E-Rate News Flash 23-06
September 27, 2023
E-Rate News Flash
- Funding Commitment Summary
- Important Deadlines
- E-Rate and Emergency Connectivity Fund Training Resources
- E-Rate Process: Activities to Work on Now
E-Rate Program Announcements
USAC Announces System Consolidation and Impact on E-Rate Productivity Center Availability
In its September 13 E-Rate Special Edition News Brief the Universal Service Administrative Company (USAC) issued long-awaited for news about its plans to consolidate its invoicing systems into the E-Rate Productivity Center (EPC) platform. USAC will be transitioning these systems between October 30 and November 7, 2023. Once the systems have transitioned, school and school district applicants must file requests for reimbursement using the FCC Form 472 Billed Entity Applicant Reimbursement (BEAR) in EPC.
During the transition period between 8:59 p.m. PT on October 30, 2023 and November 7, 2023, users will be unable to log into EPC or perform any functions in the EPC platform. This includes filing or modifying any FCC Forms 470, 472, 486, 498, and 500. Users will also be unable to file appeals, service substitution requests, SPIN changes, invoice deadline extension requests, or perform any routine activities in EPC. Please plan in advance to work around this outage period. Appeals with deadlines during this outage period may be submitted to USAC via e-mail at Appeals@usac.org. As noted in the News Brief, the last day applicants and service providers can submit invoices in the current legacy systems is October 30, 2023, at 8:59 p.m. PT.
FCC Releases Draft E-Rate Eligible Services List for Funding Year 2024
The Federal Communications Commission (FCC) has issued notice for public comment on the draft E-Rate Eligible Services List (ESL) for Funding Year (FY) 2024. In the notice, the FCC did not propose any significant changes to the ESL. Initial public comments are due October 12, 2023, and reply comments are due October 26, 2023. To submit comments, or view comments submitted by others, visit the FCC’s electronic comment filing system at https://www.fcc.gov/ecfs/. The proceeding numbers for the E-Rate program are 02-6 and 13-184.
Over the summer, FCC Chairwoman Jessica Rosenworcel announced two initiatives that may ultimately impact E-Rate eligible services for schools and school districts. One is the Learning Without Limits initiative, which would provide E-Rate funding for WiFi on school buses and for schools to lend WiFi hotspots to students for use at home. The other initiative, a cybersecurity pilot program would provide $200 million in funding over three years. These two initiatives are currently being circulated at the FCC and ultimately may impact the final Eligible Services List for 2024.
Reminder to Submit Comments on How the E-Rate Program Can be Further Simplified and Improved
In July, the FCC approved a Report and Order and Further Notice of Proposed Rulemaking that offered both immediate relief of some complicated aspects of the E-Rate program and also asked for public comment on ways to further simplify and streamline the program. The questions are extensive; below are some highlights.
- Should there be exemptions to competitive bidding requirements for small applicants and/or small purchases; for example, less than $3,600 per school?
- Should the signed contract requirement be eliminated?
- Can the process be improved for contract transitions so funding loss is minimized?
- Should discounts be established for three or five year intervals?
- Should there be an FCC Form 471 EZ and should the FCC Form 486 be eliminated?
- Should service providers only charge the amount net of anticipated E-Rate discounts at all times if the applicant selects the service provider discount method?
Schools are highly encouraged to submit comments to the FCC on how the E-Rate program can be simplified and improved. Comments are due to the FCC by September 25, 2023 and Reply Comments may be submitted by October 23, 2023. Comments may be filed in the Electronic Comment Filing System under Proceeding Number 02-6 and may be viewed at this link.
Emergency Connectivity Fund Announcements
Final Emergency Connectivity Fund (ECF) Reimbursement Deadline for Most Window 1 and 2 Funding Requests is October 30, 2023
The last date to request reimbursement from USAC on most approved funding requests for equipment and services with a service delivery deadline of June 30, 2023 is October 30, 2023. These requests must be submitted and certified in the ECF portal by the school or the service provider on or before the October 30 deadline. It is important to verify your organization’s ECF deadlines by checking the tools made available by the Universal Service Administrative Company (USAC):
Both tools will allow you to filter to your organization’s funding requests by Billed Entity Number (BEN) or by Applicant Name.
- The CTF Program website
- eCAP website
- General eCAP Help and FAQ
- CTF program Help and FAQ for eCAP
- Participants and applicants can contact CTFHelp@cpuc.ca.gov for additional help or inquiries regarding eCAP
Annual K12HSN/CENIC Letter of Agency Collection
With the support of State Superintendent of Public Instruction, Tony Thurmond, the California K-12 High Speed Network (K12HSN) and Corporation for Education Network Initiatives in California (CENIC) are pleased to invite all California local educational agencies (LEAs), including county offices of education, school districts and charter schools to join the statewide E-Rate consortium led by CENIC. Annually, this consortium pursues E-Rate discount funding for its connections to the California Research and Education Network (CalREN) which provides statewide Internet access for public K-12 schools.
