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August 24, 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 16 for FY 2020 was released on Thursday, August 20th for a total of $47.4 million. Cumulative commitments are $1.39 billion. Nationwide, USAC has now funded over 83% of the FY 2020 applications representing almost 50% of the requested funding.

As discussed in our newsletter of August 17th, USAC’s new Category Two Budget Tool is designed to calculate Category 2 budgets as of FY 2021. Under the new Category 2 rules, the five-year budget for any individual entity — school, school district, library, or library system — is determined by the following:

  • For most schools or school districts, $167.00 per student.
  • For most libraries or library systems, $4.50 per square foot.
  • For any individual school or library, a minimum of $25,000.

As of FY 2021, the most significant change is that Category 2 budgets are calculated on a district-wide or system-wide basis. In most cases, this is a straight-forward calculation. A school district budget is the greater of $167 per student or $25,000 per school. Similarly, a library system budget is the greater of $4.50 per total square foot or $25,000 per library.

However, for school districts or library systems with 10 or less component schools or libraries, there is an additional hybrid option. The budgets for each individual school or library can be maximized individually then added together to determine the district-wide or system-wide budget. This requires a more complicated budget calculation algorithm. Fortunately, USAC’s new budget tool handles these situations well. The following three examples include districts, each with four schools, whose budgets are optimized with the three different budget options: $167 per student, $25,000 per school, or the hybrid model.

Understanding USAC's Category 2 Budget Tool Algorithm

This is a little hard to read; each case is examined separately in more detail below. The key differences between the three examples depend upon whether the schools in a particular district have more or less than 150 students.

District 1 has the following schools, all with more than 150 students.
    School 1A 529   students
  School 1B 576  
  School 1C 247  
  School 1D     371  
    1,732   C2 Budget is $167 x 1,732 students = $287,741

 

District 2 has the following schools, all with fewer than 150 students.
    School 2A 53   students
  School 2B 81  
  School 2C 121  
  School 2D       20  
    275   C2 Budget is $25,000 min. x 4 schools = $100,000

 

District 3 has the following schools with more or less than 150 students.
    School 3A 33   students @ the minimum = 25,000
  School 3B 1,806   students @ $167/student = 301,602
  School 3C 591   students @ $167/student = 98,697
  School 3D     247   students @ $167/student = 41,249    
    2,677   Total C2 budget = $466,548
 

Note that in the first two examples, the Tool’s data lines list the "C2 Budget Algorithm" as "School District Wide," whether the calculation is based on the number of students or the number of schools, but in the third "hybrid" example the "C2 Budget Algorithm" is listed as "Per Site Basis School District." The "Per Site" designation is used only for the hybrid calculation.

Note also that the hybrid example is the only one with data in the column labeled "C2 Per Site Basis Difference." The $19,489 shown represents the difference between the higher hybrid budget of $466,548 and what the budget would have been without a hybrid option (in this case. $167 x 2677 = $447,059).

Most importantly, USAC’s new C2 Tool calculates a school district’s or library system’s budget using the best possible student and school parameters. Based on our tests, USAC’s budget calculation algorithm is working perfectly.

Upcoming E-Rate Dates:

September 4   Deadline for submitting reply comments on the FCC's draft ESL for FY 2021 (DA 20-767) (see our newsletter of July 27th and the summary of initial comments below)
October 12 Nomination deadline for six USAC Board members including one school representative (see our newsletter of August 17th).

Comments on the FCC's Draft ESL for FY 2021:

The comment period on the FCC's draft Eligible Services List ("ESL") for FY 2021 closed last week with only limited responses. The most extensive comments were filed by the State E-Rate Coordinators' Alliance ("SECA") and Funds for Learning ("FFL"). Both suggested the following:

  • Acknowledge the overlap between, or eliminate, the subcategories of Category 2 services between Internal Connections, Managed Internal Broadband Services, and Basic Maintenance of Internal Connections. Services and equipment often fall into more than one subcategory that can lead to application denials if not properly identified in applicant Form 470s.
  • Clarify that Category 2 data distribution equipment (e.g., switches) may be used to connect network devices of all types regardless of use without cost allocation.
  • Network security equipment and services should qualify for E-rate funding.

Additionally:

  • SECA recommended that connections between different schools on the same campus be treated as eligible in either Category 1 or Category 2. Currently such connections are defined as Category 1 only.
  • Several parties supported the E-rate eligibility of off-campus mobile hotspots.

Historically, the FCC has been receptive to comments seeking clarification of currently eligible services but has deemed requests for new product and service eligibility as being beyond the scope of the annual ESL process.

To access the BEAR system through USAC’s new One Portal system requires that your email address is associated with the BEAR filing system and that you have been assigned a BEAR Personal Identification Number ("PIN"). Once an applicant is in the One Portal, they will see the BEAR login screen.

E-rate BEAR login screen
 
USAC’s Schools and Libraries News Brief of August 21, 2020 reviews the procedures for accessing the BEAR form, requesting a new PIN, or regenerating a forgotten PIN.

Last Friday’s News Brief also discusses two new EPC upgrade features including simplified error messages and a new option to set and save one or more filters on the search pages located under the "Records" tab.