Collapse All

December 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.

FY 2020:

Wave 35 for FY 2020 was released on Wednesday, December 23rd for a total of $27.3 million.  Cumulative commitments are $2.06 billion.  Nationwide, USAC has now funded 95% of the FY 2020 applications representing 74% of the requested funding.

FY 2021:

USAC announced that the FY 2021 Form 471 application window will open at noon on Friday, January 15th, and will close on Thursday, March 25th at 11:59 p.m. EDT.  Two other key dates associated with this window are:

  • The FY 2021 administrative window, allowing applicants to update their EPC entity profiles will close on Wednesday, January 13th at 11:59 p.m. EDT.  Thereafter, entity profiles will be locked for the duration of the application window.
  • Thursday, February 25th, will be the last possible day to file a Form 470 so as to allow the minimum 28-day posting period required before applicants can close their competitive bidding processes, evaluate bids, sign contracts, and file their Form 471 applications.  Whenever possible, avoid waiting until the last day to file Form 470s.

For additional information on the FY 2021 application window, see USAC Special Edition Schools and Libraries New Brief Dated December 22, 2020.

The latest COVID-19 relief bill —signed yesterday — does not include any additional E-rate funds or provisions that could be used for off-campus services supporting remote learning.  It does, however, include $54 billion in Elementary and Secondary School Emergency Relief (“ESSER”) that can be tapped for remote learning.  More specifically, the bill includes a $3.2 billion Emergency Broadband Benefit (“EBB”) program to subsidize the purchase of remote devices and home internet services during the pandemic.  EBB is to be implemented by the FCC, but not as a part of the E-rate program.

The following is a condensed summary of the key provisions of the EBB program (courtesy of Robert Bocher, Wisconsin State E-Rate Coordinator, ALA Fellow, and USAC Board member):

Program establishment:  The FCC shall establish a program to be known as the “Emergency Broadband Benefit Program.”  Under this program the FCC shall reimburse participating service providers — i.e., not users — for broadband internet access services and connected devices provided to eligible households.

Timing of program implementation:  Not later than 5 days after enactment of this Act the Commission shall provide a 20-day public comment period and subsequent 20-day public reply comment period.  Not later than 60 days after enactment of this Act, the Commission shall promulgate regulations to implement the Emergency Broadband Benefit Program.

Appropriations:  The program shall be funded by an Emergency Broadband Connectivity Fund of $3.2 billion.  The funding is for fiscal year 2021 but will remain available until expended.  The funds shall be provided from the U.S. Treasury and not from the Universal Service Fund.

Household eligibility:  To qualify for EBB support, at least one member of the household must meet one of these criteria:

  • Qualify for the Lifeline program;
  • Receive benefits under the free and reduced price lunch program or the breakfast program as verified by the associated school;
  • Have experienced a substantial loss of income since February 29, 2020;
  • Receive a federal Pell Grant in the current award year; or
  • Meet the eligibility criteria for a participating provider’s existing low-income or COVID–19 broadband internet connectivity program.

Eligible household broadband discount:  A household shall be eligible for a monthly discount on its internet service cost.  This discount shall be applied to the actual amount charged by the provider, not including taxes/fees.  Such a discount shall be no more than $50/month per household or $75/month on tribal land.  For example, if a provider's basic rate for broadband connectivity is $50/month and it is getting reimbursed at $50/month, the household pays nothing.  If the provider’s basic rate is $100/month and it is getting reimbursed at $50/month, the household pays $50/month.

Eligible household connected device discount:  A service provider who supplies a household with a connected device may be reimbursed up to $100.  A provider may receive reimbursement for only one connected device per household.  A connected device is a laptop or desktop computer.

Eligible participating providers:  The FCC shall establish an expedited process to approve broadband providers that are not designated as eligible telecommunications carriers.

Eligible provider certification:  To receive reimbursement, a participating service provider must certify adherence to several conditions including that if a household enters into a contract for internet service and later terminates the contract, the household will not be subject to any early termination fee.

Timeframe of emergency period:  The emergency period starts the date of the enactment of this Act and expires on the date that is 6 months after the date on which the Secretary of Health and Human Services determines the COVID-19 emergency has ended.

Post-program household connectivity:  At the conclusion of the EBB program, any participating households shall be subject to a participating provider’s generally applicable terms and conditions of internet service connectivity.

Role of USAC:  The FCC shall have the authority to avail itself of the services USAC to implement the EBB program.  This includes developing and processing reimbursements and distributing funds to participating providers.

Although EBB will not provide funds directly to schools, we believe that schools and districts can and should play a critical role by proactively preparing to encourage and to facilitate maximum participation of eligible families in the procurement of subsidized equipment and services to their most needy students and families.  Such actions, which can begin now, might include:

  • Developing lists of students most in need of devices and adequate in-home internet services.  For assistance in this process, EducationSuperHighway recently developed a K‑12 Digital Outreach Program that includes a step-by-step guide to identify students needing equipment and/or services.
  • Reaching out to local internet suppliers to encourage their early participation in the EBB program.  A willingness to cooperate and coordinate may encourage such providers to focus their EBB efforts on the local educational community at attractive price points.  Coordination efforts might include:
    • Promoting and targeting the EBB program;
    • Reminding suppliers of the FCC’s E-rate gift rule waiver through June 30th;
    • Integrating school internet services and CIPA compliance;
    • Cooperating technically on installations and trouble reports; and
    • Validating household program eligibility.

Note:  Maintaining the confidentiality of student family data is an issue that will need to be addressed in the final EBB regulations if the program expects the schools to provide validation, but the problem does not appear intractable.

Upcoming E-Rate Dates:

December 30     Form 486 deadline for FY 2020 covering funding committed in Wave 18.  More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 20            01/11/2021    Note: There was no Wave 19
Wave 21            01/15/2021
Wave 22            01/22/2021
January 13 The administrative window, allowing applicants to update their EPC entity profile, closes at 11:59 p.m. EDT.  Thereafter, entity profiles will be locked for the duration of the application window.
January 15 Form 471 application window opens as noon EST.

As noted above, USAC Special Edition Schools and Libraries New Brief Dated December 22, 2020, was issued earlier last week to announce the FY 2021 Form 471 application window.  The Special Edition:

  • Alerted first-time filers to establish an EPC user account.
  • Reminded applicants of the new five-year Category 2 budget cycle.
  • Encouraged applicants to begin the competitive bidding process.
  • Referenced the need to update EPC entity profiles during the administrative window.
  • Recommended installing browser updates for Google Chrome, the preferred EPC browser.