Issue 22-10

December 21, 2022

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

Federal Communications Commission Issues Funding Year 2023 E-Rate Eligible Services List

Recently, the Federal Communications Commission (FCC) released the approved Eligible Services List (ESL) for E-Rate Funding Year (FY) 2023. There were no material changes or additions made to services eligible for E-Rate program funding. The FCC declined to add WiFi on school buses or next generation firewalls, which include features beyond currently-eligible basic firewalls, to the ESL. You may view the FY 2023 and prior lists at this website: https://www.usac.org/e-rate/applicant-process/before-you-begin/eligible-services-list/. With the release of the ESL, USAC can announce the annual FCC Form 471 application filing window and we expect this announcement soon. We also expect that the filing dates will be similar to those in FY 2022.

FCC Seeks Public Comment on Next Generation Firewalls

While declining to add next generation firewalls or other advanced cybersecurity services to the ESL, the FCC did open a comment period asking specific questions centered around making these services eligible for support. The FCC did express its concern that adding these services could increase funding demand and impact constrained E-Rate funding resources. Among other issues, the FCC requests comment on the definition of advanced firewalls and their features, on a limited pilot program dedicating funding for advanced firewall support, and for specifics on how much schools spend on advanced firewalls and cybersecurity measures. The initial comment period is through February 13, 2023, and reply comments may be submitted through March 30, 2023. You may view the FCC’s Public Notice at this website: https://docs.fcc.gov/public/attachments/DA-22-1315A1.pdf. You may submit comments in the Electronic Comment Filing System, citing proceeding number 13-184, at this website: https://www.fcc.gov/ecfs/filings/standard.

FCC Announcing Onsite Audits of Emergency Connectivity Fund Program

Recently, the FCC started to contact Emergency Connectivity Fund (ECF) recipients to announce its intent of performing onsite audits. In its announcements, the FCC requested the following documentation to be provided:

• The asset inventory for ECF-reimbursed equipment and services
• Records of payment for ECF-reimbursed equipment and services
• Documentation of unmet needs assessments (e.g., surveys)
• If an applicant replaced old equipment with ECF-reimbursed equipment, documentation of how the applicant determined the existing equipment was inadequate
• ECF bid documentation (if bidding was required by state, local or other laws or requirements)
• ECF-related invoices

In addition, the FCC has contracted a firm called Censeo to perform further desk audits and reviews. In these reviews, the audit firm may request and review asset inventories, questionnaires/surveys related to unmet need calculations, device/service usage reports from service providers, written internal controls related to equipment/connection distribution, and bids from service providers or other documents related to the procurement of the ECF-funded equipment/service.

While not every recipient of ECF funding can expect to be audited, it is important for all recipients to understand the rules of the program and the requirement for retention of documents to support compliance with those rules for 10 years. We encourage you to become familiar with the FCC’s ECF frequently asked questions website https://www.fcc.gov/emergency-connectivity-fund-faqs as well as to review information presented at webinars by the CDE and K12HSN which are available at this website https://www.k12hsn.org/resources/erate/ecf.

FCC Grants for Affordable Connectivity Fund Outreach

As funding available through the Emergency Connectivity Fund program winds down, schools may be looking for options to help their students and families access affordable broadband connectivity. The Affordable Connectivity Program (ACP) may be a solution.  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. Please see https://www.cde.ca.gov/nr/el/le/yr22ltr0809.asp for the announcement and links to helpful resources.

In November, the FCC launched two grant initiatives to support ACP program outreach, and school districts are eligible to apply for these grants. The first is the $60 million Outreach Grant Program which provides grants for up to two years for dedicated outreach activities. More information is available at this website https://www.fcc.gov/acp-grants. The second is the $5 million Navigator Pilot Program which provides one-year grants for direct application assistance activities. Please see this website for more information: https://www.fcc.gov/affordable-connectivity-pilot-programs. The application deadline for both grants is January 9, 2023.

FCC Designates Additional Manufacturers as National Security Threats

Recently, the FCC added equipment and services from two manufacturers, Pacific Network Corp. and its wholly-owned subsidiary ComNet (USA) LLC and China Unicom (Americas) Operations Limited, to its list of communications equipment and services that have been deemed a threat to national security. Recipients of E-Rate and ECF funding may not use these funds to purchase new equipment or to support or maintain equipment already in inventory from companies, their parents, affiliates, and subsidiaries included on the FCC’s “Covered List” of banned manufacturers. It is important for schools familiarize themselves with the listing of manufacturers and take steps to ensure no E-Rate or ECF funds are used to purchase or obtain any equipment or services produced or provided by a covered company posing a national security threat. For more information, please visit this website: https://www.usac.org/about/reports-orders/supply-chain/. To view the “Covered List” of banned manufacturers, which the FCC updates on a periodic basis, please visit this website: https://www.fcc.gov/supplychain/coveredlist.

