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Writer's pictureSellico Consulting
Sep 22, 20209 min read

[ #CDE - #ERATE ] Issue 20-15 September 22, 2020 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

FCC Opens Second E-rate Application Window for Funding Year 2020 for Additional On-Campus Bandwidth Needs for Schools due to COVID-19

On September 16, 2020, the Federal Communications Commission’s (FCC) Wireline Competition Bureau (WCB) announced the opening of a second Funding Year (FY) 2020 filing window to allow schools to request additional E-rate funding specifically to address increased on-campus bandwidth needs due to COVID-19. During this second filing window, schools will be able to purchase additional bandwidth for FY2020 to address needs resulting from the increasing shift to one-to-one student-to-device ratios in classrooms, live streaming of classroom instruction to students at home, and expanding use of cloud-based educational tools and platforms. The second filing window opened on September 21st, and will close at 8:59 P.M. Pacific Time on October 16, 2020. The second filing window is limited to schools that previously submitted an FCC Form 471 for equivalent Category 1 services that has either received a Funding Commitment Decision Letter, or has such a funding request pending, and has not been denied. Funding requests filed during the second window may only receive the same or less than the price per megabit compared to the original contract/service for FY2020 and do not need to undergo a new competitive bidding process, unless required by State and Local laws.


USAC’s September 18, 2020 News Brief provides a summary of the order and second filing window: https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=971.


K12HSN will be hosting two webinars to review the requirements of the second filing window. Registration links can be found in the E-rate Training Resources section of this News Flash.



California Funding Commitment Summary

Funding Year 2020

As of September 14th, 2020, California applicants have successfully submitted 8,869 funding requests for $363 million. To date, USAC has committed $206 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 lags slightly versus same period in the previous year, primarily due to the slower processing of Category 2 (C2) applications. The pace of commitments for Category 1 (C1) applications exceeds that of the previous year.


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


FCC COVID-19 Relief and Second 2020 E-rate Filing Window

Friday, September 25 11:00 - 12:30

Wednesday, September 30 1:00 - 2:30

BIIG Webinar: What to Do Now that You Are Funded: Filing Form 486 and Coordinating Discounts with Service Providers

Tuesday, September 22 from 2:00 - 3:00 pm

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

Filing FCC Form 500 for Service Delivery and Contract Extensions

Generally, the service delivery and/or contract extension requests must be submitted to USAC on or before the September 30, 2020, deadline. However, the COVID-19 Order issued by the FCC on April 1st, provided automatic 1-year extension of service delivery deadlines for FY2019 and prior.


Applicants should check the expiration date on their contracts and, if allowed by the contract and local Board policy, extend their contracts and notify USAC of the new contract expiration date via the FCC Form 500. USAC will not approve invoices for services or products delivered after the contract expiration date reported on the funding request or after the original (or extended) service delivery deadline.

For more information on how to review for service delivery deadlines and instructions on how to complete the FCC Form 500 as well as invoice USAC for discounts, please visit the Trainings on the K12 High Speed Network website and view the webinar titled E-rate Invoicing and FCC Form 500: https://www.k12hsn.org/resources/erate/training.


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. (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. (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. (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. (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. (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. (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.


Extension: The FCC announced the extension of its waiver of the E-rate gift rules due to COVID-19 from September 30, 2020 to December 31, 2020. As a reminder, this waiver is limited strictly to the offering and acceptance of broadband connections, devices, networking equipment, or other things of value that could help students and teachers affected by school closures during the coronavirus pandemic. 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 order at the FCC’s website https://docs.fcc.gov/public/attachments/DA-20-1021A1.pdf.

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