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July 5, 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 12 for FY 2021 was released on Thursday, July 1st, for a total of $63.5 million.  Cumulative commitments are $1.51 billion.  Nationwide, USAC has now funded 82% of the FY 2021 applications representing 51% of the requested funding.

The Emergency Connectivity Fund (“ECF”) application opened last Tuesday, June 29th, and will close August 13th.  Although questions regarding program details still abound, both the FCC and USAC have been diligently addressing many of them.  It may be useful, therefore, to summarize some of the ECF resources that are available.

FCC Information:

USAC Information:

  • ECF information site
  • E-Learning Modules for program overview and Form 471
  • Sign-up for ECF newsletters and training
  • Weekly USAC-hosted “Office Hour” sessions every Wednesday for program updates and Q&A
  • USAC’s ECF Newsletter of June 28th
  • ECF Customer Support Center (“CSC”) at (800) 234-9781 or via customer service requests in the ECF Portal
  • Statistical data on ECF applications is expected to become available in the Open Data system later this summer

E-Rate Central Information:

Upcoming E-Rate Dates:

July 6 Due date for reply 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).
July 7 USAC’s “Office Hours” ECF webinar at 3:00 p.m. EDT (Register).  These webinars will be held weekly to provide program updates and answer participant questions.
July 8-11     USAC BEAR Form migration period.  As noted in the USAC News Brief discussed below, the BEAR Form system is being updated to eliminate the PIN requirement.  July 7th will be the last day that a PIN will be required to file a BEAR.  USAC asks applicants to refrain from using the BEAR system until Monday, July 12th.
July 9 Form 486 deadline for FY 2020 covering funding committed in Wave 46.  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 47            07/16/2021
Wave 48            07/26/2021
August 13 Closing date for the initial Emergency Connectivity Fund (“ECF”) window.

FCC Streamlined Decisions:

The FCC issued another set of “streamlined” precedent-based decisions (DA 21-745) last week.  As with past streamlined decisions, applicants facing similar problems as those addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes.  The original appeal and waiver requests can be found online in the FCC’s Search for Filings under Docket 02-6.
In June’s streamlined decisions, the FCC:

  1. Granted:
    1. Three Requests for Review overturning USAC denials for ineligible services.
    2. Four Requests for Waiver of late-filed Form 471 applications due to circumstances beyond the applicants’ control.
    3. 49 Requests for Waiver of late-filed Form 471 applications filed within 14 days of the close of the FY 2021 window.
    4. 99 Requests for Waiver of late-filed Form 471 applications filed more than 30 days late.  The decision extended a special COVID waiver principle, previously applied to late FY 2020 applications, to similarly delayed FY 2021 applications.  The FCC warned that this additional relief applied only to this subset of applications and that applicants should not expect additional waiver grants “absent a showing of extraordinary circumstances.”
    5. Two Requests for Review or Waiver for not meeting the service substitution request deadline but otherwise complying with the rules and with a “reasonable explanation” for missing the deadline.
  2. Denied:
    1. One Request for Waiver of the Red Light Rule for failure to satisfy an FCC debt.
    2. One Request for Review for improper service provider involvement in the Form 470 process.  Applicant FRNs involving service providers other than the selected vendor were remanded back to USAC for further determination.
    3. One Request for Waiver for an invoice deadline extension.
    4. One Request for Review involving invoicing for products or services not on the applicant’s Form 470.

USAC’s Schools and Libraries News Brief of July 2, 2021, covers two changes to E-rate forms.

The Form 470 for FY 2022 was deployed within EPC on July 1st.  As previewed in USAC’s News Brief of June 25th and our newsletter of June 21st, the revised Form 470 includes the following changes:

  • Separate screens for Category One and Category Two service requests
  • Tiered guiding statements to assist users in their selections for service and function types
  • Alert messages and requirements for special circumstances related to certain function types
  • “Save & Create Another Request,” “ Save Request,” and “Cancel” buttons added for entering service requests
  • Shortcut to create a related Basic Maintenance request under Internal Connections
  • Additional text added to Internal Connections drop-down options that includes licenses and other associated options

The News Brief also provides additional information on an important change in the BEAR Form system eliminating the separate BEAR PIN requirement.  The non-PIN BEAR system will become available July 12th.  USAC notes the following important points:

  • BEARs will be filed from within the EPC system rather than in a separate BEAR system
  • USAC will transfer current BEAR Form filing credentials into EPC
  • BEAR filers for multiple BENs who had been using different email addresses can consolidate all their BENs under a single address by completing a BEAR access template
  • BEAR filers who have not had EPC access will need to be set up as a new EPC user by their BEN’s EPC account administrator