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August 10, 2020


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 14 for FY 2020 was released on Thursday, August 6th for a total of $59.1 million. Cumulative commitments are $1.30 billion. Nationwide, USAC has now funded 80% of the FY 2020 applications received during the filing window representing almost 46% of the requested funding.

The State E-Rate Coordinators’ Alliance (“SECA”) has filed an Ex Parte request with the FCC asking for additional COVID-19 relief on behalf of E-rate applicants. Two specific initiatives are proposed.

Funding Additional On-Campus Internet Connectivity for FY 2020:

SECA notes that many schools have found it necessary to increase their Internet bandwidth beyond what was initially requested in their FY 2020 applications to support both on-campus and remote learning usage. In order to provide funding in such situations, SECA encourages the FCC to permit and fund additional bandwidth this year using any of three possible options: (a) authorizing USAC to approve appeals for additional funding; (b) adopting a liberal FCC waiver policy; or (c) opening a second, one-time, Form 471 window for FY 2020. In any event, SECA urges the FCC to temporarily waive competitive bidding procedures to accommodate requests for additional bandwidth.

To build support for this effort, SECA is asking applicants requiring additional bandwidth to complete a very brief Internet survey concerning their increased broadband requirements for FY 2020.

Gift Rule Waiver Extension Through FY 2020:

Last March, as the full effect of the pandemic was becoming clear, the FCC issued a special waiver Order (DA 20-290) permitting E-rate applicants to accept free or reduced-priced hardware and/or services, used to support remote learning during the pandemic, without running afoul of the FCC gift rules (see our newsletter of March 23rd). This special waiver is currently in effect only through September 30, 2020. The waiver states, “We will monitor the situation and assess the need for continued relief in the future.” Given the ongoing nature of the pandemic and the FCC’s willingness to evaluate the need for continued relief, SECA asks the FCC to extend the gift rules waiver through June 30, 2021.

similar request to extend the gift rule waiver was submitted to the FCC the following day by the Schools, Health & Libraries Broadband Coalition (“SHLB”), the Consortium for School Networking (“CoSN”), and the State Educational Technology Directors Association (“SETDA”).

E-Rate Central fully supports both requests of the FCC.

Upcoming E-Rate Dates:

August 12
at 1:00 p.m. EDT    
NYSED E-rate training: MFA Access to the USAC One Portal System
Meeting ID: 966 1985 0676
Password: 741266
August 20 Deadline for submitting initial comments on the FCC’s draft ESL for FY 2021 (DA 20-767) — see our newsletter of July 27th. Reply comments are due September 4th.

FCC Extends FY 2020 Late-Filed Application Waivers:

The FCC issued an Order (DA 20-845) last week extending the scope of its late-filed application waiver policy in light of the pandemic. Traditionally, the FCC had routinely granted waivers on late-filed Form 471s filed within two weeks of the close of USAC’s application window. This year, treating COVID-19 as an “extraordinary” circumstance, the FCC has been granting special waivers for pandemic-related late-filings of up to 30 days. Last week’s Order extended the late-filing period to 60 days and approved waivers for an additional 51 applications. We expect to see additional waivers for similarly affected applicants.

Applicants submitting waiver requests for applications filed within the 60-day period should note that waivers are not automatically granted. Applicants should be able to demonstrate “that they were unable to meet the filing window deadline…due to timing constraints and procedural obstacles associated with extended school and library closures.”

School Reopening Resources Available from the Parabola Project:

The Parabola Project — a joint effort of The Learning Accelerator and Ariadne Labs, funded by One8 Foundation — is a non-profit initiative committed to rapidly develop evidence-informed, open-licensed tools to help school system leaders identify options for school reopening during the COVID-19 pandemic. The Project’s tools are not intended to supplant official federal, state, or local guidance but rather to lay out implementation options. Initial resources from the Parabola Project include:

  • School Reopening Readiness Guide: This evidence-informed guide is intended to assist district and school leaders in developing, evaluating, and executing operational plans for reopening schools, as well as in assessing readiness to implement these plans.
  • Practitioner Toolkit: How to Build a Mask Culture: This resource aims to help educators consider how to best help students adjust to and sustain mask-wearing.
  •  This resource aims to help educators consider how to support small-group, collaborative, and one-to-one learning while physically distancing.

President Trump Withdraws Re-Nomination of FCC Commissioner O’Rielly:

President Trump, who had re-nominated Commissioner Michael O’Rielly to a new term on the FCC last March, withdrew that re-nomination last week even though the re-nomination had already been approved by the Senate (albeit before O’Rielly’s current term expires at the end of this year). This surprising development is formally related to an action by Sen. Jim Inhofe (R-OK), Chairman of the Senate Armed Forces Committee, to place the nomination on hold until the Commissioner agrees to vote to overturn the FCC’s unanimous decision last April approving an application for a low-power L-band terrestrial network that many, including the Defense Department, are concerned would create GPS interference. Less officially, the withdrawal may reflect the President’s concern with the FCC’s more recent decision to open public comment on an NTIA petition for a rulemaking on Section 230 of the Communications Decency Act governing legal liability of Internet content. Perhaps unsurprisingly there are politics involved in the re-nomination withdrawal, hopefully to be resolved before yearend.

USAC’s Schools and Libraries News Brief of August 7, 2020 reviews the process for filing applicant Form 498s. Applicants intending to submit BEAR reimbursement forms are required to have approved Form 498s on file in order to provide USAC with the necessary bank account and contact information to support ACH payments. Unless there is a change in this information, a Form 498 need only be filed once.

An applicant filing a Form 498 for the first time will need to provide the following information:

  • Contact information for the applicant’s key official and general financial officer.
  • The applicant’s DUNS Number as provided by Dun & Bradstreet.
  • The applicant’s FCC Registration Number.
  • Bank routing number and bank account number for direct payments.