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:
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.
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.