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September 13, 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 22 for FY 2021 was released on Thursday, September 9th, for a total of $21.1 million. Cumulative commitments are $2.16 billion.  Nationwide, USAC has now funded 93% of the FY 2021 applications representing 75% of the requested funding.

The first 2021-2022 application window for the Emergency Connectivity Fund (“ECF”) closed Friday, August 13th.  Applications received during the window totaled over $5 billion.  An additional two-week 2021-2022 ECF application window will open September 28th (see our newsletter of August 30th).

The FCC continues to update its master ECF FAQ document to reflect new guidance.  The most recent updates as of September 9th (marked with an asterisk) include the following questions and answers:

*6.14 Q: After submitting an application during the first application filing window, a school or library realizes they need additional equipment and services to meet their students’, school staff’s, or library patrons’ unmet needs.  Can the school or library submit another application during the second window to address these unmet needs?
A:  Yes.  If a school or library determines there is additional need for eligible equipment and/or services, they may submit another application during the second application filing window to address these unmet needs.  However, applicants should not seek support for equipment and services already requested during the first filing window. Applicants requesting support for similar services or equipment should clearly explain the differences between their requests. See FAQ 7.10.

*7.9 Q: How will requests be prioritized?
A: In the event that demand exceeds available funding during any ECF application filing window, funding requests will be prioritized based on an applicant’s E-Rate discount rate for category one services, adjusted to provide a five percent increase for rural schools and libraries.  This means that those schools and libraries entitled to a higher E-Rate discount will receive funding ahead of those entitled to a lower discount rate, as reflected in the discount matrix provided in section 54.1708(c) of the ECF rules.

*7.10 Q: If a school or library submitted an application during the first application filing window and has not heard from USAC on their funding request by the time the second application filing window opens (e.g., September 28, 2021), should they re-apply for funding in the second window?
A: No. Applicants should not re-file applications that were already submitted in the first application filing window. Submitting duplicate requests may lead to additional delay in the review of applications and will be denied.

*7.11 Q: If I have the credentials to access the ECF Portal, can I begin filling out my application for the second application filing window before the window opens?
A:  No. Applicants should not begin completing an ECF Form 471 in the ECF Portal for the second application filing window until the window opens on September 28, 2021.

*9.8 Q: What should an applicant or service provider submit along with a request for reimbursement (ECF Form 472/474)?
A: Each request for reimbursement must be accompanied by a vendor invoice supporting the amount requested. Vendor invoices must include the level of detail needed for USAC to validate the following information during its review of this supporting documentation.

  • A date of the service for non-recurring charges, or a bill date for recurring charges that is consistent with what was entered on the ECF Form 472/474.
  • A date of the service or bill that is acceptable based on the relevant funding period.
  • The equipment or services provided are the same as what was approved on the ECF Form 471 (unless modified pursuant to an approved post-commitment change) and are at or below the price approved on the ECF Form 471.
  • The service provider who provided the equipment or services is the same as the service provider approved on the ECF Form 471 (unless modified pursuant to an approved post-commitment change).
  • The service or equipment has been delivered.

*9.9 Q: Can a school or library submit a reimbursement request after it has received the ECF-supported equipment but before it distributes the equipment to their students, school staff, or library patrons?
A: Yes. While the school or library must have received the equipment or services prior to submitting their request for reimbursement and must certify to this on the ECF Form 472, they can seek reimbursement before distributing the equipment or services to students, school staff members, or library patrons with an unmet need.

Applicants and service providers are also reminded of the need to certify on their reimbursement requests (ECF Forms 472/474) that they are not willfully or knowingly requesting reimbursement for equipment or services that are not being used.

Upcoming E-Rate Dates:

September 16     Form 486 deadline for FY 2020 covering funding committed in Wave 55.  More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines are:
Wave 56            09/23/2021
Wave 57            09/30/2021
September 27 Due date for initial comments on the FCC’s draft version of the Eligible Services List (“ESL”) for FY 2022 (DA 21-1062).  Reply comments are due by October 12th.
September 28 Opening of the second ECF application window for 2021-2022.  This shorter 15-day window closes October 13th.
September 30 General non-recurring service delivery deadline for FY 2020 and, under the FCC’s COVID extension, for FY 2019.
October 20 Nomination deadline for six USAC Board members including one school representative.  The FCC subsequently added a request for board member nominations representing commercial mobile radio service providers (due November 8th).

FCC Hurricane Ida Rule Waivers:

In response to the devastation caused by Hurricane Ida, the FCC waived (DA 21-1107) a number of rules for many of its programs including E-rate, ECF, and EBB for schools and libraries in Affected Disaster Areas.  The affected areas include all Louisiana parishes and Mississippi counties.  Similarly affected E-rate and ECF entities located outside of the Affected Disaster Areas may request comparable, narrowly-tailored relief.

Affected E-rate applicants have been granted:

  • Extended program deadlines to 150 calendar days after the effective date of the Order for
    • Requests for review or waiver by USAC or the FCC
    • Form 486 filings
    • BEAR or SPI invoice filings
  • Service implementation deadline extensions
    • FY 2020 non-recurring services by one-year to September 30, 2022
    • Existing special construction projects to June 30, 2023
  • Relief from documentation retention and production requirements
  • Functional flexibility on service and equipment substitutions

Affected Emergency Connectivity Fund (“ECF”) applicants have been granted:

  • Extended program deadlines to 150 calendar days after the effective date of the Order for
    • Responses to PIA information requests
    • Requests for review or waiver by USAC or the FCC
  • Relief from documentation retention and production requirements
  • Functional flexibility on service and equipment substitutions

Relief is also provided to participating providers and household users of Emergency Broadband Benefit (“EBB”) internet discounts to account for widespread service outages.  In a separate, relatively minor, action (DA 21-1119), the FCC expanded EBB benefits to all households participating in school meal programs for the 2021-2022 school year.

USAC’s Emergency Connectivity Fund Program Newsletter of September 7, 2021, addresses the following frequently asked questions:

Will I have visibility in the ECF Portal for the committed version of my application?
Short answer: Yes.

Will I receive a notification when the PIA reviewer contacts me about my application?
Short answer: Only if you are full rights ECF Portal user.

I can access the ECF Portal, but can’t file any forms – what can I do?
Short answer: Ask the account administrator to make you a full rights ECF Portal user.

Is there a CFDA – Catalog of Federal Domestic Assistance number assigned to the Emergency Connectivity Fund?
Short answer: Yes, it’s 32.009 (see our newsletter of September 6th).

I am a service provider, have a Service Provider Identification Number (SPIN), and need access to the ECF Portal. How do I get access to the ECF Portal?
Short answer: Sign into your OnePortal account; ECF is the second option.

I am a service provider and agreed to invoice USAC for equipment or services for ECF support on behalf of the applicant. Where do I submit the invoices?
Short answer: “Invoicing will be available via the ECF Portal in the coming weeks.”

If the service provider is invoicing on behalf of the applicant, does it need a SPIN for ECF?
Short answer: Yes.