E-rate News Flash
Contents:
Announcements
Funding Commitment Summary
Pending Dates and Deadlines
E-rate Training Resources
E-rate Process: Activities to Work on Now
Summary of Federal Communications Commission’s E-rate Response to COVID-19
Announcements
New Category 2 Budget Tool
On August 13, 2020, USAC deployed a new Category 2 Budget Tool for Funding Years 2021-2025. The tool is designed to provide applicants a forecast of their Category 2 Budgets for the upcoming Category 2 budget period. Applicants will need their Billed Entity Name or Billed Entity Number (BEN) to filter the budget information.
Note: The tool will provide forecasted Category 2 budget amounts utilizing the BEN’s current profile information (number of entities, enrollment or square footage).
A video demonstration of the Category 2 tool can accessed via the following link: https://www.usac.org/e-rate/learn/videos/#E-rate-C2-Budget-Tool-FY2021
The Category 2 Budget Tool may be accessed through USAC’s Resources Tools page: https://www.usac.org/e-rate/resources/tools/
USAC’s August 14th News Brief provides detailed information regarding the Category 2 Budget Tool algorithms: https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=965
FCC Grants Relief for Form 471 Applications Filed Within 60 Days of Deadline
On August 6, 2020, the Federal Communications Commission (FCC) released DA 20-842 formally announcing waiver of the Funding Year 2020 E-rate application deadline for applicants who filed their applications within 60 days of the April 29th FCC Form 471 deadline and directed USAC to automatically treat these applications as if they were filed within the deadline. This order eliminates the requirement for applicants to individually file a formal waiver request with the FCC. You may read the entire order addressing the extension and view the list of named applicants at the FCC’s website at https://www.fcc.gov/general/e-rate-schools-libraries-usf-program#daily-releases under the Daily Releases section.
California Funding Commitment Summary
Funding Year 2020
As of August 18, 2020, California applicants have successfully submitted 8,857 funding requests for $363 million. To date, USAC has committed $171 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 is slightly higher than it was as of the same period in the previous year. While the commitments of Category Two (C2) funding are slightly less than those at the same time last year, the pace of funds committed versus those requested for Category One (C1) funding is higher year-to-date in FY 2020 versus FY 2019.
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.
* 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.
* 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
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
Service Substitution Requests
A service substitution request must be submitted to USAC any time an applicant wants to change the products and/or services on the approved FCC Form 471. In the service substitution request you will be required to provide USAC the original product and/or service that was approved on the FCC form 471 and the substituted product and/or service. Each Funding Request Number (FRN) line item requiring a substituted product and/or service must be requested through the E-rate Productivity Center (EPC) for Funding Year 2016 forward. For Funding Year 2015 and previous years, the service substitution is submitted via an EPC customer service case. For step-by-step instructions, please refer to USAC’s user guide at https://www.usac.org/wp-content/uploads/e-rate/documents/e-rate-productivity-center/EPC-User-Guide-Service-Substitution-Requests.pdf.
When Service Substitutions May Be Submitted
A service substitution may be submitted to USAC as soon as your FCC Form 471 Receipt Acknowledgement Letter (RAL) is available in EPC which is generally moments after the FCC Form 471 has been certified. Service substitutions must meet the following conditions:
The substituted services or products have the same functionality as the services or products contained in the original proposal
The substitution does not violate any contract provisions or any California or local procurement law
The substitution does not result in an increase in the percentage of ineligible services or functions
The requested change is within the scope of the establishing FCC Form 470, including any Requests for Proposals (RFPs), for the original products and/or services
If the service substitution results in an increase to the pre-discounted amount the substitution will only be approved at the amount that was originally committed by USAC. If the service substitution results in a decrease to the pre-discounted amount, then the funding request will be approved at the lower amount associated with the substitution.
Service Provider Identification Number (SPIN) Changes
Invoicing to a funding request may be on hold due to an incorrect SPIN currently being associated to a funding request. There are two types of SPIN changes: Corrective SPIN Change or Operational SPIN Change.
Corrective SPIN Changes
Corrective SPIN Changes are commonly required when the applicant or USAC made a data entry error and/or a change to the service provider identification number occurred. For example:
Data entry errors were made when the FCC Form 471 was submitted.
Your service provider has multiple SPINs and you chose the wrong SPIN.
A merger or acquisition occurred: The original service provider has merged or has been acquired by another company and the SPIN indicated on the FRN has changed.
Additional information and instructions for completing a Corrective SPIN Change are located at USAC’s website at https://www.usac.org/e-rate/applicant-process/before-youre-done/spin-changes/
Operational SPIN Changes
Operational SPIN changes are commonly required when the applicant is required to change the associated SPIN on a funding request due to reasons beyond its control. This occurs when the original service provider is unable or unwilling to perform the services associated with the approved funding request.
Operational SPIN Changes are allowed in very limited situations and must meet the following requirements:
California and local procurement rules allow it.
Terms of any contract between the applicant and its original service provider allow it.
The applicant has notified the original service provider of its intent to change service providers.
There is a legitimate reason to change providers. For example: non-responsive communications, breach of contract, or the service provider is unable to perform the requested services.
The newly selected service provider received the next highest point value in the original bid evaluation and has accepted and agreed to provide services.
Note: FCC rules also allow for an Operational SPIN Change if the funding request is for a new contract and the new service provider is unable to deliver the service in a timely manner. An applicant may file an Operational SPIN change to request some or all of the funding to be allocated to the previous service provider so that there are no interruptions to funding or service. However, the funding request cannot be increased if the previous provider’s service costs more than what is approved on the funding request.
Additional information and instructions for completing an Operational SPIN Change are located at USAC’s website at https://www.usac.org/e-rate/applicant-process/before-youre-done/spin-changes/
SPIN Change Deadlines
SPIN change requests must be submitted no later than the last date to submit an invoice. For Funding Year 2019, the deadline for recurring services is 02/25/2021 and the deadline for non-recurring services is 1/28/2022. However, the sooner your request is submitted and processed by USAC, the sooner invoicing may begin under the correct SPIN.
Applicants who file either Corrective or Operational SPIN Change requests must still comply with program deadlines and must continue to file their FCC Form 486. If the SPIN change is being submitted near the invoicing deadline date, the applicant should also request an invoice deadline extension. This will extend the invoice deadline while USAC reviews and processes the SPIN change.
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.
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.
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.
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.
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.
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.
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.
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. You may read the entire order at the FCC’s website https://www.fcc.gov/document/fcc-acts-support-telehealth-remote-learning-during-coronavirus.
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