E-Rate News Flash 20-14

E-Rate
  Tuesday, September 8, 2020

Issue 20-14

September 8, 2020

E-rate News Flash

Contents:

Announcements

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 other California Local Educational Agencies (LEAs) in 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 ajones@icoe.org.

Extension of Waiver of E-rate Gift Rules and Extension of Certain E-rate Information Requests

On Thursday, September 3, 2020, the Federal Communications Commission (FCC) announced the extension of its waiver of the E-rate gift rules due to COVID-19 from September 30, 2020 to December 31, 2020. As a reminder, this waiver is limited strictly to the offering and acceptance of broadband connections, devices, networking equipment, or other things of value that could help students and teachers affected by school closures during the coronavirus pandemic. Schools are expected to continue to follow the FCC’s competitive bidding requirements for the 2021/22 funding year and to not allow the acceptance of gifts to compromise their adherence to the rules of the E-rate program.

The FCC also directs the Universal Service Administrative Company (USAC) to grant 30-day extensions to the deadlines associated with USAC’s review of and outreach pertaining to the following forms and requests: FCC Form 471 Program Integrity Assurance (PIA), USAC appeals, invoices, FCC Form 500 requests, service substitutions, Service Provider Identification Number (SPIN) changes, funding request cancellation requests, and program audits issued between September 11, 2020 through December 31, 2020. The 30-day extensions must be requested by the applicant with an explanation of their inability to respond due to school closures, lack of resources or other challenges due to COVID-19.

You may read the entire order at the FCC’s website at https://docs.fcc.gov/public/attachments/DA-20-1021A1.pdf.

Summer Deferral for Program Integrity Assurance Review Ends Soon

During the summer contact period, Program Integrity Assurance (PIA) may have placed your application on hold if a PIA reviewer was unable to make a live contact by telephone with the contact person or someone else who has been designated to respond to their questions. The summer deferral period began on May 22, 2020 and will end on the Friday after the Labor Day Weekend. Starting Monday, September 14, 2020, application reviews placed on hold will be reactivated and USAC will perform additional outreach. If your organization requires additional time to respond due to COVID-19, please request a 30-day extension and explanation of the inability to respond.

California Funding Commitment Summary

Funding Year 2020

As of August 31, 2020, California applicants have successfully submitted 8,863 funding requests for $363 million. To date, USAC has committed $185 million for California applicants. In its July 2020 Board meeting, USAC indicated that due to the extension of the FY 2020 FCC Form 471 filing deadline its target for processing all workable applications has been pushed from September 1, 2020 to October 1, 2020.

Pace of Commitments

The overall pace of commitments in terms of funding committed versus requested for California applicants in FY 2020 lags slightly versus same period in the previous year, primarily due to the slower processing of Category 2 (C2) applications. The pace of commitments for Category 1 (C1) applications exceeds that of the previous year.

 

 

FY 2020 Status  as of 8/31/2020

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved

Requests

% of Requested

Funding Approved

% of Requested

C1

3,966

$225.6 M

2,908

73%

$158.7 M

70%

C2

4,896

$137.4 M

1,517

31%

$25.9 M

19%

Total

8,862

$363.0 M

4,425

50%

$184.6 M

51%

 

 

 

Versus FY 2019 as of 8/31/2019

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved Requests

% of Requested

Funding Approved

% of Requested

C1

3,802

$246.1 M

2,982

78%

$152.9 M

62%

C2

4,385

$112.2 M

2,213

50%

$37.7 M

34%

Total

8,187

$358.3 M

5,195

63%

$190.6 M

53%

 

Pending Dates and Deadlines

E-rate deadlines may be viewed or calculated on the Universal Service Administrative Company (USAC) website at https://www.usac.org/sl/tools/deadlines/default.aspx.

Funding Year 2018 Non-Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing USAC for FY 2018 non-recurring services was January 28, 2020.  Applicants and service providers that requested and were approved for the single one-time 120-day extension now have an invoice deadline of May 27, 2020. Per the Novel Coronavirus Disease 2019 (COVID-19) Order, the FCC has now granted an additional 120-day extension to September 24, 2020. We encourage applicants, if they are able, to continue to try and meet invoice deadlines so as to not delay receipt of E-rate funding.

