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Writer's pictureSellico Consulting
Jan 15, 202110 min read

#CDE #ERATE Issue 21-01 January 15, 2021 Newsflash


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

Funding Year 2021 E-rate Application Window Announced

The Universal Service Administrative Company (USAC) has announced the Funding Year 2021 E-rate application filing window. Schools that wish to request E-rate funding for services received from July 1, 2021 through June 30, 2022 must submit an FCC Form 471 application in USAC’s E-rate Productivity Center (EPC) between January 15, 2021 and March 25, 2021. Applicants have until January 13, 2021 to update their school profiles in EPC after which they will be locked for the duration of the FCC Form 471 filing window. Please see USAC’s announcements at the following websites: https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=987 and https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=988.


FCC Requests Comment on Emergency Broadband Benefit Program

The Federal Communications Commission (FCC) is requesting comment on how to effectively administer the recently created Emergency Broadband Benefit Program which will provide a temporary broadband subsidy to qualifying low-income households through the end of the COVID-19 pandemic. The program, which will be structured similarly to the existing Lifeline program, will allow for participating Internet service providers to offer up to a $50 per month discount on broadband services to eligible low-income households and $75 per month if the households are on Tribal lands. A $100 per household benefit may also extended if the Internet service provider offers a single device such as a laptop, desktop, or tablet and the charge for the device to the household is between $10 and $50. The FCC is requesting stakeholders, including schools, for comment on the roll-out of the program, including, but not limited to:

  • The definition of a household for purpose of receiving the benefit.

  • How the FCC can facilitate the ability of schools to connect with their students for the purposes of remote learning.

  • Minimum system requirements necessary to support video conferencing and other software platforms essential to ensure full participation in online learning.

  • Measures schools can take to publicize the availability of the program to households in need.

Stakeholders are encouraged to submit comments by January 25, 2021, and reply comments by February 16, 2021. More information is available at the FCC website: https://www.fcc.gov/fcc-seeks-comment-emergency-broadband-benefit-program. Information on the Lifeline program may be viewed at this website: https://www.fcc.gov/general/lifeline-program-low-income-consumers.


FCC Extends E-rate Gift Rules Waiver Through June 30, 2021

To assist schools in their ongoing response to the COVID-19 pandemic, the Federal Communications Commission (FCC) has announced that it will further extend its waiver of the E-rate gift rules through June 30, 2021. This waiver enables service providers to offer, and 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. The FCC reminds schools that the waiver is limited to offerings provided by service providers and solicited or accepted by E-rate eligible entities on behalf of students and teachers while schools prepare for extended remote learning and remain fully or partially closed as a direct result of COVID-19. The FCC also reminds schools of their obligation to comply with state and local procurement laws and that they are still subject to the program rules requiring a fair and open competitive bidding process for Funding Year 2021. You may read the entire announcement here: https://docs.fcc.gov/public/attachments/DA-20-1479A1.pdf.


FCC Offers Invoice Deadline Relief

On December 10, 2020, the FCC issued Order FCC 20-178 in which it modified its invoice deadline rules to permit applicants and service providers up to 120 days to submit invoices after USAC issues a Revised Funding Commitment Decision Letter (RFCDL) approving a post-commitment request or granting an appeal of a previously denied or reduced funding request. The FCC limits the rule change to post-commitment requests or appeal decisions that result in a RFCDL approving the request. Therefore, applicants or service providers appealing partially approved funding requests should submit invoices for the partial funding before the original invoice deadline expires because USAC will not provide additional time to invoice if the appeal is denied. The order also provides relief to certain previous year funding requests that had pending post-commitment activities which were not resolved until after the original invoice deadlines had passed. You may read the entire order on this website: https://www.fcc.gov/document/fcc-enhances-efficient-administration-e-rate-program.


California Department of Technology Offers New CALNET Next Generation Contracts

The California Department of Technology (CDT) makes available certain contracts which may be used by eligible public schools for E-rate eligible telecommunications and Internet services. The current CALNET 3 contracts are slated to expire in December of 2021. CALNET Next Generation contracts are now being made available in the following categories that may be of interest for E-rate applicants: 20 – MPLS Data Network, 23 – Metropolitan Area Network Ethernet, 24 – Flat Rate Internet Services, 25 – Sustained Bandwidth Internet Service, and 30 – Broadband with Internet Services. Schools may visit the following websites for further information:

Schools are reminded that use of state master contracts like CALNET do not eliminate the necessity of complying with E-rate competitive bidding rules. Schools anticipating using the CALNET Next Generation contracts should carefully review the CDT requirements for eligibility and use of the contracts and should plan on conducting an E-rate compliant competitive bidding process for services for which they will seek E-rate funding.


California Funding Commitment Summary

Funding Year 2020

As of January 05, 2021, California applicants have successfully submitted 9,053 funding requests for $371 million. To date, USAC has committed $289 million for California applicants.


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.


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.


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/.


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


Category 2 Webinar Series


General E-rate Topics


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

Competitive Bidding and Responding to Service Provider Questions

As of July 1st, 2020, schools have been able to post an FCC Form 470 for Funding Year 2021. The FCC Form 470 provides a Description of Services Requested and opens the minimum 28-day competitive bidding process. The competitive bidding process must identify the products and services a school is seeking so that potential service providers can review those requests and submit bids for them. Any additional documents, such as a request for proposal (RFP) must be uploaded onto the FCC Form 470 in the E-rate Productivity Center portal. It is the school’s responsibility to run an open and fair competitive bidding process.

  • All bidders must be treated the same.

  • No bidder can have advance knowledge or ‘insider’ information.

  • All questions received by the due date and due time must be answered.

  • All information must be shared with all potential bidders and all bidders must know what is required of them.

Schools should be aware that answering questions that may change the original scope of services and/or requirements outlined in the Form 470 and/or RFP may require the restart of the 28-day competitive bidding period and in some cases may also require the posting of a new FCC Form 470. Most often, a new FCC Form 470 is required when:

  • The original FCC Form 470 was certified without attaching any RFP documents, but you have now issued an RFP document and need to attach it.

  • You did not post services for a specific dropdown menu service type, and now realize that you need to post for services in that dropdown menu service type.

We caution schools that if changes are significant, applicants must restart the 28-day clock. Schools must count out the 28-days outside of EPC and extend due dates accordingly. Schools may refer to USAC’s website on competitive bidding for further information at: https://www.usac.org/e-rate/applicant-process/competitive-bidding/.


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) 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) 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) 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) 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) 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) 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


Extensions: The FCC extended the gift rules waiver twice. The first extension was to December 31, 2021, and the second to June 30, 2021. 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.



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