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April 20, 2020

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.

FY 2019:

USAC released Wave 55 for FY 2019 on Friday, April 17th.  Funding was $14.4 million.  Cumulative commitments through April 17th are $2.26 billion. 

FY 2020:

The extended Form 471 application deadline for FY 2020 is 11:59 p.m. EDT on Wednesday, April 29th.  PIA reviews are currently underway with well over half of the applications already designated as “Wave Ready.”

Early this month, the FCC issued an Order (DA 20-364) extending the deadlines for service installations, for the filing of most E-rate forms, and for responding to USAC inquiries during the COVID-19 crisis.  We discussed the initial version of that Order in some detail in our newsletter of April 6th.  Last week the FCC issued an Erratum to that Order that extends deadline relief to earlier funding years.  The FCC’s online version of the original extension Order (cited above) has been updated to incorporate the changes, namely:

  1. All service implementation deadlines for non-recurring services, currently set for September 30, 2020, have been extended one year to September 30, 2021.  The original Order applied only to FY 2019 services.  In other words, the revised Order now applies the extension to earlier funding years for which the deadline had already been extended to this coming September.
  2. Similarly, the deadline for the completion of special construction installations currently set for June 30, 2020 — regardless of funding year — has been extended to June 30, 2021.  The original Order applied only to FY 2018 and FY 2019 services.  Again, this makes the revised Order apply to even earlier funding years for which the deadline had already been extended to this coming June.

We applaud the FCC for quickly and appropriately correcting and clarifying the original Order.

USAC, for its part and as summarized in last Friday’s News Brief referenced below, clarified its procedures for implementing the extended deadlines for responding to USAC’s information requests.  The following two points are important:

  1. Although USAC will implement the extended 30-day response deadlines, USAC notes that its EPC messaging system will unfortunately continue to automatically generate messages based on the customary program deadlines reflecting fifteen-day, seven‑day, one-day, or “no response” notices.  We hesitate to tell applicants to henceforth disregard these notices but treating them only as “warnings” may be appropriate.
  2. USAC states in its News Brief that it is “not moving to deny any of these forms or requests due to non-response or incomplete responses.”  This appears to represent an even more flexible approach than detailed in the FCC Order.  To implement this policy, we are seeing USAC reviewers starting to question applicants as to their availability to respond to inquiries much like USAC handles inquiries during the summer deferral period.  One of the only positive aspects of COVID-19 is that it seems to bring out the best in people.

Upcoming E-Rate Dates:

April 20 Deadline to file reply comments on the Petitions for Reconsideration filed by (a) the State E-Rate Coordinators’ Alliance (“SECA”) and (b) Infinity Communications & Consulting (“Infinity”) regarding Category 2 budgetary calculations for non-instructional facilities (“NIFs”) and part-time students.
April 29     Extended closing date of the FY 2020 Form 471 application window (11:59 p.m. EDT).

Updated Income Eligibility Guidelines for 2020-2021:

The U.S. Department of Agriculture’s revised income guidelines used to determine student eligibility for free and reduced-priced lunches — and thus for E-rate discounts — for the 2020-2021 school year were published in the March 20th Federal Register.  For the 48 contiguous states, the income eligibility thresholds are up 1.59%-2.16% over the preceding year.  An updated discussion of Discount Rate Optimization and sample income survey letters in both English and Spanish are available on the E-Rate Central website.

USAC’s Schools and Libraries News Brief of April 17, 2020 provides a few tips/instructions for first-time Form 471 filers including how to:

  • Log into EPC as a new user.
  • Change the EPC Account Administrator.
  • Create contract records in EPC.
  • Update EPC entity profile information.
  • Add or remove entities on a Form 471.

Friday’s News Brief also discusses USAC’s implementation of the new deadline extensions (as discussed above) and lists the following extended operating hours of the Client Service Bureau for the five days leading up to the close of the current Form 471 application window.

USAC extended operating hours for the Client Service Bureau.