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Writer's pictureSellico Consulting
Dec 9, 20209 min read

#CDE / #ERATE Issue 20-18 December 9, 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 Releases FY 2021 Eligible Services List

On November 30, 2020, the Federal Communications Commission (FCC) released the final version of the Eligible Services List (ESL) for Funding Year (FY) 2021. There were no changes to the types or classifications of eligible services from FY 2020. The FCC made minor clarifications, including the following: 1.) Acknowledging the change to District or Library system-wide Category 2 budgets starting in FY 2021; and 2.) Noting equipment or services produced or provided by companies deemed as national security threats are not eligible for E-rate discounts. The FCC also reminds applicants that off-campus use of eligible services, even if used for an educational purpose, is generally ineligible for support.


You may read the entire order at the FCC’s website at: https://docs.fcc.gov/public/attachments/DA-20-1418A1.pdf


California Funding Commitment Summary

Funding Year 2020

As of December 1, 2020, California applicants have successfully submitted 9,030 funding requests for $371 million. To date, USAC has committed $262 million for California applicants. Due to the COVID-19 pandemic and the second FCC Form 471 filing window, USAC has pushed back its deadline to complete the processing of workable applications to December 31, 2020.


Pace of Commitments

The overall pace of commitments in terms of funding committed versus requested for California applicants in FY 2020 lags versus same period in 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.


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.


Funding Year 2019

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.


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 and webinar registration for upcoming webinars are posted on the USAC website at https://www.usac.org/e-rate/learn/webinars/.


E-rate Invoicing Process Webinar

Date: Wednesday, December 16, 2020

Time: 11:00 AM PT


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 for Funding Year 2021. Upcoming sessions include the following:


Winter Series Schedule:

  • January 7 – 2:00 pm ET – Form 471 Category 2

  • January 7 – 3:45 pm – Form 471 Category 1

  • February 11 – 2:00 pm ET – Changes: RAL, Service Substitutions, SPIN Changes

  • February 11 – 3:45 pm – Questions and Review, PIA interaction, Audits

  • April 1 – 2:00 pm ET – Post Commitment, Document Retention, Appeals

  • April 1 – 3:45 pm – Forms 486 & 472


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


K12 High Speed Network E-rate Resources


Fall Webinar Series

K12HSN is currently hosting complimentary “E-rate Lunch and Learn” webinars for both Category 1 and Category 2 services. These webinars will include tips and best practices geared specifically to California schools. Registration may be completed at the following link: https://www.k12hsn.org/resources/erate/training.


Category 1 Webinar Series

Webinar Topic

Previous Recording Link or Upcoming Date


Category 2 Webinar Series

Webinar Topic

Previous Recording Link or Upcoming Date


General E-rate Topics

Webinar Topic

Previous Recording Link


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

Check EPC Profiles for Accuracy, Collect and Review NSLP and Enrollment Data, Establish Category 2 Budgets for FY 2021-2025

On October 19, the Universal Service Administrative Company (USAC) opened the Administrative Window for updating entity profile information in the E-rate Productivity Center (EPC). Profile information includes an entity’s classification, address, enrollment, National School Lunch Program (NSLP) information, Urban/Rural status and is the basis of the discount calculation on the FCC Form 471. New this year is a separate section in EPC where enrollment is reported for the purposes of establishing Category 2 budgets for FY 2021-2025. Applicants 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 2021 application window has closed.


Important Enrollment and NSLP Data Reporting Information for FY 2021

Recognizing that student enrollment at schools has been impacted by COVID-19, and FY 2021 is the first year of the new Category 2 (C2) five-year budget cycle under the new rules, USAC will permit applicants to utilize their full-time enrollment and National School Lunch Program (NSLP) eligibility numbers from their FY 2020 FCC Form 471 applications for the FY 2021 application cycle. The FY 2020 numbers are pre-populated in the school entity profiles and C2 budget forecasts and will not change unless the school district overwrites these numbers with new data during the Administrative Window.


Schools that do not have entity updates should confirm that EPC information matches their FY 2020 supporting documentation. Otherwise, schools may update their FY 2021 profiles utilizing Fall/Winter 2020/21 school year supporting documentation. Acceptable documentation sources for enrollment and National School Lunch Program eligibility include the following:

  • 2019/20 FRPM File on the CDE website: https://www.cde.ca.gov/ds/sd/sd/filessp.asp

  • 2020/21 CALPADS 1.17 - FRPM/English Learner/Foster Youth – Count

  • 2020/21 Child Nutrition Information and Payment System (“CNIP”) SNP Site Claim Report

  • 2020/21 Community Eligibility Provision (CEP) Form SNP-19

It is important to note that applicants should only use data sources that accurately depict the enrollment and poverty rate of their school populations.


Updating Profiles in EPC

To update or verify the data for each school in the organization you must select each school listed under the “My Entities” section of the Landing Page. Once a school is selected, click “Manage Organization” to make updates to the individual school.

Once the discount profile has been updated for each school within the school district, please be sure to go back to your organization's landing page, click on discount rate link and the discount that will be imported into the Form 471 will be displayed.


Verify the contact person’s information on the district’s profile. Since this person will receive communications from USAC, it is important that this be someone who has regular e-mail access and access to the LEA’s account in the E-Rate Productivity Center (EPC).


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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