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July 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.

Wave 12 for FY 2020 was released on Thursday, July 23rd for a total of $39.7 million. Cumulative commitments are $1.18 billion. Nationwide, USAC has now funded over 76% of the FY 2020 applications received during the filing window representing about 41% of the requested funding.

The FCC released a draft of the Eligible Services List (“ESL”) for FY 2021 (DA 20-767). As is usually the case, the draft ESL remains virtually unchanged from the previous year, and the comment period is unlikely to engender additional updates. The accompanying Public Notice notes only two minor additions/changes including (a) a reference to the prohibition on the use of equipment and services provided by “covered companies” deemed threats to national security, and (b) updated language on the new Category 2 budget rules for school districts and library systems. Additionally, we found one update on a link to a USAC web resource. Specifically:

Corrected reference
 

Page 4 old:
Draft Eligible Services List for FY 2021 corrected reference page 4 old

Page 4 revised:
Draft Eligible Services List for FY 2021 corrected reference page 4 revised

Category 2 budget change
 

Page 6 old:
Draft Eligible Services List for FY 2021 category 2 budget change page 6 old

Page 6 revised:
Draft Eligible Services List for FY 2021 category 2 budget change page 6 revised

Reference to new ban on Huawei and ZTE
  Page 9 new:
Draft Eligible Services List for FY 2021 reference to new ban on Huawei and ZTE

Comments on the draft ESL are due August 20th; reply comments are due September 4th.

Up until now, most discussions of remote learning have focused on student access at home. With the pandemic still raging, and the new school year about to start, few schools are planning for a return to fully traditional, in-class instruction. Remote learning in full or in hybrid mode is a more likely scenario for most schools at least through the 2020 fall semester.

Many schools are beginning to realize that whatever may have worked — often with hard work and with impressive success — on a short-term basis last spring, when most students and their parents were quarantined at home, may not work as the economy begins to reopen and parents return to work outside their homes. At-home remote learning may no longer be feasible for many students. If these students can’t be in a classroom every day, and must participate remotely, where will that be? Will there be adequate Internet access? And most importantly, will it be safe and supervised?

An answer we’re hearing to these questions is often “day care.” But traditional day care, focusing on younger children and facing its own COVID-related problems, is unlikely to be the answer for dealing with a flood of older K-12 students requiring properly-distanced workspaces to support full-day remote learning (and support services including supervision, technology, meals, etc.). Putting aside private pandemic “pods,” as discussed in a recent New York Times Op-Ed, schools have two basic options.

  • In-school remote learning facilities. This seemingly oxymoron-like approach recognizes that while socially-distanced classrooms hold less students, most schools have other larger capacity spaces — gyms, auditoriums, cafeterias, etc. — that could support other students attending classes “remotely” while still being supervised and supported within their schools.
  • Non-school remote learning centers. With ongoing pandemic restrictions on social gathering, many large venue facilities — community centers, theaters, convention centers, churches, etc. — remain unused or under-utilized and (with proper staffing) could be used as remote learning centers. Use of such facilities raise financial, technical and potential regulatory issues. In particular:
    • Rental (hopefully modest in community-based facilities) and configuration costs must be addressed. CARES 2.0 legislation, with substantial school support remains pending but, if enacted, would hopefully not preclude funding of such facilities.
    • WiFi capacity will likely need to be boosted with higher Internet bandwidth, mobile hotspots, and/or additional cloud-managed WAPs.
    • To maximize E-rate flexibility, states may wish to formally designate such facilities as schools or annexes at least on an interim basis.

Upcoming E-Rate Dates:

July 27     Implementation of multifactor authentication (“MFA”) as a requirement for E-rate applicants to access EPC or the BEAR Form systems through a new “One Portal” (see USAC News Brief referenced below).
August 20     Deadline for submitting initial comments on the FCC’s draft ESL for FY 2021 (DA 20-767) — see article above. Reply comments are due September 4th.

FFL 2020 Applicant Survey Findings:

Earlier this summer (see our newsletter of June 15th) we urged applicants to complete the E-rate survey conducted by Funds For Learning (“FFL”). This was FFL’s tenth annual nationwide survey — a particularly important one coming at a time of expanded need for critical E-rate support. Earlier this month, FFL presented the results of its 2020 survey to FCC staff (see extensive ex parte report). Key findings of FFL’s survey, with an impressive response rate of 10% of E-rate applicants, included the following:

  • The E-rate program is succeeding in its mission to provide faster, cost-effective, Internet services to more students and library patrons.
  • Additional E-rate support is needed for cybersecurity, redundant Internet access , VoIP services, and school bus WiFi.
  • Emergency and ongoing funding is needed to support remote learning.

USAC’s Schools and Libraries News Brief of July 24, 2020 covers the following three topics:

  1. The FCC’s release of the draft Eligible Services List (“ESL”) for FY 2021 (discussed in more detail above).
  2. This past weekend’s implementation of a new multifactor authentication (“MFA”) process to enable applicant access to USAC’s EPC and BEAR Form systems effective today, July 27th (see our newsletter of July 20th).

    To login, a user will first enter their regular username and password. The system will then send the user a temporary security passcode to be entered as shown below.
    USAC's new multifactor authentication (“MFA”) process
  1. Reminders for filing a Form 470 for FY 2021, namely:
    • You must file the Form 470 in EPC.
    • If you issue a request for proposal (RFP) and/or RFP documents, you must upload these documents to your Form 470.
    • Certify the form online in EPC.
    • Service providers can view filed Forms 470 either through EPC or on the USAC website.