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:
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. |
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| 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. |