E-Rate News Flash 21-05

E-Rate
  Thursday, May 6, 2021

Issue 21-05

May 6, 2021

E-rate News Flash

Contents:

Announcements

USAC Issues First Funding Waves for Funding Year 2021

The Universal Service Administrative Company (USAC) issued its first funding wave for applications approved for the 2021 funding year on April 17, 2021. Since that date, USAC has issued a total of three waves, for a total commitment of $80.8 million for California’s schools and libraries. For 2021 thus far, 31.5% of Category 1 and 5.5% of Category 2 funds requested have been committed. USAC typically issues funding waves on a weekly basis on Thursday evenings and posts details of the commitments on its website, which is searchable by wave number and state: https://data.usac.org/publicreports/SearchCommitments/Search/SearchByYear/2021.

Participate in Annual National E-rate Survey

An annual survey is being conducted which asks schools and libraries to contribute their opinions on and experiences with the E-rate application process. The survey results will be tabulated and shared with Congress, the Federal Communications Commission (FCC) and the public this summer. The survey is available at this link and is available through May 15, 2021: https://www.surveymonkey.com/r/2021erate.

E-rate applicants are encouraged to complete the survey to share their thoughts and experiences; all responses are confidential.

FCC Releases Draft Rules for Emergency Connectivity Fund Program

In March 2021, Congress passed The American Rescue Plan Act which appropriated $7.17 billion to create an Emergency Connectivity Fund (ECF) to be administered by the Federal Communications Commission (FCC) and provide funding to support off-campus broadband connectivity and devices for schools and libraries during the COVID-19 pandemic. On Friday, April 30, the FCC released draft rules for the ECF program which may be viewed at https://www.fcc.gov/document/rosenworcel-unveils-proposed-rules-emergency-connectivity-fund. It is anticipated that the FCC will issue final rules for the ECF program on May 10, 2021. Expect more information in future editions of the News Flash. K12HSN will hold an informational webinar on the ECF on May 27, 2021. You may sign up for the webinar at this website: https://www.k12hsn.org/resources/erate/training.

FCC Holds Emergency Broadband Benefit Webinar and Releases Toolkit for Community Outreach Providers

As mentioned in our previous News Flash, the Emergency Broadband Benefit (EBB) Program is a subsidy program to assist low-income households with paying for broadband service during the COVID-19 pandemic. EBB will provide a discount of up to $50 per month towards broadband service for eligible low-income households and up to $75 per month for households on Tribal lands. Eligible households can also receive a one-time discount of up to $100 to purchase a laptop, desktop computer, or tablet from participating providers if they contribute $10-$50 toward the purchase price. On April 27, 2021, the FCC held a webinar to provide community outreach partners with information and resources to help inform low-income consumers of the availability of the benefit and where to sign up. The recorded webinar may be viewed at the FCC’s EBB website: https://www.fcc.gov/broadbandbenefit. The FCC has also made available a toolkit for community outreach partners at this website:  https://www.fcc.gov/emergency-broadband-benefit-outreach-toolkit. As explained in the webinar, consumers may sign up for the benefit through their participating broadband provider or may sign up directly at this website:  https://www.getemergencybroadband.org/. The webinar provided an overview of the application screens and the necessary documentation for consumers to provide in order to qualify. The FCC expects to launch the program on May 12, 2021.

California Funding Commitment Summary

Funding Year 2021

For Funding Year 2021, California applicants have successfully submitted 5,573 funding requests for $374 million. California applicants requested $230 million for Category 1 services and $144 million for Category 2 services.

Funding Year 2020

As of May 3, 2021, California applicants have successfully submitted 9,082 funding requests for $371 million. To date, USAC has committed $314 million for California applicants.

Pace of Commitments

The overall pace of commitments in terms of funding committed versus requested for California applicants in FY 2020 is comparable same period in the previous year.

 

 

FY 2020 Status  as of 05/03/2021

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved

Requests

% of Requested

Funding Approved

% of Requested

C1

4,164

$234.1 M

3,857

93%

$212.0 M

91%

C2

4,918

$137.4 M

4,282

87%

$102.8 M

75%

Total

9,082

$371.5 M

8,139

90%

$314.8 M

85%

 

 

 

Versus FY 2019 as of 05/03/2020

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved Requests

% of Requested

Funding Approved

% of Requested

C1

3,811

$246.1 M

3,563

93%

$222.7 M

90%

C2

4,385

$112.2 M

3,628

83%

$78.4 M

70%

Total

8,196

$358.3 M

7,191

88%

$301.1 M

84%

 

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.

