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June 21, 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.

Wave 10 for FY 2021 was released on Thursday, June 17th, for a total of $72.9 million.  Cumulative commitments are $1.37 billion.  Nationwide, USAC has now funded 78% of the FY 2021 applications representing 46% of the requested funding.

The FCC announced that the initial Emergency Connectivity Fund (“ECF”) application window will open next week on Tuesday, June 29th, and will close 45 days later on Friday, August 13th.

This first window will permit eligible schools and libraries to apply for funding to meet the off-campus (e.g., home) “unmet needs” of their students, school staff, and library patrons for internet services and connecting devices for the 2020‑2021 year.  Assuming sufficient funding, a subsequent application window may provide retroactive funding of school and library expenditures for similar equipment and services provided during the first 16 months on the pandemic, March 1, 2020 to June 30, 2021.

USAC/FCC Training and Services:

USAC held an introductory ECF webinar last Wednesday (see slides).  The following two pre-window points were discussed:

  • ECF applicants will file their Form 471 applications within a separate ECF section of USAC’s One Portal system, much like as filing E-rate applications in EPC.  For potential ECF applicants already listed in EPC, USAC will carry-over user credentials thus creating ECF user profiles using the same usernames, passwords, and rights.
  • USAC reminded potential applicants that they will need FCC Registration Numbers (which existing E-rate applicants will already have) and current SAM registrations (which some applicants may have for other purposes).  As discussed in our newsletter of June 14th, and reiterated in USAC’s webinar, the SAM registration process may take several weeks.

As indicated below in the Upcoming E-Rate Dates section, both USAC and the FCC will be presenting ECF webinars this week.  USAC also plans to provide e-learning modules and to conduct weekly “office hours” video sessions to provide ECF updates and answer questions.  Applicants are encouraged to Stay Informed about ECF by signing up for informational emails (including weekly newsletters) and training opportunities.  Additional ECF information is available online from USAC, the FCC, and E-Rate Central’s recent newsletters.

USAC will also be implementing an ECF Customer Service Center helpline, separate from the E‑rate helpline, at 800-234-9781.  An announcement on that line indicates that the ECF helpline will be available 8:00 a.m. to 8:00 p.m. ET effective this coming Wednesday, June 23rd.  Questions can also be emailed to ecfcustomersupport@usac.org.

Defining, Surveying, and Documenting Unmet Needs:

Perhaps the most important issues faced by schools and libraries planning to apply for ECF is to determine exactly what equipment and services, in what quantities, and ultimately for which individuals, is funding to be requested.  To a large degree, these issues depend upon further FCC clarification of the definitions of “unmet need,” “sufficient,” “remote learning,” and “educational need” — all terms used in applicant Form 471 certifications (our newsletter of May 24th).

In one sense, if these definitions are not clarified, libraries may be in a better position to certify compliance by relying on the certifications of their own patrons.  The ECF rules specifically “require that the library patron sign and return a statement that the library patron would otherwise lack access to equipment or services sufficient to meet the patron’s educational needs if not for the use of the equipment or service being provided by the library.”

Although the ECF rules do not require schools and school districts to obtain similar certifications from student families receiving school-provided and ECF-funded devices and/or internet services, cautious schools and school districts may wish to adopt a library-like certification process when surveying student needs and/or actually delivering equipment and services.  E-Rate Central expects to have more to say on this topic after next week’s USAC and FCC webinars.

The FY 2022 version of the Form 470 will be available in EPC on July 1st for those wishing to begin the traditional E-rate procurement process at that time.  (Note:  ECF procurements, as distinct from traditional E-rate procurements, need only follow state and local laws.  Form 470s are not required for ECF purposes.)   

Based on a working example in USAC’s applicant test site, the FY 2022 Form 470 version appears to have been substantially revised to address the service type pull-down menus that have been the source of confusion in recent years.  At first glance, the new version looks much better.

The first thing you’ll notice is that service requests for Category 1 and Category 2 no longer start from a single screen.  More importantly, there are tables of clearly defined service options that, when selected, lead to logically related sub-options.  For example:

New Category 1 service request with sub-options
E-rate new Category 1 service request with sub-options

New Category 2 service request with sub-options
E-rate new Category 2 service request with sub-options

Reminder: USAC’s News Brief of June 4th warned applicants who started, but have not yet certified a FY 2021 version of a Form 470, that those forms must be certified by this June 25th so that USAC can update the Form 470 by July 1st.  After Friday, uncertified FY 2021 Form 470s will be removed from EPC.

Upcoming E-Rate Dates:

June 21     Due date for comments on Comcast’s FCC gift rule waiver request to provide its Lift Zone initiative to establish remote learning centers in seven selected library systems (see Comcast waiver request and FCC comment notice DA 21-597).  Reply comments are due July 6th.
June 23 USAC Emergency Connectivity Fund overview webinar for potential applicants — 3:00 p.m. EDT.  Registration link.
June 25 FCC webinar (DA 21-696) to provide information on the Emergency Connectivity Fund (ECF), on fcc.gov/live — 2:00 p.m. EDT.  Registration is not required for the event.  Questions can be submitted in advance or during the webinar at ECFwebinar@fcc.gov.
June 25 FY 2019 recurring services invoicing deadline for funding requests that received an extension of the February 25, 2021 deadline.
June 25 Form 486 deadline for FY 2020 covering funding committed in Wave 44.  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 45            07/02/2021
Wave 46            07/09/2021
Wave 47            07/16/2021
Wave 48            07/26/2021

Updated Federal Broadband Funding Guide:

The National Telecommunications and Information Administration (“NTIA”) has released an updated BroadbandUSA Federal Funding Guide with information on more than 80 federal programs across 14 federal agencies whose funding can be used for broadband-related purposes.  Funding opportunities include direct grants, loans, indirect support, and discounts for industry, state and local governments, schools, libraries, small businesses, and other community institutions.  The information is also available as a spreadsheet to allow users to sort the material by selected criteria.

Advocacy Groups Urge Appointment of 5th FCC Commissioner:

A coalition of more than 50 advocacy organizations, including the American Library Association, sent a letter last week to President Biden and Vice-President Harris urging the immediate nomination of a candidate for the fifth and final position as FCC Commissioner.  This a seat has been vacant since the resignation of the previous FCC Chairman upon the inauguration of President Biden.  The group’s letter noted the importance of a full FCC Commission to address numerous critical issues including the need to “[a]pprove emergency waivers for E-rate funded infrastructure to be opened up for remote education.”

USAC’s Schools and Libraries News Brief of June 18, 2021, provides additional details and timing of USAC’s plans, discussed in the previous week’s News Brief, to eliminate the requirement for a separate PIN to access the BEAR filing system within USAC’s One Portal system.  As indicated in the table below, the transition to the PIN-less BEAR system will temporarily disable BEAR filings for an estimated four days in early July.

E-rate BEAR PIN Removal Schedule

Last week’s News Brief also reminds service providers that the Form 473 (“Service Provider Annual Certification” or “SPAC”) will now require two additional certifications affirming compliance with the National Security Threat rules for the use of equipment provided by certain Chinese “covered” companies.

Importantly, what last week’s News Brief did not mention was the opening of the initial ECF application window on June 29th.  We believe that this is an indication of USAC’s plan to essentially treat traditional E-rate and the Emergency Connectivity Fund as distinct programs.  As indicated above, interested ECF applicants are encouraged to Stay Informed by signing up for informational emails (including weekly newsletters) and training opportunities.