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November 20, 2023


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 (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

E-Rate for FY 2023:

USAC issued Wave 30 for FY 2023 on Thursday, November 16th, for $41.2 million.  Total funding is now $2.38 billion.  At this point, USAC has funded 96.1% of the originally submitted applications representing 83.0% of the dollars requested. 

ECF for 2021-2023:

For the first time in a while, USAC did not issue a new ECF wave on an alternate Wednesday. Total commitments for all three ECF windows remain at $6.46 billion.

E-Rate for FY 2024:

The EPC administrative window opened on October 24th.  Applicants can now update their entity profiles (including student counts and NSLP percentages) in advance of the FY 2024 application window.  USAC will close the administrative window shortly before the Form 471 application window opens in mid-January, at which point EPC entity profiles will be locked during the window.

Less than one week after releasing a Notice of Proposed Rulemaking (“NPRM”) to provide E-rate funding for Wi-Fi hotspots and services for students and library patrons without access to internet at home (see our newsletter of November 13th), the FCC released another NPRM (FCC 23-92) announcing a three-year cybersecurity pilot program.  The original concept for an E-rate cybersecurity pilot was first proposed by Funds For Learning last November as a plan to put aside $60 million per year, for three years, in Category 2 funding for advanced firewalls.

What the FCC has proposed is quite different in scope but equivalent in scale.  It is being structured as a true pilot program designed to test and compare different approaches to school and library cybersecurity.  The program will be funded up to $200 million over a three-year period with Universal Service Funds.  Although not directly funded within E-rate, the pilot will apparently utilize many of the E-rate and ECF-like forms and procedures.

Key aspects of the pilot program, to be more fully developed through the upcoming comment process, will apparently include the following:

  • Schools and libraries will apply for pilot program participation by filing a new Form 484.  Conceptually, the Form 484 can be viewed as a grant application for the pilot.  Once accepted into the program, participation will be for the entire three-year period.  Annual re-applications will not be required.  Successful applicants will be required to propose specific cybersecurity test plans, ideally leveraging other federal cyber resources, that can be tested over the three-year period.
  • Equipment and services provided to pilot participants must be procured, approved, and funded in an E-rate manner using new forms that mirror E-rate’s Forms 470, 471, 472, and 474.  Invoicing and appeal deadlines will unfortunately track the shorter ECF schedules.
  • Annual and final progress reports will be required “detailing use of funds and effectiveness of the programs.”

Comments on the NPRM will be due within 30 days after its publication in the Federal Register.  Reply comments will be due another 30 days thereafter.  Based on this schedule, we would not expect to see a final order until at least March of next year perhaps with a 60-day application period opening in the Spring.

Upcoming Dates:

November 20      Nominations are due for a Tribal Board member on the USAC Board of Directors (see DA 23-903).
November 24 The Form 486 deadline for FY 2023 Wave 14.  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 15               12/01/2023
Wave 16               12/08/2023
Wave 17               12/15/2023
Wave 18               12/22/2023
Wave 19               12/29/2023
November 30 Due date for additional comments on the proposed Eligible Services List (“ESL”) (DA 23-1011) for FY 2024 regarding the eligibility of Wi-Fi on school buses.  There is no provision for additional reply comments.