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September 27, 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 24 for FY 2021 was released on Thursday, September 23rd, for a total of $38.2 million.  Cumulative commitments are $2.23 billion.  Nationwide, USAC has now funded 94% of the FY 2021 applications representing 77% of the requested funding.

Wave 1 of the Emergency Connectivity Fund (“ECF”) was released Friday, September 24th, for a total of over $1.2 billion.  An additional two-week 2021-2022 ECF application window will open tomorrow, September 28th.

First Funding Wave:

The first ECF funding wave was big news.  It was first announced on Friday by Vice President Kamala Harris in an interview on ABC’s “The View,” followed quickly by an FCC news release and a funding data Excel file.  By midday, successful applicant contacts were receiving emails with attached Funding Commitment Decision Letters (“FCDLs”) beginning:

ECF Funding Commitment Decision Letter

By Saturday morning, USAC’s ECF dataset was updated to reflect the first wave’s approval data.  The changes to approved line items include:

Col. B Form Version is changed from “Original” to “Current.”
Col. C Form PDF URL is blank (not yet available).
Col. D Application Status is changed from “Certified” to “Committed.”
Col. AM     Funding Request Status is changed from “Pending” to “Funded.”
Col. BA FRN Approved Amount is no longer blank.
Col. BD Invoice Deadline Date is set at 8/29/2022.
Col. BH FCDL Comment for FRN is most commonly set as “Approved as submitted” but there are significant instances of SPIN changes, cancellations, and funding changes (often for device funding requested in excess of the $400 cap).

As per the FCC’s ECF Order, now that the first wave of ECF FCDLs has been released, USAC must begin to accept reimbursement requests within 15 days (see USAC’s Requests for Reimbursement guidelines).

FCC Treatment of Out-of-Window ECF Applications:

Earlier last week, the FCC announced (DA 21-1182) that late-filed applications certified after August 13th, the close of the initial ECF application window, will be treated as In-Window applications within the second ECF application window opening September 28th and closing October 13th.  The FCC’s action has several important implications, namely:

  • Out-of-Window applications for the first window will automatically be reclassified and processed as In-Window applications in the second window.  Affected applicants need not re-file in the second window nor request FCC waivers for their late-filed applications.  For the time being, however, the ECF dataset is still showing these applications as being filed in “ECF Window 1” (Col. F) with an “Out Of Window” status (Col. AJ).
  • One potential drawback of having a late-filed application processed in the second window is the possibility that funding requests may exceed the program’s $7 billion cap.  Should this occur, funding will be allocated for second window applicants beginning with, and working down from, those with the highest discount levels.
  • Although the FCC has historically granted waivers submitted by late-filing applicants who filed within two weeks of the deadline, the FCC’s announcement clearly states that it does not “expect to grant waivers of the Program’s second application filing deadline of October 13, 2021 absent a showing of extraordinary circumstances.”

Fund Utilization Summary Charts:

The E-Rate Central website has long provided a popular database tool displaying applicants’ E‑rate histories tracing back to 1998 and providing the capability of drilling down to the individual FRN detail.  As indicated in the sample below, we are currently adding comparable ECF data.

E-Rate Central's database tool

Please note that the ECF data display is a work in progress and includes only applicant level funding requests and commitments.  Drill down capability to the FRN level will be provided shortly.

Note also that, in anticipation of USAC’s move to treat late-filed applications, filed after the first window (as per the FCC Public Notice discussed above), funding requests for certified Out-of-Window applications will be displayed as pending ECF Window 2 applications.

Upcoming Dates:

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 Form 486 deadline for FY 2020 covering funding committed in Wave 57.  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 58            10/07/2021
Wave 59            10/14/2021
Wave 60            10/21/2021
September 30 General non-recurring service delivery deadline for FY 2020 and, under the FCC’s COVID extension, for FY 2019.
October 13 Close of the second ECF application window for 2021-2022.
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).

USAC’s Emergency Connectivity Fund Program Newsletter of September 21, 2021, covers the following topics — mostly repeating information from the previous week’s newsletter:

  • A warning that incomplete Form 471 applications generated during the first ECF application window will be cancelled in advance of the opening of the second window on September 28th.
  • A reminder that service providers have access to the ECF Portal through their OnePortal dashboards.
  • Last minute announcement of two ECF overview and invoicing webinars last week.  Recordings of these webinars are available via the registration links in the newsletter.

The ECF newsletter repeats last week’s frequently asked questions adding only the following:

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?
Short answer: Yes.