Collapse All

April 27, 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 56 for FY 2019 on Thursday, April 23rd.  Only two applicants were funded for a total of $283 thousand.  Cumulative commitments through April 23rd 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 almost 60% of the applications already designated as “Wave Ready.”

Members of both the House and Senate continue to push for funding in future stimulus legislation to support at-home schooling during (and beyond) the COVID-19 crisis.  At the forefront of this effort currently is the Emergency Educational Connections Act of 2020 which was recently introduced by Congresswoman Grace Meng (D-NY) with promises of companion legislation by Senator Edward Markey (D-MA) and others.  The proposed legislation would provide $2 billion in funding, authorizing the FCC to utilize those funds to support broadband connections, Internet access, and connected equipment (mobile hotspots, modems, routers, end-user devices, etc.) prioritized for students (or library patrons) who do not have residential access.

Unlike current E-rate funding through the Universal Service Fund (“USF”), the additional funding would be based on Congressional appropriations.  Exactly how the funding would be used by the FCC is not specified.  The bill sets a tight one-week timetable for the promulgation of implementing FCC regulations.  Given this condensed timeframe, the FCC would most likely leverage the existing E‑rate infrastructure modified to permit off-campus usage, an expanded Eligible Services List, and an expanded application window.  Proposals to do just that — as well as to expand funding beyond the $2 billion dollar level — are being circulated within the E‑rate community (e.g., see FCC filings by the Open Technology Institute and Funds For Learning).

The FCC’s Category 2 Order (FCC 19-117), released last December, established the basic Category 2 budgeting rules for ongoing 5-year budget cycles beginning with FY 2021 (see our newsletter of December 9th).  In January, two Petitions for Reconsideration were filed asking the FCC for two small but important changes and/or clarifications (see our newsletter of January 27th).  Specifically:

  • The State E-Rate Coordinators’ Alliance (“SECA”) asked the FCC to eliminate the requirement to allocate out of funding requests any Category 2 equipment used by standalone Non-Instructional Facilities (“NIFs”).  SECA argued that the allocation requirement was unnecessarily burdensome and unfairly penalized districts with separate administrative buildings.
  • Infinity Communications & Consulting (“Infinity”) asked the FCC to reconsider and/or clarify its decision to base Category 2 student counts on “full time” students only.  Infinity noted that the rule would disadvantage many specialized schools such as career centers largely serving part-time, often half-day, student enrollments.

In comments filed earlier this month, SECA joined Infinity encouraging the FCC to include large part-time student enrollments in the calculation of Category 2 budgets (see our newsletter of April 13th).  Reply comments, due last week, added support to both Petitions for Reconsideration, including:

Broad support for the two Petitions for Reconsideration and the absence of any opposing positions increase the likelihood of FCC amendments to the Category 2 budget rules effective FY 2021.  Those changes would simplify the treatment of NIFs and provide adequate funding for schools with large part-time enrollments.

 

Upcoming E-Rate Dates:

April 29        Extended closing date of the FY 2020 Form 471 application window (11:59 p.m. EDT).

USAC’s Schools and Libraries News Brief of April 24, 2020 building on last week’s News Brief, provides additional tips/instructions for first-time Form 471 filers including how to:

  • Return to an incomplete Form 471.
  • Certify a Form 471.
  • Correct information on a Form 471 after it is certified.
  • Complete a late-filed Form 471 after April 29, 2020.

Friday’s News Brief also reminds applicants of the extended operating hours of the Client Service Bureau for the five days leading up to the close of the current Form 471 application window, namely:

E-rate Client Service Bureau extended operating hours for the five days leading up to the close of the application window