Emergency Connectivity Fund FAQs
Users – Which users are eligible for ECF-supported goods and services?
Students, school staff, and library patrons with credentials
Specifically named in the order are students, school staff, and library patrons who would otherwise lack access to a device sufficient to enable them to engage in remote learning. Applicants may purchase one device per student; this applies to every student regardless of their NSLP eligibility. The order does not limit support to just “teachers” either, rather it incorporates a broader population by identifying “school staff” as eligible for support.
From the FCC release “To ensure that connected devices supported by this Program are used primarily for educational purposes and by students, school staff, and library patrons, we require schools and libraries to restrict access to eligible connected devices to only those students, school staff, and library patrons with appropriate credentials.”
Locations – Which locations are eligible for ECF-supported services?
Any place other than the school or library campus
In the ECF Order, the FCC defined eligible locations as basically anyplace other than the school or library (see paragraph 48). While they acknowledged that remote learning would take place in the home for most students and library patrons, the FCC did not limit or define where remote learning can happen.
The only location limit was to “prohibit schools and libraries from seeking and receiving reimbursement for eligible equipment and services purchased for use solely at the school or library”. (¶52). If the connected device was purchased with the intent of providing off-campus remote learning opportunities, the FCC acknowledged that the device may be used on-campus as well. This is in line with the ECF’s goal to close the homework gap.
Services – Which services are eligible?
Off-campus internet services
Internet access services include “fixed” services like cable modem, DSL, or residential fiber service, as well as wireless services like 5G/LTE service to hotspot devices. Equipment necessary to make Internet connections functional, such as modems, routers, and hotspots are eligible as well.
Self-provisioned networks and “datacasting” solutions are presumed to be ineligible, except in cases where “no commercially available [Internet] services exist.” In limited cases where there is no commercially available service that can reach students, school staff, or library patrons, the FCC can fund the construction of networks “and/or purchase customer premises equipment to receive datacasting services.” CBRS and private LTE solutions were specifically excluded from the definition of a “router” or “modem,” but could potentially be funded in situations where there is no commercially available service that can reach a given user population.
Learning Devices – What equipment is eligible?
Wi-fi enabled laptop computers
Eligible connected devices include laptops and tablet computers, with the FCC setting an expectation that the devices will be “Wi-Fi enabled and able to support video conferencing platforms.” While the FCC did not impose a specific screen size requirement for eligible devices, they did exclude both desktop computers and smartphones from the ECF’s eligible services list.
Ineligible equipment and services include cybersecurity solutions, mobile phones/smart phones, standalone costs for peripherals like cameras or microphones, curriculum and/or learning management systems, videoconference service subscriptions (e.g. Zoom or Teams), and voice services.
Service Delivery Dates
Discounts for services from July 1, 2021 to June 30, 2022
Services and equipment delivered from July 1, 2021 through June 30, 2022, are the initial priority. Only those items provided during this timeframe will qualify for support in the first filing window.
If there are funds remaining after the first filing window, the FCC may decide to open a subsequent filing window(s), either for new purchases and/or for purchases made during the March 1, 2020 through June 30, 2021.
Forms – What forms will I file?
Existing E-rate forms will be used
The ECF program will be administered by USAC, and, where possible, will use forms that exist within the online E-rate portal (EPC) The FCC has indicated the E-rate forms that will be used are the Form 471, Form 472 (BEAR), and Form 474 (SPI).
The Form 471 will be used as the vehicle for applying. The Form 472 (BEAR) and Form 474 (SPI) will be used to seek reimbursement.
Detailed invoices will be required at the time payment paperwork is submitted. Applicants that seek payment from the Emergency Connectivity Fund prior to paying their service provider(s) must also provide verification of payment to the service provider(s) within 30 days of receipt of funds.
All applicants must register in System for Award Management (SAM.gov). SAM is a web-based application that collects, validates, stores, and disseminates business information about the federal government’s partners in support of federal awards, grants, and electronic payment processes. It can take up to 20 days for a SAM registration to become active and an additional 24 hours before that registration information is available in other government systems.
Filtering – How do CIPA laws impact ECF?
Applicant-owned devices on ECF network subject to CIPA
ECF recipients will be required to comply with CIPA requirements in a similar way to E-rate funding recipients.
The CIPA requirements will apply for the use of computers (laptops, tablets, etc.) that are owned by the applicant (school or library), if the applicant receives funding for Internet service through ECF or E-rate.
