Issue 22-08

August 29, 2022

E-Rate News Flash

Contents:

• Announcements
• Funding Commitment Summary
• Pending Dates and Deadlines
• E-Rate and Emergency Connectivity Fund Training Resources

Announcements

FCC Releases Draft E-Rate Eligible Services List for Funding Year 2023

The Federal Communications Commission (FCC) has issued for public comment the draft E-Rate Eligible Services List (ESL) for Funding Year (FY) 2023. The FCC does not propose any significant changes to the ESL. Initial public comments are due September 21, 2022, and reply comments are due October 6, 2022. The draft ESL may be accessed at this link: https://docs.fcc.gov/public/attachments/DA-22-878A1.pdf. 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.

As noted in our previous News Flash, on May 11, 2022, Chairwoman Jessica Rosenworcel circulated a Declaratory Ruling which, if adopted, would make Wi-Fi on school buses eligible for E-Rate support. If the Declaratory Ruling is adopted, the FCC will separately seek comment on the specific services and equipment needed to provide Wi-Fi on school buses.

Summer Deferral Period Ends for E-Rate Program Integrity Assurance Review

The Universal Service Administrative Company (USAC) is working diligently to keep the E-Rate application review process moving quickly in an effort to fund as many applications as possible prior to September 1, 2022. Applicants that placed their applications on Summer Deferral status should expect PIA review to resume after September 9, 2022.

Affordable Connectivity Program Updates

Starting January 1, 2022, the FCC launched the Affordable Connectivity Program (ACP) as the successor program to the temporary Emergency Broadband Benefit (EBB) Program. ACP provides qualifying low-income households a $30 per month subsidy on broadband service, directly through their Internet service provider. Families with children participating in the National School Lunch Program (NSLP) or who attend Community Eligibility Program (CEP) schools under NSLP qualify for the ACP benefit. In August, the California Department of Education announced the Get Connected! Initiative, encouraging schools to promote the ACP to eligible families as students return to school. Please visit this website to view the announcement and access a toolkit and other resources developed to promote ACP awareness: https://www.cde.ca.gov/nr/el/le/yr22ltr0809.asp.

USAC Starts Annual ACP Recertification Process

Any households that received the EBB program benefits and rolled over directly into the ACP must go through an annual recertification process to establish their continued eligibility to receive benefits. USAC will be performing outreach directly to households with instructions on how to recertify starting in August and through December of 2022. Households may recertify to their eligibility by providing a letter from their children’s schools documenting their eligibility for NSLP or enrollment at a CEP school. Sample eligibility letters are available in the toolkit at this website: https://bit.ly/GetConnectedCAK12. This recertification process will occur annually for the duration of the program.

FCC Announces ACP Outreach Grant Program

At its August open meeting, the FCC announced the adoption of $100 million in outreach grants that will be available to organizations to assist them in promoting the ACP to their communities. Schools and other organizations will be eligible to apply for competitive grants later this year. While the FCC will be releasing the details of the application process this fall, you may review information on the grants at this link: https://www.fcc.gov/document/fcc-establishes-affordable-connectivity-outreach-grant-program-0.

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.

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.

Window 3

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.

E-Rate

Funding Year 2022

For Funding Year 2022, California applicants have successfully submitted 5,348 funding requests for $496 million. California applicants requested $237 million for Category 1 services and $259 million for Category 2 services. To date, USAC has committed $294 million for California applicants.

E-Rate Funding Year 2021

For Funding Year 2021, California applicants have successfully submitted 5,685 funding requests for $375 million. California applicants requested $231 million for Category 1 services and $144 million for Category 2 services. To date, USAC has committed $323 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.

September 30 Service Delivery Deadline for Non-recurring Services

September 30, 2022 is the service delivery deadline for non-recurring services for Funding Year 2021. 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, 2022. 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, 2022, 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.

October 28 Invoice Deadline

The deadline for invoicing of Funding Year 2021 recurring services and one-time special construction is October 28, 2022. 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 28, 2022 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 extension. More information on how to submit extension requests may be found on USAC’s website at https://www.usac.org/e-rate/applicant-process/invoicing/invoice-deadline-extensions/.

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 2022

The first FCC Form 486 deadline for FY 2022 is October 28, 2022 for services starting July 1, 2022.

Funding Year 2021

The first FCC Form 486 deadline for FY 2021 was October 28, 2021 for funding waves 1-11 with services starting July 1, 2021.

Waves #	FCDL Date	Form 486 Due Date
1-52	04/17/2021-4/7/2022	Deadline passed for services starting July 1, 2021
54	5/6/2022	09/03/2022
55	5/18/2022	09/15/2022
56	5/27/2022	09/24/2022
57	6/10/2022	10/08/2022

 

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
1-88	05/09/2020-4/6/2022	Deadline passed for services starting July 1, 2020
92	5/25/2022	09/22/2022
94	6/22/2022	10/20/2022
97	8/3/2022	12/01/2022

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
1-104	04/27/2019- 4/13/2022	Deadline passed for services starting 07/01/2019
107	6/15/2022	10/13/2022

 

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

E-Rate Resources

USAC has pre-recorded webinars and other materials available at its website at  https://www.usac.org/E-Rate/learn/webinars/. Recently held webinars include the following:

• E-Rate Invoicing Process: Office Hour Webinar (July 21, 2022)
• Filing the FCC Form 470 and the Competitive Bidding Process Webinar (August 25, 2022)

Emergency Connectivity Fund Resources

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

K12 High Speed Network E-Rate Resources

Pre-Recorded Webinars Archive

Pre-recorded webinars are available on a wide variety of topics and are available for view at https://www.k12hsn.org/archived-E-Rate-webinars.

E-rate Process: Activities to Work on Now

Collect and Document Bills for FY 2021 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 2021, which ended on June 30, 2022, this deadline is October 28, 2022. 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, 2021 to June 30, 2022. 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 2021 the required documentation retention period for recurring services is through June 30, 2032. 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.