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#USAC / #ERATE Schools and Libraries News Brief for the Week of November 20, 2020


TIP OF THE WEEK:

USAC has added some new fields in two of the datasets located in the E-rate section of the Open Data platform. Please refer to the Announcements section of the USAC website for specific information.


NOTE: USAC will not issue an SL News Brief next Friday, November 27 due to the Thanksgiving holiday. Also, the Client Service Bureau (CSB) will be closed Thursday, November 26 and Friday, November 27.


Commitments for Funding Year (FY) 2020 and FY2019


FY2020. USAC released FY2020 Wave 30 Funding Commitment Decision Letters (FCDLs) on November 19. As of November 20, FY2020 commitments total over $1.95 billion. FY2019. USAC released FY2019 Wave 78 FCDLs on November 18. As of November 20, FY2019 commitments total over $2.42 billion. On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in the E-rate Productivity Center (EPC).

Fall 2020 Training - Frequently Asked Questions


On November 4-6, 2020, USAC offered a series of nine online sessions for Schools and Libraries (E-rate) Program participants, including Tribal applicants. Over the next few SL News Briefs, we will provide answers to questions of general interest that attendees asked during the sessions. We have posted a recording of each session under the Previous Trainings section of the E-rate Webinars page for you to review. Presentation slides are also published for most sessions.


E-rate Pre-Commitment Process


Q. Do I need to include my bid evaluation matrix in the RFP documents I post to my FCC Form 470?

A. E-rate Program rules do not require you to include your bid evaluation matrix in the RFP documents posted to your FCC Form 470. However, you may be required by your state or local procurement rules or regulations or competitive bidding requirements to disclose information about your evaluation criteria.


Q. Can we use cooperative awards such as national or state contracts to purchase services?

A. You can purchase from a state master contract if you are eligible to do so in your state. Moreover, if your state certifies an FCC Form 470 as part of its competitive bidding process, you can cite to that FCC Form 470 number instead of posting your own. Please refer to the State Master Contracts guidance on the USAC website for detailed information. You can also purchase from a national contract signed by a consortium pursuant to the consortium's FCC Form 470 if you are a member of the consortium. USAC may request a Letter of Agency or other documentation from you to demonstrate that you are a member.


Q. What factors do I need to consider if I am signing an addendum to my original contract with my service provider?

A. In general, your contract and contract addendum must be signed before you submit your FCC Form 471. If you signed a multi-year contract with your service provider, and you want to sign an addendum to request a higher bandwidth, for example, you must have included the option for increasing your bandwidth in your FCC Form 470 and/or RFP documents so that other service providers also had a chance to submit responsive bids. Even so, we recommend that you sign your addendum before you submit your FCC Form 471 for the upcoming funding year.


Q. Can I still receive E-rate discounts if I signed a contract with a service provider that was not competitively bid under E-rate Program rules?

A. It depends. You still must post an FCC Form 470 and may consider your existing contract as a bid response. As long as that contract is the most cost-effective of the bids you receive, using price as the primary factor, you can choose that contract as the winning bid and request E-rate discounts for eligible services provided under that contract starting with the upcoming funding year. However, if your contract is not the most cost-effective bid, you must go with the winner of your bid evaluation process in order to receive E-rate discounts on your services.


Q. How do I report violations of E-rate Program rules to USAC?

A. If you suspect a violation of E-rate Program rules, go to the Actions menu in EPC, choose Create a Whistleblower Case, provide the details that you have, and click the Submit button at the bottom of the page. You can also call the Client Service Bureau (CSB) at (888) 203-8100 and let the agent know that you want to report a program rule violation.


Q. How do I get on the list of service providers eligible to provide services under E-rate?

A. Except for providers of telecommunications services, we do not have specific requirements for service providers to participate in the E-rate Program. If you are a new service provider who wants to participate in E-rate, you can start by completing an FCC Form 498 in the E-File System to get a Service Provider Identification Number (SPIN). To do this:

  • Click the blue Sign In button at the top of any page on the USAC website.

  • Click the blue Continue button at the bottom of the One Portal instruction page.

  • Click the blue "Create an Account" text link at the bottom of the Username/Password page.

  • Click the down arrow to the right of "I am a … Service Provider - 498 ID."

  • Click the blue Register My Company button.

If you need assistance, you can review the FCC Form 498 and instructions on the USAC website or call our Customer Service Center at (888) 641-8722 and choose option 3 (Schools and Libraries), then option 2 (FCC Form 498).