The K-12 participation in CalREN is managed by the K12HSN, with the Imperial County Office of Education serving as the lead agency. There is no fee to join the consortium, and your participation will directly contribute to maximizing the E-Rate subsidies that support the statewide network and thus leveraging the state's investment and benefiting all LEAs. Participation in the CENIC E-rate consortium does not affect your LEA’s ability to independently apply for and obtain E-Rate funding.
To join the CENIC E-Rate Consortium, each LEA must execute the Letter of Agency (LOA). To verify the status of your LEA’s letter of agency, please visit this website https://www.k12hsn.org/resources/erate/loa and select “Find out the status of your School District Letter of Agency here.” If your LEA’s letter of agency is set to expire, please contact Angela Jones to coordinate the processing of the LOA at email@example.com.
California Funding Commitment Summary
Emergency Connectivity Fund
Windows 1 and 2
In the Emergency Connectivity Fund (ECF) first and second application windows, California applicants requested over $923 million in funding. To date, USAC has issued $688 million in commitments for California applicants.
In the Emergency Connectivity Fund (ECF) third application window, California applicants requested $447 million in funding. To date, USAC has issued $29 million in commitments for California applicants. USAC is currently reviewing applications at the 40% priority level.
Funding Year 2023
For Funding Year 2023, California applicants have successfully submitted 5,453 “In Window” funding requests for $394 million. California applicants requested $244 million for Category 1 services and $150 million for Category 2 services. To date, USAC has committed $285 million for California applicants.
E-Rate deadlines may be viewed or calculated on the Universal Service Administrative Company (USAC) website.
September 30- Service Delivery Deadline for Non-Recurring Services
September 30, 2023, is the service delivery deadline for non-recurring services for Funding Year 2022. Non-recurring services typically include Category 2 internal connections and one-time installation costs for Category 1 services. For Category 2 internal connections, service delivery equates to installation of the equipment at the intended location(s), not just receipt of equipment in a warehouse. If you have a Category 2 project and do not anticipate that all equipment will be installed as of September 30, it’s best to request an extension of this deadline by filing an FCC Form 500 in the E-rate Productivity Center (EPC) portal. The deadline to file this form is September 30, 2023. Failing to request an extension and/or installing services after the deadline may result in funding recovery and/or rejection of invoices for any services delivered after September 30. More information on service delivery deadlines may be accessed on USAC’s website.
September 30 Service Substitution Deadline for Non-Recurring Services
If your Category 2 project will be completely installed by September 30, 2023, but there are changes in the equipment received versus what was reported on the E-Rate funding request, it is necessary to file a service substitution request by the September 30 deadline. After September 30 passes, the module in EPC where applicants file these requests will no longer be accessible. Remember that if USAC reviews invoices and finds that products do not match what was approved on the E-rate application, it will reject the invoices until a service substitution is completed and approved. Please review USAC’s website for guidelines on service substitutions.
October 30, 2023, is the Deadline to Invoice USAC for E-Rate Funding Year 2022 Recurring Services, or to Request a 120-day Extension
The deadline for invoicing of Funding Year 2022 recurring services and one-time special construction is October 30, 2023, at 8:59 p.m. PT. This is the last date an applicant may file an FCC Form 472 Billed Entity Applicant Reimbursement (BEAR) form or a service provider may file an FCC Form 474 Service Provider Invoice (SPI) for E-rate reimbursement without an extension.
One-Time Request for Extension
Applicants or service providers may request a single, one-time 120-day extension to file additional claims for reimbursement. However, the Invoice Deadline Extension Request must be submitted to USAC on or before the October 30, 2023 8:59 p.m. PT deadline. Requests received after this deadline cannot be processed by USAC. There is no penalty to file an extension request, and all requests that are filed by the deadline will be granted. If you are in any doubt as to whether or not invoicing is complete on a Funding Request, it is best to file the request for an extension. More information on how to submit extension requests may be found on USAC’s website.
FCC Form 486 Filing Reminder
The FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Formnotifies USAC that the billed entity and/or the eligible entities that it represents is receiving, or has received, service in the relevant funding year from the named service provider(s).
Funding Year 2023
FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (FCDL) or the start date of E-Rate eligible services, whichever is later. The earliest deadline to certify FCC Form 486 for Funding Year 2023 is October 30, 2023 at 8:59 p.m. PT.
Funding Year 2022
FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (FCDL) or the start date of E-Rate eligible services, whichever is later.
Form 486 Due Date
Deadline passed for services starting July 1, 2022
Applicants missing these or earlier deadlines should closely monitor their News Feed in the E-Rate Productivity Center for an FCC Form 486 Urgent Reminder Letter notification. This letter will allow the applicant a 15-day extension to submit an FCC Form 486 without penalty.
