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June 1, 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.

Wave 4 for FY 2020 was released on Thursday, May 28th for a total of $50.4 million.  Cumulative commitments through May 28th are $817 million.  Nationwide, USAC has now funded 58% of the FY 2020 applications received during the filing window representing over 26% of the requested funding.  Funding through May is 4% greater than at the same point last year.

Upcoming E-Rate Dates:

June 30     Extended deadline to calculate Identified Student Percentage (“ISP”) data for use with the Community Eligibility Provision (‘CEP”) free school meal option.  The deadline for electing the CEP option for the 2020-2021 school year has also been extended to August 31st (see USDA’s COVID-19: Child Nutrition Response #6).

FCC Decision Watch:

The FCC issued another set of “streamlined” precedent-based decisions (DA 20-572) last week.  Applicants facing similar problems as those addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes.  The original appeal and waiver requests can be found online in the FCC’s Search for Filings under Docket 02-6.

In May’s streamlined decisions, the FCC:

  1. Dismissed:
    1. One Request for Review of an appeal that was not first filed with USAC.
  2. Granted:
    1. 138 Requests for Waiver for late-filed FY 2020 Form 471 applications filed within 14 days of the close of the window.
    2. One Request for Review and/or Waiver instructing USAC to reconsider all information previously submitted by an applicant to determine whether the request should be funded.
    3. One Request for Review and/or Waiver “due to USAC’s failure to properly process updated submission by school.”
  3. Denied:
    1. Seventeen Requests for Waiver for invoice deadline extension requests.
    2. One Request for Waiver for a service substitution for services that were not initially sought by the applicant.

“E-rate to the Home” Legislation:

The proposed “E-rate to the Home” legislation, spearheaded by the Schools, Health & Libraries Broadband (“SHLB”) Coalition, has now garnered almost two thousand signatories from the education community and is due to be presented to Congress next week as Congress resumes operations.  As discussed in our newsletter of May 18th, this proposal is designed to build upon, focus, and expand on other pending legislation including funding for remote learning.

With many schools and libraries facing fiscal uncertainties for the coming year, we expect that more E-rate applicants than normal will opt to receive FY 2020 E-rate discounts directly from their service providers, using the SPI method, rather than pay for services in full and file for BEAR reimbursements later.  Applicants who have already been funded for FY 2020 — more than half — may want to file their Form 486s before July 1st to give their service providers ample time to enable SPI calculations in their billing systems.

USAC’s Schools and Libraries News Brief of May 29, 2020 reminds applicants of the following conditions that must be met and certifications that must be made when filing early Form 486s:

  • Receipt of a Funding Commitment Decision Letter (“FCDL”) for approved funding
  • CIPA compliance
  • Service start dates on or before July 31
  • Authorization to submit the Form 486 on behalf of the applicant

Last week’s News Brief also notes updates to the following “legacy” system tools:

Note also that USAC’s FRN Status Tool (FY 2016 and forward) was temporarily taken down for maintenance last week — hopefully to be restored early this week.