Requesting an Additional 30-Day Invoice Deadline Extension

If applicants or service providers are unable to meet the extended invoice deadlines granted by the COVID-19 Order, they may request an additional 30 days in which to invoice. Instructions for requesting this 30-day extension may be found in USAC’s June 26 News Brief: https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=959.

FCC Form 486 Filing Reminder

The FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form) notifies 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 2019

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. For ongoing recurring services, starting on July 1, 2019, the following deadlines have passed or are approaching in the next two months.

Waves #

FCDL
Date

Form 486 Due Date

Extended COVID-19 Due Date*

 
 

1-40

04/27/2019-
12/05/2019

Deadline passed for services starting 07/01/2019

N/A

 

41

1/9/2020

5/8/2020

9/5/2020

 

42

1/16/2020

5/15/2020

9/12/2020

 

43

1/23/2020

5/22/2020

9/19/2020

 

* For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

Funding Year 2018

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. For ongoing recurring services, starting on July 1, 2018, the following deadlines have passed or are approaching in the next two months.

Waves #

FCDL
Date

Form 486 Due Date

Extended COVID-19 Due Date*

 
 

1-73

04/20/2018-
12/09/2019

Deadline passed for services starting 07/01/2018

N/A

 

74-77

No California approvals

 

78

1/13/2020

5/12/2020

9/9/2020

 

* For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

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.

E-rate Training Resources

Applicants may access multiple recordings and other supporting material at the following websites.

USAC Webinars

Recordings of previous webinars registration for upcoming webinars are posted on the USAC website at https://www.usac.org/e-rate/learn/webinars/.

USAC Fall Trainings

In its July 2020 Schools and Libraries Committee board meeting, USAC announced that it would not conduct any face-to-face training events this Fall as is typically the case. USAC indicated that Fall training events would be replaced by live virtual training events, topic-focused office hour webinars, and E-learning modules and videos. More information will be included in the News Flash as the details become available.

K12 High Speed Network E-rate Resources

K12HSN Webinars

BIIG Webinar: What to Do Now that You Are Funded: Filing Form 486 and Coordinating Discounts with Service Providers

Wednesday, September 16 from 10:00-11:00 am

Tuesday, September 22 from 2:00 - 3:00 pm

Registration Link: https://www.k12hsn.org/biig-supersedure-support

 

Visit the K12 High Speed Network (K12HSN) website https://www.k12hsn.org/resources/erate/training to access the E-Rate Training Roadmap and Resource Guide and supplemental training materials including recordings of previous webinars.

K12HSN E-rate Support Survey

The K12HSN E-rate support team would like your feedback regarding the E-rate training tools and resources made available on the K12HSN website. The survey will help determine priorities for outreach and training opportunities for the FY 2021 E-rate cycle. You may access the survey here: https://www.surveymonkey.com/r/GTZWHLV.

E-rate Process: Activities to Work on Now

Requesting a Personal Identification Number for the FCC Form 472 Billed Entity Applicant Reimbursement Form (BEAR)

The FCC Form 472 BEAR can only be filed online through USAC’s legacy online system. In order to submit the BEAR, the person completing the form must obtain a Personal Identification Number (PIN).  A PIN is requested by creating a Customer Service Case through EPC or contacting USAC’s Client Service Bureau (CSB) at (888) 203-8100 and submitting a completed PIN Request Template spreadsheet which may be accessed by clicking on this link: https://www.usac.org/wp-content/uploads/e-rate/documents/PIN-request-template.xlsx.

USAC will send an email with the assigned Case Number to the EPC user that submitted the Customer Service Case which will contain a link to the Customer Service Case in EPC.  Once the PIN has been created, a USAC Notification will be issued indicating that the Case Number has been modified.  USAC will notify you that a PIN has been created and will be emailed to you within in a certain timeframe.  As always, it’s best to be proactive by periodically checking on the status of your Customer Service Cases in EPC. 