Final Extended Invoice Deadline for Funding Year 2019 Recurring Services

Due to COVID-19, the FCC automatically extended the deadline for invoicing for FY 2019 recurring services to February 25, 2021.  Applicants and service providers that then requested and were approved for an additional single one-time 120-day extension now have a final invoice deadline of June 25, 2021. Any additional invoices filed after June 25, 2021, will not be accepted by USAC and will require an approved waiver from the FCC of the invoice deadline extension rule. Note that the FCC will only issue waivers of the invoice deadline for extraordinary circumstances.

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 2020

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.

Waves #

FCDL
Date

Form 486 Due Date

 
 

1-36

05/09/2020-12/31/2020

Deadline passed for services starting July 1, 2020

 

37

01/07/2021

05/07/2021

 

38

01/14/2021

05/14/2021

 

39

01/21/2021

05/21/2021

 

40

01/28/2021

05/28/2021

 

41

02/04/2021

06/04/2021

 

42

02/11/2021

06/11/2021

 

43

02/18/2021

06/18/2021

 

44

02/25/2021

06/25/2021

 

45

3/4/2021

07/02/2021

 

46

03/11/2021

07/09/2021

 

47

03/18/2021

07/16/2021

 

Funding Year 2019

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

 
 

1-79

04/27/2019-
12/16/2020

Deadline passed for services starting 07/01/2019

 

86

04/07/2021

08/05/2021

 

87

0428/2021

08/31/2021

 

 

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 applicants are available or are coming soon.

Universal Services Administrative Company Recorded Resources

USAC has pre-recorded webinars and other materials available at its website at https://www.usac.org/e-rate/learn/.

State Educational Technology Directors Association Ask the State Experts E-rate Training Series

The State Educational Technology Directors Association (SETDA), a non-profit membership association that supports U.S. state and territorial leaders in advancing education through effective digital learning policy and practice, has announced a new E-rate training series “Ask the State Experts.” These virtual trainings are designed to support the applications and implementation of the E-rate program for school, district, and library leaders, and will further support the processes, rules, and strategies for applicants to be successful in maximizing the available reimbursements for Funding Year 2021. Please visit this website for more information on the series: https://www.setda.org/events/webinars/eratetraining/.

K12 High Speed Network E-rate Resources

Spring Webinar Series

K12HSN is currently hosting complimentary “E-rate Lunch and Learn” noon-hour webinars which focus on the E-rate process after the filing of FCC Form 471 as well as on the new Emergency Connectivity Fund. These webinars will include tips and best practices geared specifically to California schools. Registration may be completed at the following link: https://www.k12hsn.org/resources/erate/training.

  • Submitting Corrections & Understanding and Responding to USAC's Reviews | April 15
  • Category 1 SPIN Changes & Service Substitutions | April 22
  • Category 2 SPIN Changes & Service Substitutions | May 13
  • The New E-rate Emergency Connectivity Fund: What You Need to Know | May 27
  • Funding Commitment, FCC Form 486, and Children's Internet Protection Act | June 3
  • Preparing for E-rate Audits and Understanding Audit Process | June 10
  • The New E-rate Emergency Connectivity Fund: Preparing for the Application Process | June 17
  • Category 1 E-rate Invoicing Best Practices June 24

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

PIA Review: Modification Notifications, Denial Notifications, and Incomplete Response Notifications

Generally, USAC will issue notifications to applicants if it intends to reduce or deny FCC Form 471 funding requests. The FCC Form 471 contact will receive outreach from a PIA reviewer with a notification of the reduction or denial and a link to the E-rate Productivity Center (EPC) where additional information may be available on the reason(s) for reduction or denial. It is very important to review and respond to these inquiries immediately because they do not allow for the typical 15-day response window experienced in PIA review. If USAC does not receive an immediate response, USAC can make the stated reductions or denials by issuing a Funding Commitment Decision Letter (FCDL) in the next the FCC Form 471 weekly funding wave. It is important that applicants carefully review USAC’s notifications and provide additional information, documentation, and/or a rebuttal to USAC’s initial decision before the FCDL is issued. USAC may also issue an Incomplete Response notification if an applicant has not fully responded to USAC’s questions or if the reviewer does not understand the information submitted. This provides applicants an additional opportunity to provide information; a lack of response can lead to funding denial.