E-Rate Administrative Window is Open and Will Close Soon

The Administrative Window for updating entity profile information in the E-rate Productivity Center (EPC) is now open and will close shortly before the FCC Form 471 filing window opens for the Funding Year 2023. As of now, the Universal Service Administrative Company (USAC) has not formally announced the FCC Form 471 window dates, but schools should expect that the window will open in mid-January and will close in mid-March.  Please see the section “E-Rate Process: Activities to Work on Now” for more information on activities to perform in during the Administrative Window.

USAC Announces Winter Holiday Hours and Winter Deferral Period

USAC’s Customer Support Center will be open to assist applicants and answer questions during its customary hours through Friday, December 23, from 5:00 a.m. to 5:00 p.m. Pacific Time. The Center will be closed on Monday, December 26, 2022 and Monday, January 2, 2023. Schools may contact USAC’s Customer Support Center by calling (888) 203-8100, or by creating a Customer Service Case under their accounts in the E-Rate Productivity Center. During the Winter Deferral period, starting Friday, December 16, 2022, and continuing through Friday, January 6, 2023, USAC will only continue reviews of pending forms and requests where documentation was received or where participants actively respond to information requests sent in EPC. Otherwise, reviews will be deferred and will be reinstated after January 6.

Update on USAC’s Move of Online BEAR Filing to EPC

As reported in the previous News Flash, USAC is moving the FCC Form 472 or BEAR invoicing system to the E-Rate Productivity Center. While USAC has announced that this move will not occur until after January 30, 2023, USAC has already migrated over appropriate permissions for users that had PINs in the legacy BEAR system and who are also authorized users in EPC. USAC is recommending that all applicants make sure that the Account Administrators for their organizations are current and to review their organizations’ authorized users and assigned user permissions prior to the migration of the BEAR system. As a reminder, there is an important final BEAR filing deadline of February 27, 2023, for Funding Year 2021 recurring service funding requests, and any applicants planning to file a BEAR for these requests must have the appropriate user permissions assigned to those individuals both preparing and certifying the BEAR forms prior to the February 27 deadline. Implementation news, resources, and updates can be found on USAC’s E-rate System Consolidation website: https://www.usac.org/e-rate/resources/e-rate-system-consolidation/ and in a recent Special Edition News Brief at https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=1049.

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 5,366 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 $416 million for California applicants.

E-Rate Funding Year 2021

For Funding Year 2021, California applicants have successfully submitted 5,693 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 $316 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.

January 30 Invoice Deadline

The deadline for invoicing of Funding Year 2021 non-recurring services is January 30, 2023. 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. Non-recurring services typically include Category 1 installation and Category 2 internal connections. You may view invoicing deadlines for your organization by using USAC’s E-Rate FRN Invoice Deadline Tool and filtering for your organization at this website: https://opendata.usac.org/E-Rate/E-Rate-FRN-Invoice-Deadline-Tool/sfyf-vvtz.

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 January 30, 2023 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

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
1-19	04/23/2022-8/25/2022	Deadline passed for services starting July 1, 2022
20	09/01/2022	12/23/2022
21	09/08/2022	1/6/2023
22	09/15/2022	1/13/2023
23	9/22/2022	1/20/2023
24	09/29/2022	01/27/2023

 

Funding Year 2021

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
1-61	04/17/2021-08/10/2022	Deadline passed for services starting July 1, 2021
62	08/24/2022	12/22/2022
63	09/09/2022	01/07/2023
64	09/21/2022	01/19/2023
66	11/2/2022	03/02/2023

 

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 recently announced its FY2023 E-Rate Eligible Services Webinar being held on Thursday, January 5, 2023, at 11:00 a.m. Pacific Time. You may register at this link: https://register.gotowebinar.com/register/5846649110151841113?source=News+Brief.

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 Program Overview
• E-Rate Pre-Commitment Process
• Filing the FCC Form 470 and the Competitive Bidding Process Webinar
• Category 2 Budgets
• EPC Administrative Window
• E-Rate Post-Commitment Process Thursday
• E-Rate Invoicing Process: Office Hour Webinar

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

California’s K12 High Speed Network will be offering multiple webinars throughout the E-Rate filing window specifically tailored to assist California’s school and school district applicants navigate the process. Please click on the Register links below to sign up!

