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September 28, 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 22 for FY 2020 was released on Thursday, September 24th for a total of $34.4 million.  Cumulative commitments are $1.68 billion.  Nationwide, USAC has now funded 89% of the FY 2020 applications representing 60% of the requested funding.

Our newsletter of September 21st included a series of unofficial FAQs based on our understanding of the FCC’s rules for the second application window for FY 2020.  A more official set of FAQs is included in this week’s USAC Schools and Libraries News Brief of September 25, 2020, as reviewed below.

Question:     What are the requirements for applicants who want to apply for support during the second filing window for FY 2020?
Answer: E-rate funding in the second window is limited to on-campus Category 1 Internet access and/or data transmission services needed to meet schools' additional bandwidth needs as a result of the COVID-19 pandemic.  Applicants must:
  • have already sought bids for the services by posting a Form 470;
  • have received an FCDL approving a funding request for Category 1 Internet access and/or data transmission services that relied on a valid Form 470 or have such a request pending with USAC; and
  • be requesting additional E-rate discounts on a Form 471 during this second window to purchase additional bandwidth through their existing service provider or a new service provider.
Question: Can libraries apply for additional bandwidth?
Answer: No.  This funding opportunity is only available to schools.
 
Question: I need some associated hardware to make use of my additional bandwidth.  Can I apply for discounts on Category 2 equipment?
Answer: No.  Eligible services are limited to Category One Internet access and/or data transmission services needed to meet a school's additional bandwidth needs as a result of COVID-19 only.
 
Question: Do I have to certify a new FY 2020 Form 470 to apply for additional bandwidth?
Answer: No.  If you previously certified an FCC Form 470 for the services you are requesting, you can cite that FCC Form 470 application number on the FCC Form 471 you certify during the second window.

Note, however, that some applicants may want to file a new Form 470 if required to do so by state or local procurement rules or regulations.  In this case, the applicant is not required to wait 28 days before certifying an FCC Form 471 that cites the new Form 470 application number. 
 
Question: Do I have to create a new contract record before I can file my Form 471?
Answer: If the FCC Form 470 and the resulting contract you signed cover the additional bandwidth you are requesting, you can cite your existing contract record.
However, if you have signed a contract amendment or a new contract, you should create a new contract record for the amended or new contract and cite that new contract record on your Form 471.
 
Question: If my Internet is provided on a month-to-month basis, am I required to sign a contract?
Answer: No.  You can request the additional bandwidth on a month-to-month basis as well.
 
Question: What information do I need to provide on my Form 471?
Answer: The Order requires that you provide the following information in the narrative section of the new FCC Form 471 funding request:
  • the identification numbers for the original FY 2020 Form 471 and the original Funding Request Numbers (FRNs) that previously relied on the Form 470;
  • a statement confirming that the requested E-rate discounts are for additional bandwidth needed as a result of the COVID-19 pandemic; and
  • additional information in the narrative section about the price per megabit in the original and new funding requests and highlighting any difference in pricing.
In addition, USAC is asking applicants to include a statement in the narrative section clarifying whether your request is for additional bandwidth on an existing circuit or if you are installing a brand new circuit.  This information will help their reviewers understand how your new request fits with your original request.
 
Question: My new Form 471, filed during the second FY 2020 filing window, is showing an out-of-window status.  Do I need to file a waiver request with the FCC?
Answer: No.  As long as you certify your new FY 2020 Form 471 between September 21, 2020 and October 16, 2020 (i.e., during the second window), USAC will move your form to an in-window status within 24 hours of submission and add your form to the queue for Program Integrity Assurance (PIA) review.

The out-of-window message (shown below), displayed when you start a Form 471 in EPC, is a confusing aspect of the second window filing process.  In order to begin accepting second window applications as quickly as possible, USAC did not create a separate filing protocol nor did they amend their misleading out of window message.  To proceed beyond this message, simply click “Continue.”
E-rate out-of-window message

Note:  If you certify your Form 471 after October 16, 2020 at 11:59 p.m. EDT (i.e., after the second window closes), you will have to file a waiver request with the FCC.
 
Question: I certified an out-of-window Form 471 before the second FY 2020 filing window opened on September 21, 2020.  Will USAC move my form in-window so that it is considered during this second window?
Answer: No.  To request support during the second FY 2020 filing window, you must certify a new FY 2020 Form 471 during the second window and meet the requirements in the Order.
 
Question: I applied for Internet access after the original FY 2020 application filing window closed.  Can I apply for additional bandwidth now?
Answer: If you have not already done so, you should file a waiver request with the FCC for your out-of-window FCC Form 471.  You can certify your new Form 471 for additional bandwidth, but USAC will not be able to review your application unless the FCC approves your waiver request.

Upcoming E-Rate Dates:

September 30     Normally the service delivery deadline for the delivery and installation of FY 2019 non-recurring services.  Applicants taking advantage of one-year service delivery extensions are reminded that they may have to extend their contracts accordingly and to so notify USAC via Form 500s.
October 12 Nomination deadline for six USAC Board members including one school representative (see our newsletter of August 17th).
October 16 The second Form 471 application window for FY 2020 closes at 11:59 p.m. EDT.

As discussed above, USAC’s Schools and Libraries News Brief of September 25, 2020, includes a series of questions and answers concerning the recently initiated second application window for FY 2020.  Schools, school districts, and school-based consortia needing funding for additional bandwidth to meet on-campus Internet demands related to the COVID-19 pandemic have until October 16th to file new Form 471s.

Last Friday’s News Brief also includes a One Portal login reminder for those seeking access to EPC and/or the BEAR filing system.