News of the Week

E-Rate for FY 2023:

USAC issued Wave 40 for FY 2023 on Thursday, January 25th, for $11.2 million.  Total funding is now $2.56 billion.  At this point, USAC has funded 97.4% of the originally submitted applications representing 91.1% of the dollars requested.

ECF for 2021-2023:

Total commitments for all three ECF windows are $6.45 billion.

E-Rate for FY 2024:

The Form 471 filing window for FY 2024 opened January 17th and will close on Wednesday, March 27th, at 11:59 p.m. EDT.  We are already seeing some applications being marked as "Wave Ready" with a strong probability of being included in the first funding wave expected in late April.

Field descriptions of the forms that USAC will use for the FCC's proposed cybersecurity pilot program (see FCC 23-92 and our newsletter of  November 20th) are posted on the OMB website for review.  In large part, the pilot program will use near-identical versions of familiar E-rate forms.  A new and important form, however, to be used to apply for entry into the pilot program itself, will be the "Schools and Libraries Cybersecurity Pilot Program Application (FCC Form 484)."  Field descriptions for the draft Form 484 are available for download on the OMB site.

The Form 484 will begin and end with familiar fields for entity information and certifications.  Most interesting, for those applicants planning to apply for the pilot, are the 38 following "Project Information" fields:
                 

By all indications, applying for entry into the cybersecurity pilot program will not be a trivial exercise.  The Form 484 questions indicate that USAC and the FCC will be seeking applicants with a pre-determined plan to conduct a rigorous cybersecurity exercise leading to measurable outcomes.

Upcoming Dates:

USAC's E-Rate News Brief dated January 25, 2024, provides tips related to the now open FY 2024 application window including the two important areas discussed below.

School Bus Wi-Fi Filing Instructions:

USAC suggests the following steps when filing a Form 471 for school bus Wi-Fi:

• Submit a separate FCC Form 471 for Wireless School Bus Services.
• Submit a separate funding request number (FRN) for each contract or vendor for these services.
• Use "School Bus Wi-Fi" or similar name as the FCC Form 471 nickname.
• List all schools as recipients of service that will be served by the buses.
• At the FRN level:
  • Include "School Bus Wi-Fi" again in the FRN nickname.
  • In the FRN Narrative, include "Applicant seeks support for wireless school bus service, and, if applicable, associated equipment to make the service functional" along with make and model information, the number of buses serviced.
  • For FRN Purpose, select "Internet access service that includes a connection from any applicant site directly to the Internet Service Provider."
  • In the Function text box, enter "Wireless School Bus Service."
  • For Type of Connection, enter "Wireless data service," "Equipment," "Installation," etc., as applicable.  Note that the "Wireless data service," when used will ask you to enter "Number of Buses Being Serviced."

Treatment of New 25% CEP Threshold:

Last October, the U.S. Department of Agriculture ("USDA") finalized new rules reducing the school eligibility threshold for participation in the Community Eligibility Provision ("CEP") program from an Identified Student Percentage ("ISP") of 40% to 25%.  (See our newsletter of October 2nd).  Although the new threshold was to apply for CEP applications for the 2024-2025 school year, USDA accepted and approved waivers for use in the second half of this year.  For E-rate purposes, this will mean that new CEP schools will be able to use an NSLP percentage calculated as 1.6 times their new lower ISP percentage.

EPC, however, does not yet accept any ISP percentage below the original 40%.  Applicants trying to enter a lower percentage during the administrative window could not do so.  Thus FY 2024 Form 471s being submitted for these applicants now will have to use current EPC discount rates.

Last week's News Brief explains this problem and advises: "If you want to report a CEP percentage less than 40%, you must enter your regular NSLP numbers (without CEP multiplier calculations) and use the FCC Form 471 narrative field to communicate your request for the PIA reviewer to enter the proper CEP percentage."