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August 8, 2022

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.

E-Rate for FY 2022:

Wave 16 for FY 2022 was issued on Thursday, August 4th, for $85.9 million.  Cumulative commitments to date are $2.21 billion.  Nationwide, USAC has funded 93.8% of the FY 2022 applications representing 71.4% of the requested funding.

ECF for 2021-2023:

Total commitments as of Wave 19 for ECF-1/2 and Wave 4 for ECF-3, issued jointly on July 27th, are $5.56 billion.  Nationwide, USAC has funded 96.4% of the applications from ECF windows one and two, and 18.5% of applications from ECF window three.  Authorized disbursements as of last Friday totaled $1.53 billion.

Upcoming Dates:

August 18 Form 486 deadline for FY 2021 covering funding committed in Wave 53.  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 54                      09/06/2022
Wave 55                      09/15/2022
Wave 56                      09/26/2022
Note: The first Form 486 deadline for FY 2022 Waves 1-11, committed before July 1st, will be Monday, October 31st.
August 26 ECF deadline for “Affected Applicants” to file requests with USAC asking to restore the voluntarily reduced months of service for their first or second window recurring service funding requests (see DA 22-799 and our newsletter of August 1st).
September 9 Last day of the “Summer Deferral” window giving applicants additional time to respond to PIA E-rate inquiries.  No such deferral period is in effect for ECF inquiries.
September 30     Service delivery deadline for FY 2021 non-recurring services.

CEP and the Build Back Better Act:

According to the Food Research & Action Center (“FRAC”), the recent Build Back Better Act (H.R. 5376) adopted by the House of Representatives, if passed by the Senate and enacted into law, would dramatically expand the Community Eligibility Provision (“CEP”) program to provide free student breakfasts and lunches to more schools and districts.

Two elements of the enhanced CEP, which might by themselves generate more bipartisan support than the Build Back Better Act as a whole, would be:

  • For the next five school years, beginning on or after July 1, 2022, and ending before July 1, 2027: (a) the CEP multiplier for directly identified students would be increased from 1.6x to 2.5x; and (b) the directly identified student percentage threshold for CEP participation would drop from 40% to 25%.
  • For the same period, and under certain non-Federal funding provisions, a statewide community eligibility option would be available to provide free school meals for all schools.

 The FRAC report provides individual state fact sheets estimating the impact of the BBB provisions, if enacted, on each state.

From an E-rate perspective, the critical issue would be whether the FCC would adopt the five-year CEP changes for discount rate purposes.  If so, the increased CEP multiplier (2.5x up from 1.6x)  and lower direct certification requirement (25% down from 40%) would raise the discount rate of many schools and districts.  The statewide option, if adopted for E-rate purposes, would move all applicants to the highest discount rate.  If the FCC did not adopt either change, it would presumably have to redefine the discount rate calculation mechanism.

We would welcome expansion of CEP, whether it is reflected in E-rate discounts or not.  CEP, even as currently configured, is a winning program for schools and students alike.