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March 8, 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 45 for FY 2020 was released on Thursday, March 4th, for a total of $20.1 million. Cumulative commitments are $2.265 billion.  Nationwide, USAC has now funded 97% of the FY 2020 applications representing 83% of the requested funding.

FY 2021:

The FY 2021 Form 471 application window will close on Thursday, March 25th, at 11:59 p.m. EDT.  Applicants who missed the February 25th Form 470 deadline (or the invoice deadline on the same day) should read USAC’s Schools and Libraries News Brief of February 26, 2021.

The FCC’s Emergency Broadband Benefit (“EBB”) Order (FCC 21-29), as discussed in our newsletter of March 1st, set a tight time schedule for the program’s implementation.  To begin offering discounts on internet services for low-income families by late April, internet service providers (“ISPs”) must formally elect to participate in the program.  Moving quickly, the FCC issued a Public Notice (DA 21-265) last week establishing open dates and deadlines for provider application and election notices.

Eligible Telecommunications Companies (“ETCs”) are automatically approved for the EBB and need only elect to participate.  Last week’s Public Notice announced that the inbox for “Provider Election Notices” will open on the USAC website on March 11th.

Non-ETCs must first be approved to participate before filing their “Election Notices.”  The Public Notice indicated that the “Non-ETC Provider Application & Alternative Eligibility Verification Process Portal” will open on the FCC website March 8th with a filing deadline of March 22nd.

Schools and libraries seeking to promote and/or participate in the EBB program on behalf of their students or patrons should review the EBB strategy memoranda * prepared by E-Rate Central.  Note that the timetable set forth in the FCC’s first Public Notice highlights the importance of reaching out to determine local ISP participation in the EBB program as soon as possible.

Upcoming E-Rate Dates:

March 12     Form 486 deadline for FY 2020 covering funding committed in Wave 29.  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 30            03/19/2021
Wave 31            03/25/2021
Wave 32            04/02/2021
Wave 33            04/09/2021
Wave 34            04/16/2021
March 22 “Non-ETC Provider Application & Alternative Eligibility Verification” filing deadline for ISPs seeking to participate in the EBB program (see article above).
March 25 The FY 2021 Form 471 application window will close at 11:59 p.m. EDT.

Senate Approves COVID Relief Bill with E-Rate Support:

The U.S. Senate approved a $1.9 billion COVID relief bill last Saturday presumably containing the equivalent $7.6 billion E-rate funding provision for off-campus broadband internet services as was contained in the House version approved the previous week (see our newsletter of March 1st).  This sets up final congressional approval by the House expected later this week so that the bill can be sent to President Biden for his signature.  Implementation will require action by the FCC.

USAC’s Schools and Libraries News Brief of March 5, 2021, provides the following reminders on evaluating bids:

  • Construct a bid evaluation matrix giving the highest weight to the price of eligible products and services.  In addition to USAC’s sample bid evaluation matrix, see E-Rate Central’s Excel-based Bid Responses Assessments workbook.
  • Any reasons for disqualifying bids must have been stated in your Form 470 and/or RFP (preferably both).
  • If you receive one or no bids, you can keep your competitive bidding process open and solicit additional bids.  If no bids, or only one bid, is ultimately received, that fact should be documented.
  • Accepted bid(s), even if only one bid is received for a given service, must be cost-effective.
  • Service providers selected must have a valid Service Provider Identification Number (“SPIN”).  Applications submitted during the last two weeks of the window may utilize an “interim SPIN.”
  • Retention of bidding information is important to document compliance with the E-rate competitive bidding rules.

 

*  E-Rate Central’s EBB strategy memos are based solely on our interpretation of the FCC’s initial EBB Order.  We expect the Order to be supplemented with additional FCC and USAC notices and clarifications.