E-rate Funding Year 2020 Kicks Off!

November 11, 2019

I’m so excited to announce that the FY 2020 application process is officially underway!  Below is a summary of the changes you can expect for FY 2020 and a helpful “what to do by what date” chart at the bottom.

No Changes to Category 1

– Although the FY 2020 Eligible Services List has not yet been released, I do not expect any changes to Category 1 for FY 2020.

Changes Coming for Category 2 – No Details Yet

– The FCC has not released their much-anticipated Category 2 Order that will outline what C2 budgets everyone will have for FY 2020 and beyond, as well as any other changes.  I am very hopeful that we will see the Order before Thanksgiving and as soon as it’s released, I’ll prepare a detailed summary for the listserve and schedule a webinar.  In the meantime, please begin to consider your internal connections needs for each building so you’re prepared to release your 470/RFP or PEPPM mini-bid right away.

Form 471 Filing Window Dates

– USAC has not yet announced the official Form 471 Window dates, but has stated they expect the dates to be similar last year (early January – mid/late March).  For a suggested FY 2020 bidding/filing timeline, see the chart at the bottom of this message.

FY 2020 “Administrative Window”

– The “Administrative Window” is the window before the 471 window, during which time schools must update their enrollment and NSLP (or CEP%) data in each school’s EPC profile.  The Admin Window is currently open and is expected to close the first week in January.  Like last year, I expect PDE’s Bureau of Food and Nutrition will provide us with the “unofficial” enrollment and NSLP (CEP%) data that each school has entered into the PEARS system during the month of October.  I will then send to you this unofficial PDE data set by mid-December and you’ll then have a few weeks to update your schools’ EPC profiles while the Admin Window is still open.  If you want to update their profiles now, you certainly may, but it will be much easier if you wait until I send you the data in December (which will then likely match what PIA uses to review your Form 471 discount data information).

FY 2020 Form 470 Category 1 Service Description Drop Down Options

– You may recall that in recent years the Form 470 contained confusing drop-down options for applicants seeking Internet Access services.  Unfortunately, the FY 2020 Form 470 drop downs HAVE NOT CHANGED.  The FCC is currently seeking comments on how to improve the Form 470 application for both C1 and C2 for FY 2021, so we are optimistic that FY 2020 is the last year with the current confusing service descriptions.  But for FY 2020, here is how you should file for Internet:

  • If you want Internet delivered over Fiber Transport, you must select “Leased Lit Fiber with or without Internet” and then explain in the narrative that you’re seeking Internet and at what bandwidth level(s).
  • If you are seeking Internet via a different mode of transport (cable modem, DSL, etc.), then you must select “Internet Access and Transport Bundled – Non-Fiber

!!! Important: Add Bid Due Date to All Form 470’s !!!
– USAC has recently taken the position that if your Form 470 or RFP doesn’t state a deadline for vendors to submit proposals, you must consider all bids received up until the date you conduct your bid evaluation.  This is different from previous guidance which was that vendors should consider the 28th day after the 470 is posted as the default deadline to submit bids.  Therefore, it is extremely important that you state a deadline for vendors to submit proposals (which, of course, must be on or after the 28-day waiting period).  I suggest the following language:

“Deadline for vendor proposals is 9:00 am Eastern, 29 days after the date this Form 470 is posted.  We reserve the right to reject late-submitted proposals.  Proposals must be e-mailed to the Form 470 contact unless otherwise noted.”

Unsure Whether You Need to Rebid Category 1 Services This Year?

– In order to remind you of the status of your current Category 1 contracts (telecom and Internet), please see this message (http://e-ratepa.org/?p=31899) sent to the listserve a few weeks ago that provides a list of all FY 2019 C1 FRNs, and the expiration dates of those contracts.  In the spreadsheet there’s an additional column – “Julie’s Rebidding Status Notes” – explaining whether I think the service must be rebid for FY 2020.  Please note that this data was taken directly from your FY 2019 From 471 submissions.

Extending an Existing Contract?
– If your original contract included (finite, not open-ended) voluntary extensions and you wish to exercise one of those extensions for FY 2020, be certain to notify the vendor in writing of that decision before the Form 471 is filed.  USAC will ask for a copy of that written notification during PIA review, so be sure to retain evidence of that notification.

New Changes to USAC Website
– On Friday, USAC announced major changes to their website, so most of your bookmarks will no longer work.   While the EPC log-in is easy to find, most other resources are hidden.  The Reference Area is gone, but many of those subject topics are now in an FAQ page (under Learn) at: https://www.usac.org/e-rate/learn/faqs/all-topics/.  Also, the best quasi site-map I can find is available by holding your cursor over the word “E-rate” in to top toolbar.

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Upcoming Webinars

I will be conducting several E-rate training webinars in the coming weeks and registration will be announced shortly.

  • 90-minute E-rate for Beginners
  • Form 470 Filing – Category 1
  • Category 2 Changes (scheduled after the FCC’s C2 Order is released)
  • Category 2 Bidding Options/Requirements for Public Schools (scheduled after the FCC’s C2 Order is released)
  • Category 2 Bidding Options/Requirements for Non-Public Schools and Libraries (scheduled after the FCC’s C2 Order is released)

Funding Year 2020 Suggested Timeline:

Step: Timeline:
Post Form 470 in EPC to competitively bid all new/expiring contracts (unless using the PEPPM mini-bid option for C2) Now – early December (by Thanksgiving, if possible!)
Update enrollment/NSLP data in school EPC profiles Now – January 7.  But consider waiting for the unofficial PDE data to be available in mid-December
Conduct bid evaluation Early January
Obtain school board approval January or February board meeting (no later)
Sign vendor contracts By End of February
Create Contract Records in EPC/upload signed contracts Late February/Early March
Submit Form 471 Early March
Earliest applicants can purchase C2 equipment April 1, 2020
Funding Commitment Letters (FCDLs) issued End of April – Sept 1 (goal)
File Form 486 Upon receipt of FCDLs
Earliest that FY 2020 BEARs or SPIs can be submitted to USAC July 1, 2020
 

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Julie Tritt Schell

Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org

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