Applicants have reported that EPC will not allow them to upload responses to modification or denial notifications. Applicants experiencing this issue are advised to e-mail the PIA reviewer directly outside of EPC with the information needed and to also create a customer service case to document the EPC issue which prohibited the applicant from being able to submit its response in EPC. Applicants are also encouraged to proactively e-mail and call their PIA reviewers in any instance where they are unsure of what USAC is requesting or to help the reviewers understand information submitted.

Applicants who were unable to respond to USAC’s reduction or denial notifications, or whose rebuttals were not accepted by the USAC reviewer will receive USAC’s decision in the FCDL.

Review Your 2021 Funding Commitment Decision Letter

The purpose of the Funding Commitment Decision Letter (FCDL) is to notify applicants and service providers which funding requests were approved, denied, or cancelled and how much funding was committed. The FCDL notification will arrive via email to the FCC Form 471 contact person, form certifier, and the general contact for the service provider. The email notification will include a PDF summary and a CSV file supporting the commitments and/or changes made by USAC during the review process. Additionally, the FCDL is accessible in the applicant’s “News” header in the E-rate Productivity Center (EPC) and viewable by any user in the organization with viewing rights. FCDLs are issued by individual FCC Form 471.

Applicants are encouraged to review the FCDL as soon as they are issued. If an applicant does not agree with a commitment, denial, cancellation, and/or change that USAC has made to the application or any funding request, the applicant has 60 days from the date of the FCDL to file an appeal with USAC. Instructions on how to file an appeal are located at this website: https://www.usac.org/about/appeals-audits/appeals/.

When reviewing FCDLs, applicants should verify the application comments, committed amounts, monthly recurring and one-time costs, discount percentage, service provider information, and total number of funding requests. The PDF and CSV files provide summary information. If applicants are looking to verify corrections or changes to more detailed information such as: contract records, individual site enrollments, parent/child relationships, line item details and unit costs, quantities or recipient of services (ROS), the applicant will need to log in to EPC.

In EPC, the applicant may access individual modules from the main landing page by navigating to the “FCC Forms” section. From there, select “FCC Form 471” as the Category and “2021” as the Funding Year. A list of FCC Forms 471 will load for the applicant. Using the hyperlinks to individual FCC Forms 471, the applicant can navigate and view: Summary, Funding Requests, Discount Calculations, or Entity Information. Funding Request Number (FRN) line item details can be accessed by using the individual FRN hyperlinks and selecting each line item to view details.

Currently, under the Summary view for individual FCC Form 471, applicants may scroll to the bottom of the section to view “FCC Form 471 Generated Documents.” The “Original Version” of the FCC Form 471 can be downloaded in PDF form by selecting the hyperlink. USAC system updates will soon include a full PDF version of the “Committed Version” of the FCC Form 471 to help simplify and avoid having to view individual module information via multiple screens in EPC.

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. After September

Extension for USAC review deadlines: The FCC has directed 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 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. You may read a copy of the extension order at the FCC’s website https://docs.fcc.gov/public/attachments/DA-20-1021A1.pdf.

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.

Waiver of E-rate Gift Rules

As mentioned in our previous News Flash, the FCC announced that it is temporarily waiving the E-rate gift rules through September 30, 2020. Due to the necessity for schools to acquire goods and services to meet increased broadband demand or to support connectivity to students at home while schools are closed, the FCC is waiving E-rate program gift rules to enable service providers to offer, and E-rate eligible schools to solicit or accept, broadband connections, devices, networking equipment, or other things of value that could help students and teachers affected by school closures during the coronavirus pandemic.

Extensions: The FCC extended the gift rules waiver twice. The first extension was to December 31, 2020, and the second to June 30, 2021. 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.

You may read the entire order at the FCC’s website https://www.fcc.gov/document/fcc-acts-support-telehealth-remote-learning-during-coronavirus. You may read a copy of the extension orders at the FCC’s website https://docs.fcc.gov/public/attachments/DA-20-1021A1.pdf and https://docs.fcc.gov/public/attachments/DA-20-1479A1.pdf.