Recordings and materials posted at https://www.k12hsn.org/resources/erate/training:

• Beginners: E-Rate 101 and Tour of K12HSN Resources
• Filing FCC Form 470 and California Competitive Bidding Reminders
• Beginners: Administrative Window Updates - Calculating Discounts and Category 2 Budgets 
• CITE conference State and Federal Broadband Updates
• Office Hour and Tour of USAC's Data Tools and Application Platforms

Upcoming sessions:

• Office Hour and Preparing for E-Rate Filing Window - January 11, 2023 12PM PT - Register
• Beginners: Filing FCC Form 471 for Category 1 - January 18, 2023 11AM PT Register
• Beginners: Filing FCC Form 471 for Category 2 - January 25, 2023 11AM PT - Register
• Office Hour and Review of Post Application Window Activities  - April 12, 2023 11AM PT - Register
• Office Hour and Important Invoicing Reminders - May 17, 2023 11AM PST- Register

In addition to conducting live training events through the application window, K12HSN has a wide variety of resources on its website that are tailored specifically to California’s school and school district applicants. The E-Rate Roadmap and Resource Guide provides an in-depth and step-by-step overview of the E-Rate program requirements and application process with links to various resources and videos. K12HSN also has an extensive library of pre-recorded webinars and materials that address a wide variety of topics and are available on-demand at any point in the E-Rate process. You may contact K12HSN’s E-Rate support team at any time with questions about E-Rate at eratequestions@lists.k12hsn.org.

E-Rate Process: Activities to Work on Now

Complete Administrative Window Activities

School and School District applicants are reminded that they must review and make any necessary updates to their schools’ profiles in the E-Rate Productivity Center (EPC) prior to the opening of the annual FCC Form 471 application filing window in January. EPC school profile information includes an entity’s classification, address, enrollment, National School Lunch Program (NSLP) eligibility information, Urban/Rural status and is the basis of the discount calculation on the FCC Form 471.  Schools should carefully review their entity profiles from now until the open of the FCC Form 471 window in early January at which time the entity profile information will be locked and not editable until the FY 2023 application window has closed.

If this is your first time reviewing and updating school profile information in EPC, we highly recommend that you watch K12HSN’s webinar recording of “Beginners: Administrative Window Updates - Calculating Discounts and Category 2 Budgets” at this link: https://www.k12hsn.org/resources/erate/training and visit the CDE’s website at https://www.cde.ca.gov/ls/et/ft/eratentityvalidation.asp to familiarize yourself with various entity classifications and data resources.

E-Rate Discount Updates

It is required for schools to update the source data for their E-Rate discount calculation for Funding Year 2023. For the past two years, USAC has allowed schools to carry forward data from their Funding Years 2020 and 2021 applications due to the COVID-19 pandemic. This will not be allowed for FY 2023 and schools must enter the most recently-available third-party validated enrollment and National School Lunch Program eligibility information into EPC. Commonly used third-party data sources for enrollment and National School Lunch Program eligibility for California public schools include:

• FRPM File on CDE website: https://www.cde.ca.gov/ds/sd/sd/filessp.asp
• CALPADS 1.17 - FRPM/English Learner/Foster Youth – Count
• Child Nutrition Information and Payment System (“CNIP”) monthly SNP Site Claim Report
• Community Eligibility Provision (“CEP”) Forms SNP-19 and SFA-2A

More information on calculating E-Rate discounts is available at USAC’s websites: https://www.usac.org/e-rate/applicant-process/applying-for-discounts/calculating-discounts/ and https://www.usac.org/e-rate/applicant-process/applying-for-discounts/alternative-discount-mechanisms/.

Category 2 Budget Allocation Updates

The five-year (2021-2025) Category 2 budget allocations derive from $167 multiplied by the full-time enrollment of the school district, or the $25,000 floor per school, or a combination of the two for school districts with 10 or fewer schools. Schools relying on the full-time enrollment multiplier must update this number at least once in the five-year cycle with third-party validated data. Schools that applied for and were funded for Category 2 services in FY 2021 and/or FY 2022 will have a fixed Category 2 budget for the five-year budget cycle FY 2021-2025 unless a Replacement Budget is requested.

Schools either applying for Category 2 for the first time in FY 2023 or who are requesting a Replacement Budget must update their full-time enrollment during the Administrative Window. The full-time enrollment may either be updated at the District level from the District’s main profile page in EPC or at the school level under each school’s EPC profile page. This video demonstrates how to request a Category 2 replacement budget: https://www.usac.org/video/sl/request-category-two-replacement-budget/index.html.

Other Entity Updates

Schools should verify that their entity profiles contain current and correct information. School districts should verify that all eligible school and non-instructional entities are listed under their School District in EPC. The Account Administrator and General Contact for the school or school district applicant should also be current. The Administrative Window is the time to make any necessary additions, deletions, or modifications to entity profiles either directly in EPC or via USAC’s Customer Service Center at (888) 203-8100. While these modifications may be made during application review if absolutely necessary, it is a best practice to complete these updates during the Administrative Window. This will assist USAC in its review of your application and will likely result in quicker funding commitments.