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November 30, 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 31 for FY 2020 was released on Wednesday, November 25th for a total of $20.8 million.  Cumulative commitments are $1.95 billion. Nationwide, USAC has now funded 92% of the FY 2020 applications representing 69% of the requested funding.

Now that we’re on the threshold of December, and before thoughts turn to the holidays, all applicants should review/update their EPC entity profiles.  We expect that the Form 471 application window will open in January, perhaps late in the second week.  Shortly before the Form 471 window opens, USAC will close the administrative window.  That will lock entity profiles for the duration of the application window.

Entity profiles at the start of the administrative window generally reflect information based on  applicants’ FY 2020 applications including PIA modifications.  Changes for FY 2021 might include:

  • Adding or deleting schools, libraries, NIFs, annexes, or consortium members
  • Editing or updating entity names or addresses
  • Updating school enrollment numbers and NSLP eligibility data (and library square-foot areas, if necessary)

Updating school enrollment and NSLP eligibility will be a challenge this year.  With all students being eligible for free meals through June 30, 2021, traditional methods of reporting student family income, as required for E-rate purposes, are unlikely to be reliable.  As an alternative, USAC and the FCC have indicated that applicants can utilize FY 2020 data for FY 2021.  The following points should be noted for discount rate purposes:

  • With the COVID economy wreaking havoc with family incomes, FY 2020 eligibility percentages may not accurately reflect current levels.  Because E-rate discounts are based on bands of NSLP percentages, use of FY 2020 data is most likely to adversely affect applicants whose FY 2020 percentages were in the upper portion of the discount rate bands.  For example, an urban school district with 49% of its students qualifying for free or reduced lunches in FY 2020 was only 1% shy of increasing their discount from  60% to 80%.  However, any decrease in the return of NSLP forms would make this district unlikely to achieve an 80% discount rate even if family incomes in the area were actually lower this year.
  • Early indications are that states, which have historically provided NSLP valid files to USAC for discount rate validation purposes, will essentially be reusing the same FY 2020 valid file for FY 2021, perhaps with minor updates.
  • Applicants wishing to use more current measures of NSLP eligibility, not available from their states, may have to rely on family income surveys.  Sample surveys reflecting income eligibility guidelines for 2020-2021 are available on the E-Rate Central website in both English and Spanish.

It should be noted that school and district entity profiles have two fields each for student enrollment — one for discount rates and one for Category 2 budgets.  Although USAC and the FCC will also accept 2019-2020 enrollment data for FY 2021 Category 2 budget purposes, applicants able to document higher enrollments for 2020-2021 may use those higher numbers in the Category 2 budget fields.

Districts reviewing or updating Category 2 enrollment data in their entity profiles should note that the district profile page offers two options for reporting student counts — by district or by individual schools (the default).

E-rate Category Two (C2) budget information 

We recommend using per-school numbers for budget calculations so as to take maximum  advantage of the $25,000 prediscount minimum for small schools.  This is particularly important for small- to medium-sized districts with ten or fewer schools of various sizes and for larger districts with average school sizes of 150 students or less.

Upcoming E-Rate Dates:

December 4     Form 486 deadline for FY 2020 covering funding committed in Wave 14.  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 15              12/11/2020
Wave 16              12/18/2020

USAC did not issue a Schools and Libraries Program News Brief on Friday, November 27th, due to the Thanksgiving holiday.>