Compliance with CIPA is not required if 1) the devices are owned by the school or library applicant, but the applicant is not receiving Internet service funding from either ECF or E-rate, or if 2) the devices are owned by a third-party (the student or library patron).
The CIPA certifications for the ECF program will be included on the FCC Form 471 that applicants submit for ECF funding requests (no additional Form 486 CIPA certification will be required).
ESSER/CARES – Does my organization still qualify?
No reimbursements for other pandemic relief
The FCC will not provide support for eligible equipment and services that have already been reimbursed through other federal pandemic relief programs (e.g., CARES Act, Emergency Broadband Benefit Program, or other provisions of the American Rescue Plan); state programs specifically targeted to providing funding for eligible equipment and services; other external sources of funding or gifts specifically targeted to providing funding for eligible equipment and services.
Audit Trail – What are the documentation requirements?
10-year documentation requirement
Similar to the E-rate program, applicants are required to keep documentation supporting their funding requests, goods and services delivery, and payment requests.
Category 2 Cost Allocations:
Some Category 2 equipment is not completely eligible for E-rate funding . This requires the application to deduct a percentage of the base costs to arrive at the E-rate eligible pre-discount amount.
Below are links to some manufacturers who have published their cost allocations for their E-rate product catalogue:
2021-2022 LOOKING FORWARD
CATEGORY 2 BUDGETS RESET FOR NEW 5 YEAR PERIOD
Schools- $167 per student
Libraries- $4.50 per square foot
Minimum of $25,000 for individual library or school
Your discount rate comes directly from the NSLP percentage of your district- this is based on school surveys that student families fill out regarding their need for free/reduced lunches.
FORM 470 WINDOW OPEN NOW
If you have bandwitth upgrade needs or new projects on the horizon for infrastructure or other updates, get in touch with us as soon as possible so we can get a plan together
2020-2021 471 FILING WINDOW JAN 15 THRU MARCH 25, 2020
CATEGORY 2 BUDGET MULTIPLIERS 2020
The FCC released the budget multipliers and funding floor for FY2020, which will be the sixth and final year of the C2 budget test period.
The multipliers and funding floor for the FY2020 transition year are as follows:
Schools – $195.63 per student
Libraries with Institute of Museum and Library Services (IMLS) locale codes 11, 12, or 21 – $6.52 per square foot
Libraries with all other IMLS locale codes – $3.00 per square foot
Entities at the funding floor – $11,998.43.
CATEGORY 2 BUDGETS FOR 2021
On December 3, 2019, the FCC issued the Category Two Report and Order, FCC 19-117, which permanently extended the Category Two (C2) budget approach with some modifications.
This week we are providing information regarding the C2 budget changes for FY2021.
Here are some important things to keep in mind as you plan ahead for FY2021.
C2 budgets will change to a fixed, five-year cycle.
After the FY2020 transition year, the first five-year C2 budget cycle will begin in FY2021 and go through FY2025. All applicant budgets will be reset for FY2021. Any unused C2 budget funding from the six-year test period (FY2015 through FY2020) will not carry forward.
The C2 multipliers and the budget floor are changing.
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.
For the FY2021-FY2025 cycle:
The school multiplier will be $167.00 per student.
The library multiplier will be $4.50 per square foot for all libraries regardless of IMLS locale code.
The funding floor will be $25,000.00.
C2 budgets are set at the beginning of the cycle, but applicants have the option to adjust them during the cycle.
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 have the option to request a C2 budget recalculation in any year after the first year of the five-year cycle, 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.
BEGIN THE PROCESS - STEP 1 - COMPETITIVE BIDDING
Competitive bidding is a formal process to identify and request the products and services you need so that potential service providers can review those requests and submit bids for them.
Services provided on a month-to-month basis require an FCC Form 470 to be posted each year. However, if a multi-year contract results from a completed competitive bidding process, it is not necessary to post a new Form 470 in subsequent funding years until a new contract is required.
Applicants must wait at least 28 days from the date the Form 470 is certified before closing the competitive bidding process. Changes to the Form 470 beyond the allowable changes require applicants to wait 28 days from the date of the change before closing the competitive bidding process.
The entity filing a Form 470 can issue a RFP in addition to the Form 470. In general, an RFP is a formal bidding document that describes the project and requested services in sufficient detail so that potential bidders understand the scope, location and any other requirements. However, we USAC uses "RFP" or "RFP document" generically to refer to any bidding document that describes your project and requested services in more detail than in the fields provided on the Form 470.