Upcoming Training Events
Numerous training opportunities available for E-Rate and Emergency Connectivity Fund applicants are available or are coming soon.
Universal Services Administrative Company Recorded Resources
USAC has pre-recorded webinars and other materials available on its website. Recently held webinars include the following:
- E-Rate Open Data Course 1: Open Data Overview
- E-Rate Open Data Course 2: Creating Reports and Visualizations
- Service Provider Webinar
Filing the FCC Form 470 and Competitive Bidding Webinar
- E-Rate Systems Consolidation Training Overview Webinar, Wednesday, October 4, 2023, 10 a.m. to 11 a.m. PT Register
USAC will be holding additional webinars throughout the Fall. Please subscribe to USAC’s Schools and Libraries News Brief to receive further announcements.
Emergency Connectivity Fund Resources
USAC has conducted multiple office hour webinars for ECF. You may view the webinars and register at this website.
K12 High Speed Network E-Rate Resources
California’s K12 High Speed Network will be offering multiple webinars throughout the E-Rate process specifically tailored to assist California’s school and school district applicants to navigate the process. The Fall Training Schedule will be announced soon! Archived sessions and materials may be viewed at this link.
E-Rate Process: Activities to Work on Now
Collect and Document Bills for FY 2022 Recurring Services
The deadline to invoice USAC for approved funding for recurring services is typically 120 days from the end of the funding year and is applicable to both the Service Provider Invoice (SPI) and Billed Entity Applicant Reimbursement (BEAR) invoicing methods. For FY 2022, which ended on June 30, 2023, this deadline is October 30, 2023. However, schools should get into the practice of reviewing their bills for recurring services both periodically during the funding year and after the close of the funding year to determine if they have received their proper E-Rate discounts and create a plan of action if the anticipated discounts have not been received.
The FCC Form 472 (BEAR) is filed after eligible services have been both received and paid for by the applicant. Determining the E-Rate eligible costs is accomplished by compiling the bills for the approved services on your FCC Form 471 funding request(s). Arriving at the total eligible costs will require a calculation based on the monthly bills for services received from July 1, 2022, to June 30, 2023. By identifying the eligible services on the bills, deducting the costs for any ineligible services, and multiplying by the approved E-Rate discount percentage, you will arrive at the amount to request reimbursements for on the BEAR.
The FCC Form 474 (SPI) is filed by the Service Provider after the eligible discounts have been applied to the applicant’s bills. Collecting the bills and calculating the total eligible costs is still necessary for the SPI method to confirm that the correct amount of E-Rate discounts was applied to the bills. If you have received no discounts on your bills or the discounts received do not appear to be correct, now is the time to contact your service providers to allow them enough time to make any corrections to the discounts before the invoice deadline has expired.
After reconciliation of discounts posted on bills, applicants may compare the discounts or credits received against funds that have been issued by USAC to the service provider by using the E-Rate Invoices and Authorized Disbursements (FCC Forms 472 and 474) Tool and searching by the approved Funding Request Number (FRN). The amount of funds issued by USAC on the FRN is the sum of the amounts listed under the column “Total Approved Invoice Line Amount.” If you identify discrepancies between funds issued by USAC and credits received, contact your service provider for further explanation and remediation. Note that it is important to do this now so the service provider has adequate time to submit further invoices to USAC before the approaching invoice deadlines.
IMPORTANT: Remember to retain all bills and calculations to support your E-Rate discount requests for a minimum of 10 years from the end of the funding year. For FY 2022 the required documentation retention period for recurring services is through June 30, 2033. Ensure your business department is aware of the 10-year documentation retention period necessary for both bills and proof of payments for E-Rate-funded services, as this period may be longer than that required for other financial records.
Review Contracts and Services for Upcoming FCC Form 470 and Competitive Bidding Cycle
For the Funding Year 2024, school and school district applicants should begin reviewing their existing services and contracts to determine the following:
- Is the existing service and contract valid for the duration of the 2024 funding year (July 1, 2024 – June 30, 2025)?
- Does the existing service and contract meet the needs and expected growth anticipated in the 2024 funding year?
If the answer is ‘No’ to any of the questions above, applicants can further research their original procurement processes, establishing FCC Forms 470, and contract language to determine if services and contracts can be extended and/or amended.
The final Funding Year 2024 Eligible Services List is currently pending; however applicants may refer to the Funding Year 2023 Eligible Services List at https://www.usac.org/e-rate/applicant-process/before-you-begin/eligible-services-list/ to determine the services for which they may seek funding and begin a competitive bidding and FCC Form 470 process for Funding Year 2024.
Once you have determined which services must be competitively bid, plan your E-Rate process and timeline. Contracts for service must be awarded before the annual application window closes, typically in mid-March. A best practice is to map out your annual application process and establish key milestones such as Board meetings and competitive bidding dates. Start planning now for your FY 2024 process!