E-Rate News Flash 21-10

E-Rate
  Thursday, August 19, 2021

Issue 21-10

August 19, 2021

E-rate News Flash

Contents:

  • Announcements
  • Funding Commitment Summary
  • Pending Dates and Deadlines
  • E-rate and Emergency Connectivity Fund Training Resources
  • E-rate Process: Activities to Work on Now

Announcements

Emergency Connectivity Fund First Window Closes/Next Steps for Applicants

The first application window for the Emergency Connectivity Fund (ECF) closed Friday, August 13, 2021. While nationwide data is not available at this time, California public schools applied for approximately $712 million, a little over 10% of the $7.17 billion in available funds. The Federal Communications Commission (FCC) may announce additional application window(s) to come, if funds are available. The FCC set targets for the Universal Service Administrative Company (USAC) in processing ECF applications; it expects USAC to process 50% by September 12 and 70% by November 21.

Respond to USAC Program Integrity Assurance Review

USAC is rapidly initiating application review. The contact on the ECF Form 471 application will receive outreach via e-mail and will be directed to respond to the reviewers’ questions in the ECF application portal. The timeframe for response is accelerated when compared to traditional E-rate application review, although applicants may request a seven-day extension if more time is needed. If you are unable to respond within the required timeframe, make sure to communicate with the reviewer and ask for more time. Do not ignore the outreach!

USAC may ask you for copies of vendor documentation to support the funding requests. This may be fulfilled through a vendor quote, screen shot from a website (if ordering online), master contract pricing schedule, and/or contract(s). USAC may also ask for clarification on information entered into the “Unmet Needs” section of the application. Complete responses will ensure your application is processed quickly and efficiently.

Verify and Document Unmet Needs Prior to Invoicing

While the FCC clarified that schools could use estimates of “unmet needs” for the purpose of completing their applications, it also has stated that when schools file for reimbursement, they should only request reimbursement for eligible equipment and services provided to students or staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. Schools may perform surveys or ask for signed statements from students, parents, and/or teachers verifying unmet needs for this purpose. As schools re-open for the 2021/2022 school year, a best practice would be to ask for this verification upon re-enrollment or at the time the equipment and/or services are issued to students and teachers.

Track Distribution of Equipment and Services

The FCC also requires that all ECF-funded equipment and services issued to students and teachers be tracked by individual for a minimum of three years, and that these records be retained for a minimum of 10 years. The minimum information to track is outlined below:

Connected Devices and Equipment:

  • Device type (i.e., laptop, tablet, mobile hotspot, modem/router)
  • Equipment make and model
  • Serial number
  • Name(s) of the person(s) to whom the device was provided
  • Dates the device or other piece of equipment was loaned out/returned to the school
  • If applicable, the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged

Services:

  • Type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless)
  • Service plan details, including upload and download speeds, and monthly data cap
  • Name(s) of the person(s) to whom the service was provided
  • For fixed broadband service only, such as cable modem internet, the service address and installation date of service and the service was received

ECF Information Resources

Because ECF is a new program, information and guidance is constantly evolving. It is recommended that all schools participating in the program continue to monitor official guidance from the FCC and USAC.

BEAR Invoicing System Incorporated into USAC’s Portal

In July, USAC migrated the Billed Entity Applicant Reimbursement (BEAR) invoicing system into the general application portal used for access to the E-rate Productivity Center and the Emergency Connectivity Fund program portals. By doing so, USAC has eliminated the necessity of requesting a separate Personal Identification Number (PIN) to file BEAR reimbursement requests. Access to the BEAR system is now established through the general portal by selecting the blue “Sign In’ button on USAC’s home page: https://www.usac.org/. If you plan on filing for reimbursement through the BEAR system for either E-rate or the ECF programs and have not yet established credentials to do so, please review the following information from USAC on setting up your account for appropriate access: https://www.usac.org/e-rate/resources/forms/bear-form-access/

Important Approaching E-rate Program Deadlines

Multiple important deadlines are approaching in the E-rate program as described below.

September 30 Service Delivery Deadline for Non-recurring Services

September 30, 2021 is the service delivery deadline for non-recurring services for Funding Years 2019 and 2020. 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, 2021. Failing to request an extension and installing services after the deadline may result in funding recovery and/or rejection of invoices for any services delivered after September 30.

