system will be updated in July to eliminate the need to enter, much less need, a PIN when filing a BEAR.  Effectively, the BEAR filing system will now become an EPC option.  When selecting the BEAR Form option on the One Portal EPC dashboard, a user will need only enter the Billed Entity Number (“BEN”).  In making this change, USAC will be transferring BEAR login information for current BEAR filers to the new BEAR Access Tool.

Note:  The transfer of current BEAR login information into the unified One Portal system will mean that BEAR filers, who currently only have access into the separate BEAR system, must now request access into the broader EPC system.  USAC will be sending notices to all such users later this week.

USAC’s News Brief also announced the following EPC updates:

  • When a request to certify a Funding Request Number (FRN) on the Form 486 is canceled, the applicant can now resubmit that FRN on a new Form 486.
  • The first, second, and final demand payment letters now reflect a surcharge of 30 percent (an increase from 28 percent) based on the latest guidance from the U.S. Treasury.
  • Applicants and consultants can now limit searches to program forms and requests located under the Records tab that were filed by their organization.