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July 26, 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 15 for FY 2021 was released on Thursday, July 22nd, for a total of $51.5 million.  Cumulative commitments are $1.67 billion.  Nationwide, USAC has now funded 86% of the FY 2021 applications representing 57% of the requested funding.

The 2021-2022 application window for the Emergency Connectivity Fund (“ECF”) opened June 29th and will close August 13th.

FCC Service Delivery and Certification Changes:

Last Thursday, the FCC released a Public Notice (DA 21-881) modifying/clarifying two provisions of the original Emergency Connectivity Fund (“ECF”) Order (FCC 21-58) that had been of concern to a number of applicants.  Specifically:

  • One original certification on the ECF application states that “[t]he applicant or the relevant student, school staff member, or library patron has received, or the applicant has ordered the equipment and services for which funding is sought.”  That certification is being modified to read that: “[t]he applicant or the relevant student, school staff member, or library patron has received, or the applicant has ordered or will order, the equipment and services for which funding is sought.” [change emphasized]  This addition will permit applicants to file their ECF applications, and perhaps wait until their applications are approved, before actually placing their orders.  Presumably, applicants filing their ECF applications now, before the online Form 471 is modified to reflect the change, will be covered under the revised certification.
  • The original Order included an invoice filing deadline indicating that invoices must be filed “within 60 days from the date of the funding commitment decision letter; a revised funding commitment decision letter approving a post-commitment change or a successful appeal of previously denied or reduced funding; or service delivery date, whichever is later.”  Recognizing that the delivery dates for non-recurring services and equipment may not be known at the time applicants submit their applications, the FCC established a default delivery date of June 30, 2022, for these services.  At the earliest, therefore, the invoice deadline for non-recurring services and equipment will be August 29, 2022 — 60 days after the end of the 2021-2022 ECF funding year.

Both changes will make many applicants more comfortable with the ECF application and invoicing processes.

FCC FAQ Updates:

To assist applicants — not to mention USAC — in tracking additional ECF guidance, the FCC manages a master ECF FAQ list on its website.  Updated FAQs are added periodically, marked with an asterisk, and are often subsequently repeated in USAC’s weekly Emergency Connectivity Fund Program Newsletter.

Four of the more interesting new FAQs added by the FCC (as of July 16th) are:
FCC FAQ Updates - duration of internet service reimbursement 
FCC FAQ Updates - do I need to modify my library invenory system to track all of the required recordkeeping data in a single report
FCC FAQ Updates - do the CIPA requirements apply for all equipment that is eligible for ECF support

Different groups of FCC staff were active in several webinars last week and responded to questions that have not yet been published in the FCC’s list of FAQs.  Here are two questions and the FCC responses we heard (please treat these as informal guidance):

Q:     Must schools survey parents/families to determine unmet needs?
A: No.  For application purposes, schools can rely on a variety of methods to estimate unmet needs.  Parental surveys are not mandatory.  Schools may rely on other publicly available data such as: (a) NSLP data to determine financial ability to afford internet services or connected devices; or (b) maps or other data on area connectivity and home computer penetration.
Note that while estimates of unmet needs are fine for application purposes, schools must ultimately be able to document the need for services and devices provided to students.
   
Q: Must all ECF applicants be registered with SAM?
A: To provide maximum invoicing flexibility, SAM registration is recommended for all applicants.  SAM registration is not required to file an ECF Form 471 application but is required for BEAR invoicing.  Applicants relying solely on SPI invoicing need not be registered in SAM (but, in that event, their service providers must be SAM registered).
Note: The SAM SPI-exception option may be of interest to private and parochial schools seeking to participate in ECF without being the direct recipients of federal funding.  E‑Rate Central is reporting this strategy but is not espousing an opinion on the legality of this framework.

Upcoming E-Rate Dates:

July 27 USAC webinar on E-rate equipment transfers (2:00 p.m. ET) (Register).
July 28 USAC’s “Office Hours” ECF webinar at 3:00 p.m. EDT (Register).  These webinars are held weekly to provide program updates and answer participant questions.
July 29 Form 486 deadline for FY 2020 covering funding committed in Wave 49.  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 50            08/06/2021
Wave 51            08/13/2021
August 13     Closing date for the initial Emergency Connectivity Fund (“ECF”) window.  The window will close at 11:59 p.m. EDT.

USAC’s Emergency Connectivity Fund Program Newsletter of July 20, 2021, provides answers to the following frequently asked questions:

  • Do schools and libraries need to keep documentation of the specific students, school staff, or library patrons who receive Emergency Connectivity Fund-supported service or equipment?  Short answer: Yes.
    Hint: See E-Rate Central’s Inventory and Service Log Templates.
  • What does it mean for a household to lack access to broadband?  For example, what if the school paid for a student’s broadband service using other sources of funding, including federal funding, last year?  Short answer: Applicants must make a “reasonable” determination.
  • Will USAC wait until the application filing window closes to approve applications?  Short answer: Yes.
  • Do schools need to identify the names of specific students who lack access to a connected device or broadband connectivity on the application?  Short answer: Only a “best estimate” is required for application — but see ultimate documentation requirement noted above.
  • Is there a minimum number of days that hotspots or connected devices must be in use – that is, loaned out to library patrons – to justify reimbursement for the services or equipment?  Short answer: There is no “hard and fast test”, but the goal is to avoid warehoused equipment.

The ECF Newsletter also notes: “Reimbursement request forms for the Emergency Connectivity Fund Program will be available in the ECF Portal.  Applicants and service providers will use the ECF Portal to submit requests for reimbursement.  Additional information regarding the invoicing process for the Emergency Connectivity Fund Program will be coming soon.”

USAC’s Schools and Libraries News Brief of July 23, 2021, summarizes the following activities that E-rate applicants may be involved with this summer:

  • New applicants: Review the steps in the application process.
  • FY 2020 invoicing: Collect your customer bills for reference and review your Form 498 if you intend to file BEAR Forms.
  • FY 2021 PIA review: Check your EPC account for unanswered questions and provide the information requested.
  • FY 2021 Form 486: Confirm your service start date and provide the status of your compliance with CIPA.
  • FY 2022 Form 470: If you are ready to open your competitive bidding process, you can certify this form.
  • ECF applicants: File the ECF Form 471 on or before the close of the initial application window on August 13th.  Note the recent FCC Public Notice discussed above.

USAC also announced that, after 15 years of continuous publication of 49-50 weekly issues a year, the Schools and Libraries News Brief will be taking a break for the remainder of the summer and will resume this fall.  We are particularly dismayed by this publication break because it is undoubtably related to the retirement — as of the date of this News Brief — of John Noran, the SLD’s Senior Manager of Outreach and long-time News Brief author and editor.  John has organized all of USAC’s E-rate training and has been an effective and much loved personality across the entire E-rate community.

We will miss you John Noran.  Go forth and prosper!