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December 23, 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 2025 – Application Window:

Application Window: The Form 471 application window for FY 2025 is scheduled to open midday on Wednesday, January 15th, and close on Wednesday, March 26, 2025, at 11:59 p.m. EDT.  The administrative window, giving applicants an opportunity to update their EPC entity profiles, will be closed on Thursday, January 9th.

E-Rate for FY 2024:

Wave 35 for FY 2024 was released on Thursday, December 19th, for $27.2 million.  Total funding is now $2.50 billion.  Currently, USAC has funded 97.4% of the originally submitted applications, representing 85.2% of the dollars requested.

Upcoming Dates:

December 30     FY 2024 Form 486 deadline for Wave 19.  The Form 486 deadline is 120 days after the FCDL date, or the service start date (typically July 1st), whichever is later.  The next Form 486 deadlines for FY 2024 are:
Wave 20              01/03/2025
Wave 21              01/10/2025
Wave 22              01/17/2025
Wave 23              01/24/2025
Wave 24              01/31/2025
January 2 FY 2023 Form 486 deadline for Wave 63.  Upcoming Form 486 deadlines for FY 2023 are:
Wave 64              01/30/2025
Wave 65              02/17/2025
January 3 Last day of USAC’s winter deferral period for PIA responses.
January 9 Expected close of the EPC administrative window.
January 15 Opening of the Form 471 application window for FY 2025 (noon EST).
January 20 President Trump’s inauguration will mark a change in control of the Federal Communication Commission (“FCC”).  The current Chairwoman, Jessica Rosenworcel, has announced plans to step down that day.  President-elect Trump has already announced that current Commissioner Brendan Carr will become the new FCC Chairman (see our newsletter of November 11).
January 28 Normal Invoice deadline for FY 2023 non-recurring services.
February 25 Extended invoice deadline for FY 2023 recurring services for deadlines extended beyond the original October 28, 2024, deadline.
March 26 Close of the Form 471 application window for FY 2025 (11:59 p.m. EDT).

New York State’s Affordable Broadband Program:

With the termination of the Affordable Connectivity Program (“ACP”) last June, no serious prospects for renewed ACP funding from Congress, and the limited (and uncertain) nature of E‑Rate for hotspots, the prospects of federal funding for free or low-cost internet for low-income families looks bleak.  A decision last week by the U.S. Supreme Court, however, raises the possibility of low-cost, low-income internet by individual states.

This story starts in 2021 when New York State first attempted to initiate its own Affordable Broadband Program to require the State’s broadband providers to offer qualifying low-income consumers basic internet service plans of either 25 Mbps for $15 per month or 200 Mbps for $20 per month.  ISPs in the State (and their national trade associations) challenged New York’s law, fearing that other states would follow with their own plans if the law was allowed to stand.  They argued, in part, that only the FCC could regulate internet rates.  Last April, a federal court ruled to the contrary and the industry sought Supreme Court review.  Last week, the Supreme Court declined to hear the case thus leaving in place the lower court’s decision that states — or at least New York State — could regulate internet rates.

Barring any action by either Congress to reinitiate ACP funding, or the FCC to assume jurisdiction over internet rates, we are likely to see other states seek legislation supporting free or low-cost pricing on internet services for low-income users.

FCC Names Eight Members to the USAC Board:

FCC Chairwoman Jessica Rosenworcel appointed eight members to new or extended terms on the USAC Board of Directors.  Of most interest to the E-Rate community, the Chairwoman extended the term of Julie Tritt Schell, the State E-Rate Coordinator in Pennsylvania, one year to December 31, 2025, and appointed David Schuler, Executive Director of AASA, the School Superintendents Association, to a new three-year term expiring December 31, 2027.

The most important news in USAC’s E-Rate News Brief dated December 18, 2024, is the announcement of the Form 471 application window for FY 2025.  As noted above, the window will open Wednesday, January 15th, and close on Wednesday, March 26th.  In a subsequent announcement, USAC indicated that the administrative window will close Thursday, January 9th, at which point the entity profile data will be locked for the duration of the application window.

Last week’s News Brief also includes the following FAQs on hot spots:

Q.  Can applicants apply for more wireless Internet access lines than Wi-Fi hotspot devices or must they request an equal number of lines and devices?  What if the applicant already bought Wi-Fi hotspots through other means (e.g., Emergency Connectivity Fund (“ECF”) or other funding sources)?
Short answer: Yes.

Q.  Can an applicant request more Wi-Fi hotspot devices than wireless Internet access lines just in case the devices are lost, stolen, or stop working?
Short answer: No.

Q.  Can applicants request Wi-Fi hotspot devices and pair them with private network services or wireless Internet access purchased via another funding source?
Short answer: No.

Q.  Do we have to purchase all of our Wi-Fi hotspot devices/lines of service at once or can we stagger the purchases based on student or library patron needs?
Short answer: Both are acceptable.

Other topics covered in the latest News Brief include:

  • Notice of an updated FY2021-2025 Category Two (C2) Budget Management Guide.
  • Not surprisingly, USAC’s Customer Service Center (“CSC”) will be closed on December 25th and January 1st.
  • The annual winter deferral period runs from December 20th through January 3rd.
  • There are two important invoice deadlines in early 2025:
    • January 28th for FY 2023 non-recurring services; and
    • February 25th for FY 2023 recurring services for invoices deadlines extended beyond the original October 28, 2024, deadline.