The FCC issued a Public Notice (DA 24-887) announcing the opening of the Form 484 Part 1 application window for those schools and libraries interested in participating in the Cybersecurity Pilot Program (FCC 24-63). The Form 484 Part 1 window is scheduled to open September 17th and close November 1st, 2024.
As discussed in our newsletter of August 26, the Form 484 Part 1 will serve as an initial screening mechanism for participation in the Pilot. We expect that only a subset of the applicants submitting this first form will be selected by the FCC to participate in the Pilot itself. Those selected will then be able to file the remaining forms: (a) the Form 470 to initiate competitive bidding for Pilot equipment and services; (b) the Form 484 Part 2 to provide more detailed information on Pilot plans; and (c), the Form 471 to apply for actual Pilot funding.
The FCC’s announcement clarifies the next steps in the Pilot funding process for those Form 484 Part 1 applicants who are then selected to participate in the Pilot itself. The announcement states:
Selected participants in the Pilot Program will be required to provide more detailed cybersecurity information in Part 2 of the FCC Form 484, which may be submitted at the same time the Cybersecurity Pilot Program FCC Form 471 is filed in an upcoming FCC Form 471 application filing window.
A footnote to this statement further explains that:
Additional information will be made available in the future about how to complete Part 2 of the FCC Form 484 application, as well as the processes for conducting competitive bidding, seeking reimbursement for eligible cybersecurity services and equipment, complying with the Pilot’s periodic reporting requirements, and other processes.
We are now in the position to understand the basic sequence, and perhaps the rough timing, of the next steps in the Cybersecurity Pilot Program as they will apply to the selected participants. An optimistic schedule might be:
- The FCC will need to review all the Form 484 Part 1 applications to select those participants who will be approved to participate in the pilot itself. This could take at least two months. The FCC will then release a Public Notice announcing the chosen Pilot participants, possibly before the end of 2024.
- Selected Pilot participants will then — perhaps beginning in January 2025 — begin the competitive bidding process by filing the Pilot versions of a Form 470 to seek bids on eligible Pilot equipment and services. (Note: Eligible services are listed in Appendix B of FCC 24-63.)
- We assume that the Form 470 window would have to be open for at least two months before the FCC would open the actual Pilot application window. Within the application window, Pilot participants would be filing both the Pilot version of the Form 471 and, as indicated above, the Form 484 Part 2. At best, we would expect the Pilot application window to close in the May-June time frame, roughly 2-3 months after the close of the FY 2025 E‑rate window in March.
- Estimating when we might expect the first Pilot Funding Commitment Decision Letters (“FCDLs”) is difficult. If the previous steps and timing outline above occur, Pilot FCDLs could begin flowing in July. Note, however, that:
- The Cybersecurity Pilot Program is not tied to any particular funding year (as is the E-rate program).
- The review of Pilot applications will involve consideration of two forms per applicant, the Form 471 and the Form 484 Part 2.
- Whereas the initial selection of Pilot participants may be tied to initial estimates of required funding, based on Form 484 Part 1 submissions, there is a possibility that total demand based on participant Form 471 filings will exceed the program’s $200 million cap. Should this occur, the FCC may have to initiate a prioritization process that would require at least a preliminary review of all submitted applications before funding commitments could begin.
There remains a lot we do not know about the Cybersecurity Pilot Program. But we do now know that the adventure begins September 17th.