E-rate Program rules do not require applicants to issue an RFP. Generally, you are not required to issue an RFP unless your state or local procurement rules or regulations require you to do so. However, if you have issued or will issue an RFP, you must upload that document to EPC.
There are additional competitive bidding requirement for leased dark fiber and self-provisioned networks.
Please note that an RFP is required in EPC if you are requesting the options for:
Leased Dark Fiber and Leased Lit Fiber
Self-Provisioned Networks and Services Provided over Third-Party Networks
Maintenance & Operations
Commercially available business class Internet access services are exempt from the Form 470 posting requirement if they cost $3,600 or less annually per entity, including a one-time cost such as installation; provide bandwidth speeds of at least 100 Mbps downstream and 10 Mbps upstream; provide basic conduit access to the Internet as those required minimum speeds.
OPEN AND FAIR COMPETITIVE BID PROCESS
The entity filing the Form 470 must ensure that the competitive bidding process is open and fair:
All bidders must be treated the same
No bidder can have advance knowledge of the project information
There are no secrets in the process - such as information shared with one bidder but not with others.
All bidders need to know what is required of them
With limited exceptions, service providers and potential service providers cannot give gifts to applicants
The value of free service (price reductions, promotional offers, free products) generally must be deducted from the pre-discount cost of funding requests.
Once the competitive bidding process has closed, the entity that filed the FCC Form 470 must evaluate the bids received and select the service provider(s) that will provide the requested services as described further in the next step, Selecting Service Providers.
Funding Commitment Update 8.7.19
IMESD clients currently have FCDLs for 104 of 130 applications submitted for the 2019-20 Funding Year. Statistics show that USAC is concentrating on processing Category 1 applications and IMESD application submissions are following course with 64% Category 1 and 36% Category 2 funding commitments worth $3.5M combined.
Of the remaining 26 applications, we have responded to PIA inquiries on 25, while we have yet to receive any inquiries on 1 of the certified applications.
The future of Category 2
On July 9, 2019, the FCC released the Notice of Proposed Rule making (NPRM) on the future of Category Two budgets for FY2020 and beyond. The FCC stated “…our experience over the past few years suggests that these budgets have resulted in a broader distribution of funding that is more equitable and more predictable for schools and libraries. We also see clear improvements in the way in which funding for internal connections has been administered in the five-year period since adoption of the category two budget approach. Therefore, we now propose to make the category two budget approach permanent and seek comment on potential modifications that could simplify the budgets, decrease the administrative burden of applying for category two services, and thereby speed the deployment of Wi-Fi in schools and libraries across the country….”
The FCC proposes amending the rules to make permanent category two budget approach for all
The FCC proposes and seeks comment on ways to improve the category two budget
The FCC seeks comment on how to best transition from this five-year cycle
While the FCC proposes to maintain the current existing budget multipliers for schools and libraries, they also want to seek comment on whether to change the per student or per-square foot budget multipliers, particularly for entities that may have participated at a lower rate or that may face higher costs for internal connections;
The FCC seeks comment on moving from per-school or per-library budget to a per-district or per-system budget.
The FCC seeks comment if there are additional services that they should consider to make eligible for category two funding
Comment Date: (30 days after date of publication in the Federal Register)
Reply Comment Date: (45 days after date of publication in the Federal Register)
Funding Commitment Update 2019-20
IMESD clients currently have FCDLs for 80 of 130 applications submitted for the 2019-20 Funding Year. Statistics show that USAC is concentrating on processing Category 1 applications and IMESD application submissions are following course with 74% Category 1 and 26% Category 2 funding commitments worth $1.7M combined.
Of the remaining 50 applications, we have responded to PIA inquiries on 29, while we have yet to receive any inquiries on 21 of the certified applications.
As the 2018-19 Funding Year is winding down and 2019-20 Funding Commitments continue to roll in for our clients, it’s time to start the process all over again for 2020-21. As you can see, E-rate truly is a year round process!
Just released - IMESD’s 2020-21 Application Process. Use this to guide you through the four basic steps of E-rate:
Competitive Bidding Application Funding * Reimbursement.
On the left, you will notice two black “arrows”. The top row represents some of the tasks that the Applicant (you) are responsible for and when we are to complete these tasks. The bottom row represents some of the tasks that InterMountain E-rate is responsible for.
In the lavender box at the bottom are some commonly used terms in the world of E-Rate. You can print this PDF from the list of Resources below.
IMESD’s 2020-21 Application Process
Oregon.gov Program Overview- external link
Education SuperHighway (state and national data)- external link
Eligible Services Overview (USAC external link)