Q. How do service providers find service requests that applicants have posted?

A. All FCC Forms 470 and their associated attachments are available in our public tools the day after the forms are certified. You can use the four E-rate Open Competitive Bidding datasets (Basic Information, Consortium Entity Information, Consultants, and Services Requested) in the Open Data tool to run queries on posted FCC Forms 470. The View an FCC Form 470 tool allows you to search for forms that meet specific criteria, or you can download summary information using the Download FCC Form 470 Information tool. If you want to review forms posted the same day and you have access to EPC, go to the Actions tab, choose Search and Export Certified FCC Forms 470, set your search criteria, and follow the instructions. You can review the information in HTML format or export the results.


Q. How do I use a recent bill as a bid response?

A. If you are currently receiving service from a service provider, you can consider a recent bill from that service provider as a bid response to your posted FCC Form 470. Note that it would be a good idea to ask for an email or other written communication that your current provider is willing to continue to provide service at the same price (or note the reason for any expected change in price) for the upcoming funding year. You can choose that bid if it is the most cost-effective solution based on the results of your bid evaluation (using price as the primary factor), or if it is the only bid received and the service is cost-effective.


Q. How long do I need to retain bids or quotes from service providers?

A. Applicants must retain winning and losing bids for at least 10 years after the latter of the last day of the applicable funding year or the service delivery deadline of the funding request. Service providers are subject to the same requirement, except that they do not have to retain losing bids.


Category Two Budgets


Q. Do applicants still need to allocate C2 funding among their individual entities?

A. Starting in FY2021, C2 budgets are calculated at the school district or library system level, and you are not required to provide allocations by individual school or library branch. Consortia must still allocate C2 costs to their members (independent schools, independent libraries, school districts, and library systems). Although consortia can still allocate services to some child entities and not others, any such allocations will be totaled and attributed to the appropriate school district or library system C2 budget.


Q. Do the multipliers and the funding floor apply to the entire five-year C2 budget cycle?

A. Yes. Beginning in FY2021, C2 multipliers for each five-year budget cycle will be set once at the beginning of the cycle and apply to the entire cycle. They will always be rounded to two digits (dollars and cents) and adjusted for inflation. The multipliers and the funding floor for the first five-year cycle beginning in FY2021 have already been adjusted for inflation and will not change during the five-year C2 budget cycle.


Q. Can I provide updated square footage numbers for my library if the Institute of Museum and Library Services (IMLS) square footage is incorrect?

A. Yes. Be sure to maintain documentation of your square footage numbers in case USAC requests that documentation during the review of your application.


Q. My school has been closed due to COVID-19, and we are not required to report our National Student Lunch Program (NSLP) student counts this year. Can I use the student counts I entered in my FY2020 FCC Form 471?

A. Yes, this is permitted due to COVID-19. Keep in mind that you will be entering your student counts in your EPC profiles for two purposes for FY2021: your discount calculation and your C2 budget calculation. You can refer to the recording of our EPC Administrative Window training webinar for the details of how to enter the appropriate information in your EPC profiles.


Q. Where can I find exactly what products and services are included in Category Two?

A. You can find a general description of Category Two services in the Eligible Services Overview document on the USAC website. For services that will be included in Category Two for FY2021, you must wait for the FCC to release the FY2021 Eligible Services List (ESL). We will post the FY2021 ESL on the Eligible Services List web page as soon as it becomes available.


Q. When does the new equipment transfer rule come into effect?

A. Starting in FY2021 (which begins on July 1, 2021), school districts and library systems are not required to report equipment transfers between schools within a district or libraries within a system. However, both the transferor and recipient must maintain detailed records documenting the transfer and the reason for the transfer for a period of five years, and you are required to maintain asset and inventory records of equipment purchased and the actual locations of such equipment for a period of 10 years after purchase.


Q. How do I notify USAC that I want to request a C2 budget recalculation later on in the five-year cycle based on updated student counts or square footage information?

A. Your C2 budget is set once you obtain funding for C2 services. The multipliers, the inflation rate, etc. will be released by the FCC in advance of the start of each five-year cycle. Applicants must validate their student counts or library square footage in the first year they apply for funding in the relevant five-year budget cycle. Applicants will have the option to request a C2 budget recalculation in any year after the first year of the five-year cycle from their organization's EPC profile, but are not required to do so. If an applicant does not request a recalculation, the student count for the school district or the library square footage will not change during the cycle. We expect that school applicants that experience increased student enrollment or library applicants that expand their square footage during the budget cycle might choose to exercise this option.


