News of the Week

E-Rate for FY 2024:

Wave 19 for FY 2024 was released on Friday, August 30th, for $119 million.  Total funding is now $2.17 billion.  Currently, USAC has funded 92.7% of the originally submitted applications, representing 72.4% of the dollars requested.

As discussed in USAC’s Cybersecurity Pilot Program Newsletter dated August 22, 2024, forms and actions needed to participate in the Pilot will be created and certified, much like E-rate, through an online portal.  Although the FCC has not announced the opening of the initial Pilot application period — expected shortly — USAC has opened the first portion of the “CBR” — standing for “cybersecurity” — portal to permit potential applicants to update their basic information and to set user permissions to create, review, and/or certify Pilot forms.

The newsletter indicates that the new CBR portal already includes basic entity data on all applicants that have been carried over from the E-rate portal.  Prospective Pilot applicants are urged to review and update this information, particularly user permissions, in preparation for the opening of the Form 484 Part 1 application window.

There are three steps involved in adding or modifying user permissions for Pilot application work.

1. From your basic applicant Landing Page, select “Manage Users.”
   
   
2. Select “Manage User Permissions.”
3. From the “Manage User Permissions” page, click the new button for “CBR User Permissions,” then select the appropriate “CBR 484 Permission” for each individual listed.
   
   

It is important to note that E-rate consultant permissions were not automatically carried over into the Pilot section.  Applicants planning to use consultants to help with the Pilot application process will need to proactively add those consultants — limited to three individuals per applicant — as users in their CBR portals.

Upcoming Dates:

ESL Comments for FY 2025:

Last Friday was the deadline for submitting initial comments to the FCC’s proposed Eligible Services List (“ESL”) for FY 2025 (DA 24-743).  As of last weekend, only a few sets of comments had been posted.  Additional comments may be available on the FCC’s Electronic Comment Filing System this week under Proceeding 13-184.

Most interesting is a filing by the State E-Rate Coordinators’ Alliance (“SECA”) that argues for the inclusion of advanced firewalls as being eligible for E-rate discounts in FY 2025. This is a proposal that has been made many times in earlier ESL proceedings, always to be rejected by the FCC. SECA argues that, with the FCC now formally acknowledging the importance of cybersecurity protection in its new Cybersecurity Pilot Program, FY 2025 is the year to carry-over funding for at least advanced firewalls to the broader E-rate program.  SECA’s filing notes that:

• Firewalls are already eligible within E-rate, at least for “basic” (undefined) versions; making advanced firewalls eligible would simply redefine the restriction.
• E-rate funding for advanced firewalls is already covered within existing Category 2 budgets.
• Making advanced firewalls eligible, both within E-rate and the Cybersecurity Pilot, would benefit the majority of E-rate applicants, who will be excluded from the Pilot, and would permit the Pilot participants to devote more of the Pilot’s limited funds to other cybersecurity products and services.

In other comments referencing cybersecurity:

• Los Angeles Unified School District included a paragraph supporting the eligibility of advanced firewalls.
• Funds For Learning and Infoblox supported making standalone Domain Name System (DNS) and Dynamic Host Configuration Protocol (DHCP) functions eligible as Category 2 services in FY 2025.

Reply comments on next year’s ESL are due September 16th.  We urge support of SECA’s position on advanced firewalls.

FCC Seeks USAC Board Nominations:

As it does every year, on a three-year cycle, the FCC has requested nominations for members of the USAC Board of Directors (DA 24-867).  The USAC Board has twenty members made up of USAC’s CEO, Radha Sekar, eighteen others representing the interests of the programs administered by USAC, and one Tribal representative.  The nineteen representatives serve three-year terms, normally with one-third of the slots open for nominations (or renominations) each year.  This year, the FCC is requesting nominations to fill eight slots: six positions for expiring terms; one for an unfilled slot; and one for a recent resignation.

Most importantly for E-rate applicants, two of the positions for which the FCC has requested nominations this year are for two school representatives.  This includes Julie Tritt Schell, the State E-Rate Coordinator for Pennsylvania, currently serving as the Board’s Vice Chair.  Hopefully, she will be renominated for another term.  The other position has been held by Dr. Daniel Domenech who resigned effective December 31, 2024.

The two other current Board representatives important to E-rate applicants are Dr. Joan H Wade, Executive Director of the Association for Educational Service Agencies, and Amber Gregory, Manager of E-rate Services for the Arkansas State Library.

Nominations for the eight USAC Board seats are due October 28th.

USAC’s E-Rate News Brief dated August 28, 2024, announces the availability of the FY 2025 version of the Form 470 on September 19th.  The Form 470 for the next funding year, normally available as of July 1st, had been delayed this year waiting for the FCC’s new hotspot order (FCC 24-76) to be published in the Federal Register.

New to the FY 2025 Form 470 this year are:

• The ability to upload RFPs and other documents to the Form 470 after certification, even if the original Form 470 had no attachment(s).  Note: significant changes to the Form 470 as the result of a new attachment will require an extended Allowable Contract Date.
• An ability to cancel a Form 470.
• Options to request hotspot devices and wireless internet services.
• Enhanced options to request school bus Wi-Fi services and equipment.

Last week’s News Brief also includes:

• References to new competitive bidding resources including a How to File an FCC Form 470 learning module, FAQs, and the following summary graphic.
  
  

• Instructions for requesting Service Delivery Deadline Extensions for FY 2023 non-recurring services (other than special construction).
• Updates on USAC’s Open Data tools.
• 2024 training and outreach.

USAC’s ECF Program Newsletter dated August 29, 2024, includes a reminder that August 29th was the invoice deadline for Window 3 equipment and services.  The ECF newsletter also discusses:

• The Congressional funding rescission cancelling a portion of the funding previously set aside for ECF funding.  This portion of the newsletter includes a series of FAQs (previously provided) on the impact of the rescission.
• Reminders on:
  • Returning ECF funds.
  • ECF invoicing.
  • Payment verification.
  • Program compliance.