Review Existing Contracts to Verify Terms and Allowable Contract Extensions

Even though Funding Year 2021 may seem far away, now is the time to review contracts for services to determine if an E-rate compliant competitive bidding process will be required for funding requests to be filed for 2021. Note that the FY 2021 FCC Form 470, the required form associated with competitive bidding, became available on USAC’s website on July 1, 2020. Best practices are to review existing contracts and create a competitive bidding timeline that will allow for enough time to meet the minimum bidding window of 28 days, take new contracts to your governing board for approval, execute legally binding agreements, and allow adequate time to prepare your FCC Form 471 funding requests. It is expected that the FCC Form 471 E-rate filing window for Funding Year 2021 will open in January 2021 and close in mid-March, so plan accordingly. Creating a reasonable timeline for these activities, with a fall-back plan if issues arise during the competitive bidding and contracting processes, will better enable a smooth E-rate application cycle.

Multi-Year Contracts or Contracts with Voluntary Extensions

A contract that includes voluntary extensions is a contract that expires at the end of its original term, but may be voluntarily extended for one or more years pursuant to the provisions in the contract and original procurement process. The decision to extend a contract with voluntary extensions must occur before the FCC Form 471 is filed for the funding year when the contract would otherwise expire. Contracts for Funding Year 2021 must be valid at a minimum through June 30, 2022 for recurring services and September 30, 2022 for non-recurring services such as Category 2 internal connections. If you do not have allowable extensions through these end dates, you must post a new FCC Form 470 and re-bid your services for either a partial or full year of service depending on the contract end date.

Summary of Federal Communications Commission’s E-rate Response to COVID-19

This section of the News Flash summarizes actions taken by the FCC in the E-rate program in response to COVID-19.

Waiver of Various E-rate Filing Deadlines

In recognition of the unprecedented impact on schools due to the COVID-19 pandemic, the FCC has waived and extended multiple E-rate deadlines as described below.

(1) Service delivery deadline for non-recurring: Any funding requests for non-recurring services with a September 30, 2020 deadline will receive an automatic extension to September 30, 2021. This primarily impacts the installation deadline for Category 2 Internal Connections and installation of Category 1 broadband services.

(2) Installation deadline of Category 1 special construction: The FCC requires that service is delivered and lit by June 30 of the funding year for funding requests that include one-time special construction of Category 1 broadband services, allowing for a single one-time, one-year extension request. The FCC has automatically extended the deadline for any special construction funding requests with a June 30, 2020 deadline to June 30, 2021.

(3) Appeal deadline: FCC rules require parties seeking review or waiver of a decision by the Universal Service Administrative Company (USAC), either directed to USAC or the FCC, to submit their requests within 60 days from the date of the decision. This deadline has been extended to 120 days. This waiver will be in effect for parties seeking review or waiver of an adverse USAC decision with an appeal deadline between March 11, 2020 and September 30, 2020.

(4) Invoice filing deadline: The FCC will provide all applicants and service providers with an automatic 120-day extension of the invoice filing deadline for any funding request with an invoice deadline between March 11, 2020, and October 28, 2020.

(5) FCC Form 486 deadline: The FCC Form 486 deadline is 120 days from USAC’s issuance of the Funding Commitment Decision Letter, or 120 days from the start of service, whichever is later. For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directs USAC to provide these applicants with an additional 120 days to submit these forms without penalty.

(6) USAC review deadlines: The FCC also directs USAC to grant automatic 30-day extensions to the deadlines associated with USAC’s review of and outreach pertaining to the following forms and requests: FCC Form 471 Program Integrity Assurance (PIA), USAC appeals, invoices, FCC Form 500 requests, service substitutions, Service Provider Identification Number (SPIN) changes, funding request cancellation requests, and program audits.

You may read the entire order addressing these extensions at the FCC’s website, https://www.fcc.gov/document/fcc-extends-key-e-rate-program-deadlines-due-covid-19-pandemic-0 and the Erratum further clarifying the deadlines at this website https://www.fcc.gov/ecfs/filing/041385109239.

Reminder to Schools that the Community May Access On-Campus WiFi When Schools are Closed

In 2010, the FCC lifted restrictions to enable for community use of E-rate funded broadband services on a school’s campus while school is not in session. On March 23, 2020, the FCC reiterated that allowing for community access of WiFi on a school’s campus while schools are closed due to the COVID-19 pandemic is allowed under current program rules. However, the FCC declined to address allowing for the expansion of a school’s WiFi network beyond the school’s property line which is currently disallowed by E-rate program rules. You may read the entire public notice at the FCC’s website, https://www.fcc.gov/document/community-use-e-rate-supported-wi-fi-permitted-during-closures.