Category Two Budget Tool FY2021+


Q. Is the C2 budget amount in this tool our actual C2 budget for the five-year period?

A. The current information in the C2 budget tool is based on the entries in your entity profile pages, which have not yet been reviewed by USAC's Program Integrity Assurance (PIA). After USAC has issued a commitment wave featuring a C2 commitment for your entity, your C2 budget will be set. You can keep that C2 budget for the remaining four years of the five-year cycle, or you can request a C2 budget recalculation in any or all of those years if your student count (schools) or your square footage (libraries) increases. Keep in mind that the tool does not capture all data points that may be relevant for determining an applicant’s actual available C2 budget at a certain point in time during each five-year cycle, such as pending appeals and FCC Forms 500. It should therefore be used for informational purposes only.


Q. I entered my school district information and am still seeing columns that don't apply to me, for example, the library column. How do I remove them?

A. This tool was designed for all types of users to search for information on C2 budgets. To see only the columns of data that pertain to your type of entity, you have two options:

  • Search for the data you want using the tool, export it to a spreadsheet program, and then remove the columns you don't need.

  • Watch the video guides on the Open Data video guides page to learn how to set up your own queries in Open Data. You can then create an account in Open Data, build your own query for the E-rate C2 Budget Tool Data FY2021+ Dataset, and save the resulting query and any reports you design in your account. Any reports you create and save will update automatically every night.

Q. Can you explain the difference between a forecast budget, a preliminary budget, and a confirmed budget?

A. Forecast, preliminary, and confirmed versions of C2 budgets are determined as follows:

  • The forecast version of an entity's C2 budget is based on the current student count or square footage in the applicant organization's profile. If you change a student count or a square footage entry related to the C2 budget in the entity profile, the forecast version of the C2 budget will show the result of the change the following day.

  • The preliminary version of an entity's C2 budget is based on the information on the first certified C2 FCC Form 471 featuring that entity. Note: If there is an estimated student count for an independent school designated as new construction or a small school district with one or more schools designated as new construction, the tool will also show a preliminary budget until the actual student count is verified.

  • The confirmed version of an entity's C2 budget is based on the information in an FCC Form 471 for which USAC has issued a funding decision for a C2 funding request (unless all of the funding requests have been canceled or denied). You will not see confirmed C2 budgets until after the first commitment wave for FY2021.

Again, keep in mind that the tool is designed to assist applicants in determining their C2 budgets for each five-year cycle beginning with the first budget cycle, which starts in FY2021 and ends in FY2025. While the tool provides information about applicants' C2 budgets based on the most recent entity profile and commitment data available, it does not capture all data points that may be relevant for determining an applicant's actual available C2 budget at a certain point in time during each five-year cycle, such as pending appeals and FCC Forms 500. It should therefore be used for informational purposes only.


Q. Are post-commitment changes, such as appeals and FCC Form 500 requests, reflected in the tool?

A. Pending appeals and post-commitment change requests are not reflected in the tool. However, once an appeal or post-commitment request is completely processed and goes through a wave, any changes to the C2 budget information will be reflected in the tool the following day. (Note: USAC runs post-commitment waves using a process similar to that we use for the current funding waves we report at the top of each SL News Brief. However, post-commitment waves do not run on a regular schedule.)


Q. What does the number in the "C2 Per Site Basis Difference" field mean?

A. The dollar value in this field shows the advantage to a small school district (10 or fewer schools) or small library system (10 or fewer libraries) of the per-site calculation for its C2 budget. All school districts and library systems have two possible C2 budget calculations:

  • Per student or per square foot. For school districts, this is the total number of students in the district multiplied by the school multiplier of $167.00 per student. For library systems, this is the total square footage of all the library branches in the system multiplied by the library multiplier of $4.50 per square foot.

  • Per school or per library. This is the total number of individual schools in a school district or the total number of library branches in a library system multiplied by the funding floor of $25,000.

Per site. Small school districts and small library systems have a third possible calculation: determine the higher of the two C2 budget calculations above for each individual school in the district or library branch in the system and then total the results. This gives a higher C2 budget calculation for small school districts containing at least one school with more than 150 students or for small library systems containing at least one library branch with more than 5,555 square feet.


Need Help? Contact Us!

For questions about the E-rate Program, contact the Client Service Bureau at (888) 203-8100.

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