Collapse All

October 7, 2024

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

E-Rate for FY 2024:

Wave 24 for FY 2024 was released on Thursday, October 3rd, for $24.3 million.  Total funding is now $2.27 billion.  Currently, USAC has funded 94.6% of the originally submitted applications, representing 76.1% of the dollars requested.

Upcoming Dates:

October 15 USAC webinar: Cybersecurity Pilot Program Overview for Service Providers (registration).
October 17 Form 486 deadline for FY 2023 Wave 56.  More generally, the Form 486 deadline is 120 days from the FCDL date, or the service start date (typically July 1st), whichever is later.  The next Form 486 deadline for FY 2023 is:
Wave 57              10/28/2024
Wave 58              11/07/2024
Wave 59              11/14/2024
Wave 60              11/21/2024
October 28 Due date for nominations for eight positions on the USAC Board of Directors (see DA 24-867).
October 28 E-rate invoice deadline for FY 2023 recurring services and final date to request an invoice deadline extension.
October 29 Form 486 deadline for FY 2024 Waves 1-10.  More generally, the Form 486 deadline is 120 days from the FCDL date, or the service start date (typically July 1st), whichever is later.  Upcoming Form 486 deadlines for FY 2024 are:
Wave 11              10/31/2024
Wave 12              11/08/2024
Wave 13              11/15/2024
Wave 14              11/22/2024
November 1     Close of the FCC’s Cybersecurity Pilot Program Form 484 Part 1 application window.

FCC Streamlined Decisions:

The FCC issued another set of “streamlined,” precedent-based appeals and waivers last week.  As with past streamlined decisions, applicants facing similar problems to those addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes.  The original appeal and/or waiver requests can be found online in the FCC’s Search for Filings under Docket 02-6 (E-rate) or Docket 21-93 (ECF).

Two of the latest and unusual decisions took USAC to task for its action or lack thereof.  In one case, the FCC criticized a USAC decision rationale as “vague” and remanded it back to USAC with instructions “to provide specific explanations for its decision.”  In the other case, the FCC granted a waiver in a situation where the “applicant error could have been corrected promptly but for USAC inaction.”

In the other September streamlined decisions (DA 24-973), the FCC:

  1. E-Rate Dismissed:
    1. Five Petitions for Reconsideration for failure “to identify any material error, omission, or reason warranting reconsideration”.
    2. One Request for Review to allow an appeal to be filed with USAC.
  2. E-Rate Granted:
    1. Three Requests for Waiver remanding applications to USAC permitting the submission of discount rate information.
    2. Three Requests for Review or Waiver allowing applicants additional time to respond to USAC requests for information.
    3. Four Requests for Review or Waiver allowing applicants additional time to respond to USAC inquiries during invoicing.
    4. One Petition for Reconsideration for a Form 471 filed more than 30 days late due to a serious illness.
    5. One Petition for Reconsideration for an untimely filed appeal due to a serious illness.
    6. One Request for Waiver for a late-filed Form 471 due to a school reorganization.
    7. One Request for Waiver for a late-filed Form 486 “where the applicant demonstrated good cause for the late filing.”
    8. Five Requests for Waiver involving ministerial and/or clerical errors resulting in incorrect or missing Form 471 information.
    9. One Request for Waiver dealing with unutilized equipment remanded to USAC.
    10. Five Requests for Waiver involving USAC decisions released after invoice deadlines.
    11. Seven Requests for Waiver for appeals and waivers filed “only a few days late.”
    12. One Request for Waiver of the special construction service delivery deadline.
  3. E-Rate Denied:
    1. Thirty-six Requests for Waiver for late-filed Form 471 applications where the applicants failed to present special circumstances justifying a waiver.
    2. Sixteen Requests for Review or Waiver for late-filed invoice or invoice deadline extension requests.
    3. Two Requests for Waiver for ministerial and clerical errors.
    4. Two Requests for Waiver for relying on Form 470s that did not seek bids on types of services later requested.
    5. Ten Requests for Review or Waiver for untimely filed appeals or waivers.
  4. ECF Dismissed:
    1. One Request for Waiver and/or Review dismissed as insufficient.
    2. Three Requests for Waiver deemed moot as the entities had been fully compensated.
    3. One Request for Waiver deemed moot because of actions already taken by USAC.
  5. ECF Granted:
    1. Two Requests for Waiver remanded to USAC involving the early delivery of services.
  6. ECF Denied:
    1. Two Requests for Review or Waiver deemed late filed.

FCC and USDE Cybersecurity Resource Guide:

The Federal Communications Commission and the Department of Education, with input from the Cybersecurity and Infrastructure Security Agency, released a resource guide to help schools and libraries evaluate their cybersecurity risks and identify the most impactful cybersecurity solutions. The guide can also help schools and libraries as they complete Form 484 Part 1 applications for the FCC’s Schools and Libraries Cybersecurity Pilot Program.  It also serves broadly as a resource for schools and libraries as they take steps to better protect their networks.