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January 25, 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 39 for FY 2020 was released on Thursday, January 21st, for a total of $23.0 million.  Cumulative commitments are $2.14 billion.   Nationwide, USAC has now funded 96% of the FY 2020 applications representing 77% of the requested funding.

FY 2021:

USAC opened the FY 2021 Form 471 application window on Friday, January 15th.  The window will close on Thursday, March 25th, at 11:59 p.m. EDT.  For additional information on the FY 2021 application window, see the USAC Special Edition Schools and Libraries News Brief dated December 22, 2020.

It has been less than a week since the inauguration, but we are already seeing some indications of changes affecting schools and the E-rate program.

The first is a change in leadership at the FCC.  Previous Chairman Ajit Pai resigned effective January 20th and existing Commissioner Jessica Rosenworcel has already been designated Acting Chair.  Next, we expect, President Biden will nominate a fifth Commissioner to fill the remaining slot on the Commission.  Although the FCC is not a highly political agency, the fifth Commissioner will give the Democrats a 3:2 edge within the Commission.

The Acting Chair is notably important because Jessica Rosenworcel has long been a proponent of the use of E-rate to help fund off-campus internet to address the “Homework Gap,” and, more recently during the pandemic, to support remote learning.  Most immediately, although not directly E-rate related, Commissioner Rosenworcel’s interest in remote learning should help assure that the new Emergency Broadband Benefit (“EBB”) program, providing discounts on internet services and devices for low-income families (see our newsletters of December 28th and January 11th) will focus heavily on school and student needs.

Longer-term, the Democratic-leaning FCC Commission is expected to be receptive to making E‑rate more useful on- and off-campus, if only to eliminate cost allocations on shared internet services or on cybersecurity products and services.  Supporting this approach is the specific language included in the Executive Order on Supporting the Reopening and Continuing Operation of Schools and Early Childhood Education Providers signed by President Biden on January 21st stating:

The Federal Communications Commission is encouraged, consistent with applicable law, to increase connectivity options for students lacking reliable home broadband, so that they can continue to learn if their schools are operating remotely.

While contemplating the direction that the FCC might take over the next four years, it’s interesting to review what the FCC has done over the past four years under a Republican administration.  Last week, the FCC did just that itself.  Each of the FCC’s bureaus, offices, and task forces was asked to summarize four years of effort.  Here are links to all those reports, highlighting the few issues noted as having any effect on E-rate:

Consumer & Governmental Affairs Bureau
Enforcement Bureau
        We have also entered into a Consent Decree focusing on certain New York City Department of Education E-rate practices—which resulted in repayment of more than $17 million to the Universal Service Fund and relinquished rights to another $7.3 million in unpaid invoices.
International Bureau
Media Bureau
Public Safety and Homeland Security Bureau
  In support of our national security mission, the Bureau designated Chinese companies Huawei and ZTE as national security threats, which bars Universal Service Funds from being used to purchase or maintain their equipment or services.
Wireless Telecommunications Bureau
Wireline Competition Bureau
  We further strengthened universal service and enhanced programmatic efficiency and accountability for all of the USF programs, for instance by implementing performance measures for high-cost recipients, promoting the deployment of Wi-Fi for schools and libraries, boosting funding for rural health care providers, and launching the National Lifeline Eligibility Verifier in all states and territories including Washington, DC.

The Bureau also ensured connectivity for Schools, Libraries, and Health Care Facilities by waiving certain program rules, extending deadlines, and increasing funding opportunities.
  • We partnered with the Department of Education to promote the CARES Act’s funding for remote learning; waived several Lifeline Program rules to help low-income consumers keep and maintain the broadband service that has been so crucial during the pandemic; and provided regulatory relief to ensure consumers would not lose access to software platforms so essential to school and work.
  • Finally, just recently, at the end of 2020, the Bureau began implementation of the $3.2 billion Emergency Broadband Connectivity Fund. This new program will reimburse participating companies for providing discounted broadband service and connected devices to eligible households during the COVID-19 pandemic.
Office of Communications Business Opportunities
Office of Economics and Analytics
Office of Engineering & Technology
Office of General Counsel
Office of the Managing Director
  USF and TRS Program Oversight and Management
  • Completed the transfer of funds to the Treasury for both the $8 billion USF and $1.4 billion TRS programs; and
  • Completed the timely transition to a new Business Process Outsourcing (BPO), which substantially improved management and oversight of the E-Rate program and resulted in significant cost savings and stronger information security controls
Incentive Auction Task Force
Rural Broadband Auctions Task Force

Of course if you’d really like to review what has happened in the E-rate world over the past four years, you might be better off reviewing the summaries we’ve provided in our newsletters for 201720182019, and 2020.  We’ve been at this longer than most.

Upcoming E-Rate Dates:

January 25 Comment deadline on the FCC’s Emergency Broadband Benefit (“EBB”) program.  Reply comments are due by February 16th.  See our newsletters of December 28th and January 11th.  EducationSuperHighway comments provide an early indication of EBB program issues from an educational perspective.
January 27 First two in a series of USAC “Office Hour” webinars initially covering the FY 2021 Eligible Services List (see links in the USAC News Brief referenced below) with the first session geared to advanced E-rate particpants and the second session designed for beginner and intermediate participants.  Subsequent webinars will be held on February 3rd and February 17th.
January 29 Form 486 deadline for FY 2020 covering funding committed in Wave 23.  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 24               02/05/2021
Wave 25               02/12/2021
Wave 26               02/19/2021
Wave 27               02/26/2021
February 25     Last day to file a Form 470 for FY 2021 to allow the required 28-day posting requirement.
March 25 The FY 2021 Form 471 application window will close at 11:59 p.m. EDT.

USAC’s Schools and Libraries News Brief of January 22, 2021, reviews the use of bulk upload templates to create, edit and review line item data in a separate spreadsheet format that can then be uploaded at the FRN level into a Form 471.  Upload templates are particularly useful for dealing with FRNs involving numerous line items and/or multiple recipients of service.

Four separate templates are available online in the FCC Form 471 Filing section (about halfway down) on USAC’s website.  Links to the current version of the templates and their version numbers are provided below.