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November 16, 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 29 for FY 2020 was released on Thursday, November 12th for a total of $34.0 million.  Cumulative commitments are $1.89 billion.  Nationwide, USAC has now funded 91% of the FY 2020 applications representing 66% of the requested funding.

Upcoming E-Rate Dates:

November 20     Form 486 deadline for FY 2020 covering funding committed in Wave 12.  More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later.  The upcoming Form 486 deadlines are:
Wave 13           11/27/2020
Wave 14           12/04/2020
Wave 15           12/11/2020
Wave 16           12/18/2020

Category 2 Budget Petitions for Reconsideration:

Last month’s FCC Public Notice DA 20-1218 expanded upon the FCC’s new Category 2 budget rules (FCC 19-117) for years FY 2021-2025.  As discussed in our newsletter of October 19th, the Public Notice dealt with the treatment of charter schools, closed or partially closed school buildings due to COVID-19, and independent schools with part-time students.  It also declined to change the rules requiring the cost-allocation of expenses associated with Category 2 equipment located in non-instructional facilities (“NIFs”).  Both the part-time student and the NIF allocation issues were previously raised by Petitions for Reconsideration, seconded by supporting comments.  Last week, within the 30-day appeal window, two additional Petitions for Reconsideration were filed asking the FCC to clarify aspects of the part-time student rule and to reconsider the NIF allocation rule. Specifically:

  • Current FCC rules, as modified last month, permit independent schools (such as vocational schools), attended by students from multiple other districts on a part-time basis, to count those students as full-time students for Category 2 budget purposes.  Recent USAC indications are that this rule might be interpreted narrowly as to apply only to stand-alone independent schools serving only part-time students.  E-Rate Central’s petition asks the FCC to clarify that the part-time student rule also covered all schools within independent districts including those that service both part-time and full-time students.

    Note:  E-Rate Central’s petition applies only in situations in which the schools with part-time students are independent of those students’ home districts.  This is not the case in many large school districts running their own career education or other special schools serving their own students on a part-time basis.  States with large county school districts may ultimately seek greater Category 2 budget support for such schools.
  • The State E-Rate Coordinators’ Alliance (“SECA”) petition asks the FCC to reconsider the NIF cost allocation requirement.  SECA argues that eliminating NIF allocations would greatly simplify the application and invoicing process for both applicants and reviewers and that, given districtwide Category 2 budget caps, would effectively be funding neutral.

In a somewhat related development, noting that caching servers are already eligible as Category 2, ApplianSys LLC filed a petition urging the FCC to initiate a rulemaking to make caching eligible as a Category 1 service.  The ApplainSys petition argues that this would “encourage the cost-effective use of E-Rate funds and reduce wasteful spend on excessive Bandwidth.”

Two weeks ago, over a three-day period, USAC conducted a series of nine online training sessions addressing the basics of E-rate.  Recordings of those sessions and copies of the slides are available on the USAC website.  USAC’s Schools and Libraries News Brief of November 13, 2020, provides what we expect to be the first in a series of FAQs from these training sessions.  Friday’s News Brief covers the following FAQs from the first three sessions:

2020 Training Kickoff Event:

  • Where can I find information on E-rate timelines?
  • Is there a list of frequently used terms on the USAC website?
  • Do you have more information on the e-learning modules?

E-rate Program Overview:

  • When do applicants need to file a Form 470?
  • Where can I find more information about COVID-19 impacts on the E-rate Program?
  • How can I check the status of review inquiries, pending applications, invoices and program requests?
  • Where can I get more information about eligible services?

EPC Demo:

  • How do I access EPC?
  • Can I change my EPC username if I get married or divorced?  (Note:  Hopefully not too frequently asked.)
  • Where do I update my National School Lunch Program numbers?
  • We are not required to provide student counts this year to be eligible for the National School Lunch Program’s funding from USDA due to the VOVID-19 pandemic.  How can I update the numbers in my EPC profile?
  • How do I filter my EPC News feed?