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January 11, 2021

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 37 for FY 2020 was released on Thursday, January 7th, for a total of $12.6 million.  Cumulative commitments are $2.09 billion.  Nationwide, USAC has now funded 95% of the FY 2020 applications representing 75% of the requested funding.

FY 2021:

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. EST.  Thereafter, entity profiles will be locked for the duration of the application window.  (See USAC News Brief below.)
  • 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 the USAC Special Edition Schools and Libraries News Brief dated December 22, 2020.

The FCC released a Public Notice (DA 21-6) last Monday seeking comments on the implementation of the Emergency Broadband Benefit (“EBB”) program to be established as a part of the recent COVID stimulus legislation (the Consolidate Appropriations Act, 2021).  The EBB program, to be administered by the FCC through USAC, will provide discounts on internet services of $50 per month for low income families for the remainder of the COVID emergency period (see our newsletter of December 28th).  One-time discounts of up to $100 will also be available on connecting devices (laptops, tablets, etc.).  Although the program is not directly related to E‑rate, it promises to provide benefits to schools seeking to assure that all their students have access to reasonably priced internet service to support remote learning during the pandemic.

The FCC will be implementing the EBB program on an accelerated schedule.  Last week’s Public Notice sets an initial 20-day comment period (ending January 25th) and another 20-day reply comment period (ending February 16th).  Final regulations are due 20 days thereafter.  Discounts, once established, will run through the “emergency period” ending six months after the government deems that the COVID crisis has been resolved.

The EBB administrative model proposed by the FCC is similar to, and will rely on, the Lifeline program (currently providing much smaller monthly subsidies to low income families on telephone and internet services).  Suppliers, providing the discounted services, can validate household eligibility based on Lifeline’s National Verifier database.  Alternatively, suppliers may rely on schools’ NSLP data — an opportunity, assuming confidentiality issues can be resolved, for schools to work collaboratively with supplier providers to make sure that their most needy families receive discounted services.

Requested comments in the Public Notice deal with various aspects of the EBB program including:

  • Interpreting the “standard rate” of services subject to the discount
  • Verifying household eligibility
  • Processing supplier reimbursements

Although the FCC’s Public Notice did not specifically request comments from schools, we believe that it is in the best interest of schools and their students to take a proactive approach to the EBB program’s implementation.  This can be achieved by participating in the comment process and, more importantly, reaching out in a collaborative way to local internet providers.

Upcoming E-Rate Dates:

January 11             Form 486 deadline for FY 2020 covering funding committed in Wave 20.  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 21            01/15/2021
Wave 22            01/22/2021
Wave 23            01/29/2021
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 at noon EST.  The window is scheduled to close at 11:59 p.m. EDT on March 25, 2021.
January 25 Comment deadline on the FCC’s Emergency Broadband Benefit (“EBB”) program.  Reply comments are due by February 16th.

USAC’s Schools and Libraries News Brief of January 8, 2021, reminds applicants that the administrative window is closing this coming Wednesday.  As of Thursday, through the end of the application window, EPC profiles will be locked.

In the three days left before the administrative window closes, USAC encourages tribal schools and libraries to designate their tribal status in their EPC profiles.

USAC’s News Brief also indicates that it is in the process of merging all its training resources into a single location on its website and reminds users that it is continuing to seek feedback on IT enhancements.