September 30 Service Substitution Deadline for Non-recurring Services

If your Category 2 project will be completely installed by September 30, 2021, 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 were approved on the E-rate application, it will reject the invoices until a service substitution is completed and approved.

New E-rate Equipment Transfer Rules Effective July 1, 2021

Starting July 1, 2021, schools may transfer Category 2 equipment to other schools within their district at any time and are not limited to the previous three-year rule prohibiting such transfers, regardless of the funding year in which such equipment was purchased. USAC has a webinar that thoroughly explains the former rules and how they have changed. You may view this webinar and associated materials at https://www.usac.org/e-rate/learn/webinars/.

California Funding Commitment Summary

E-rate Funding Year 2021

For Funding Year 2021, California applicants have successfully submitted 5,602 funding requests for $374 million. California applicants requested $231 million for Category 1 services and $143 million for Category 2 services. To date, USAC has committed $208 million for California applicants.

Pace of Commitments

The overall pace of commitments in terms of funding committed versus requested for California applicants in FY 2021 exceeds the same period in the previous year.

 

 

FY 2021 Status  as of 08/18/2021

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved

Requests

% of Requested

Funding Approved

% of Requested

C1

3,726

$231.0 M

2,947

79%

$165.5 M

72%

C2

1,876

$143.7 M

775

41%

$42.7 M

30%

Total

5,602

$374.7 M

3,722

66%

$208.2 M

56%

 

 

 

Versus FY 2020 as of 08/18/2020

 

Requested

Approved

 

Funding Requests

Funding Requested

Approved Requests

% of Requested

Funding Approved

% of Requested

C1

4,177

$234.1 M

2,950

71%

$150.1 M

64%

C2

4,918

$137.4 M

1,342

27%

$19.6 M

14%

Total

9,095

$371.5 M

4,292

47%

$169.7 M

46%

 

E-rate Funding Year 2020

As of August 3, 2021, California applicants have successfully submitted 9,095 funding requests for $371 million. To date, USAC has committed $324 million for California applicants.

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.

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

 
 

1-51

05/09/2020-04/15/2021

Deadline passed for services starting July 1, 2020

 

52

04/21/2021

08/19/2021

 

53

05/05/2021

09/02/2021

 

54

05/12/2021

09/09/2021

 

55

05/19/2021

09/16/2021

 

57

06/02/2021

09/30/2021

 

Funding Year 2019

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

Waves #

FCDL
Date

Form 486 Due Date

 
 

1-86

04/27/2019-
04/07/2021

Deadline passed for services starting 07/01/2019

 

87

04/28/2021

08/31/2021

 

89

06/30/2021

10/28/2021

 

 

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 and Emergency Connectivity Fund applicants are available or are coming soon.

Universal Services Administrative Company Recorded Resources

E-rate Resources

USAC has pre-recorded webinars and other materials available at its website at https://www.usac.org/e-rate/learn/. In July, USAC conducted a new webinar which is now posted on its website:

  • E-rate Equipment Transfers

Emergency Connectivity Fund Resources

USAC has conducted multiple office hour webinars for ECF, and will likely be hosting more. You may view the webinars and register at this website: https://www.emergencyconnectivityfund.org/training/live-sessions/.

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. Please visit this website for more information on the series: https://www.setda.org/events/webinars/eratetraining/.

K12 High Speed Network E-rate Resources

Lunch and Learn 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. Recordings may be viewed at the following links: https://www.k12hsn.org/resources/erate/training and https://www.k12hsn.org/resources/erate/ecf. The Fall training schedule will be posted soon.

E-rate Process: Activities to Work on Now

Collect and Document Bills for FY 2020 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 2020, which ended on June 30, 2021, this deadline is October 28, 2021. 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 creating 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 that is based on the monthly bills for services received during the period of July 1, 2020 to June 30, 2021. By identifying the eligible services on the bills and 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. The process of collecting the bills and calculating the total eligible costs is still necessary for the SPI method in order to confirm that the correct amount of E-rate discounts were 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 enough time for them to make any corrections to the discounts before the invoice deadline has expired.

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 2020 the required documentation retention period for recurring services is through June 30, 2031. Make sure your business department is aware of the 10-year documentation retention period that is necessary for both bills and proof of payments for E-rate funded services, as this period may be longer than that is required for other financial records.