Let’s Begin E-rate Funding Year 2021!

November 3, 2020

I’m so excited to announce the beginning of the FY 2021 E-rate application process!   Below is a summary of the changes you can expect for FY 2021, important reminders, and a helpful “what to do by what date” chart at the bottom.

1)  No Changes to Eligible Services Expected or Form 470 Service Selections

– Although the FY 2021 Eligible Services List has not yet been released, I do not expect any changes.

– You may recall that in recent years the Form 470 contained confusing drop-down options for applicants seeking Internet Access services.  Unfortunately, the FY 2021 Form 470 drop downs have not changed.  The FCC is expected to make form changes for FY 2022, but for FY 2021, 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”
• Entire Form 470 Service Selection drop down cheat sheet is available at:  http://e-ratepa.org/wp-content/uploads/2019/11/Internet-Access-Form-470-Filing-Cheat-Sheet.pdf.

2)  Changes for Category 2 Budgets and Equipment Transfers

– Beginning in Funding Year 2021, the new Category 2 rules go into effect and all applicants will start fresh with a new, 5-year C2 pre-discount budget.  A summary of the changes and a list containing each applicant’s 5-year, C2 pre-discount budget under the new rules is available at:  http://e-ratepa.org/?p=32602.   Most importantly, C2 budgets are calculated at the school district or library system level, with no more individual school or library building C2 budget caps.  Although you will still be required to list on the Form 471 what equipment will be used by what school or library, you may transfer equipment (for any funding year) anytime after July 1, 2021.  Please begin to consider your internal connections needs for each building so you’re prepared to release your 470/RFP or PEPPM mini-bid before Thanksgiving.

3)  Form 471 Filing Window Dates

– USAC has not yet announced the official Form 471 Filing Window dates, but indicated recently that they expect the window to open around mid January and close in mid/late March).  For a suggested FY 2021 bidding/filing timeline, see the chart at the bottom of this message.

4)  Updating Entity Profiles the “Administrative Window”

– The “Administrative Window” is the window before the 471 window, during which time schools usually update their enrollment and NSLP (or CEP%) data in each school’s EPC profile.  The Admin Window opened October 16 and is expected to close the first week in January.  Typically I receive draft enrollment/NSLP (CEP%) data from PDE’s Bureau of Food and Nutrition in mid December and distribute it to schools to use as they update their EPC profiles.  However, I’m hearing from numerous schools that families aren’t returning NSLP forms this year and you’re understandably concerned about the impact on E-rate discounts.  For this reason, I ask that you do not update your EPC profiles until I can obtain clear guidance from PDE and USAC about which datasets you should/can use.  I’ll likely advise that schools use last year’s data unless your current data accurately reflects your poverty level and provides a higher discount than last year, but until then, please stay tuned…

5)  New School “SubTypes” in EPC

– USAC has introduced three new school “subtypes” in EPC.  Some schools, particularly IUs, will want to be certain that the program facilities at which they provide instruction are listed in their EPC portals and are classified as General Use Schools.  This way, they could potentially be eligible for the minimum $25,000 C2 budget.

• General Use School:  Offers instruction to students drawn from other schools, and student counts can change throughout the year.  Some examples of general-use schools are magnet schools, special education units, computer centers, or career centers.
• Detention Center:  Treated in the same way as a juvenile justice facility.

• Swing School:  A building that temporarily houses students from a school may need to be relocated due to closure, construction, or a revamping of their technological infrastructure at the school.   Note:   A swing school differs from an annex.  An annex is considered a part of the school it shares an entity number with rather than a temporary relocation site, while a swing space – although associated with a school – is part of the school district where the school is located and is considered a school in its own right with its own entity number.

6)  Be Sure to Add Bid Due Date to All Form 470’s
– Last year USAC clarified 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 28^th 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, on XX/XX/XXXX.  We reserve the right to reject late-submitted proposals.  Proposals must be e-mailed to the Form 470 contact unless otherwise noted.”  Just be sure that the date you fill in at XX/XX/XXXX is at least 29 days after the date you post your Form 470.

7)  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=32690) sent to the listserve a few weeks ago that provides a list of all FY 2020 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 2021.  Please note that this data was taken directly from your FY 2020 From 471 submissions.  If you listed the wrong contract expiration date on last year’s application, be sure to enter the accurate date on the FY 2021 application (and be prepared to show PIA your contract as you will likely receive questions on why the date changed).

8)  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 2021, 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.

9)  Changes to FY 2021 Form 471

– The FY 2021 Form 471 is expected to include form improvements (thanks to stakeholder feedback), such as:

• Easier navigation from FRN to FRN Line Items (previously it wasn’t intuitive that you had to click on the FRN Number to get to the FRN Line Item page)
• Ability to easily access narrative text box while creating FRN Line Items (there will not be separate FRN Line Item narrative boxes)
• Will no longer request bandwidth questions when requesting Taxes/Fees

10)  Set Up in One Portal Yet?

– In July, USAC introduced a new One Portal Log-In System that houses both EPC and BEAR systems and requires two-authentication factors to log-in (your EPC password and a 6-digit code that is sent either via e-mail or text).  To enter the BEAR System, both authentication factors are required, in addition to a BEAR PIN.  If you haven’t yet set up your One Portal account, please do so now before you have to file any official forms.  A One Portal Set-Up Guide is available at:  http://e-ratepa.org/wp-content/uploads/2020/07/One-Portal-MFA-Set-Up-Guide.pdf.  If you don’t have a BEAR PIN, you’ll also want to follow the BEAR PIN Request Guide to make the request.

11)  Why Were PA Applicants Denied E-rate Funding in FY 2020?

– I think it’s important to do a “post mortem” after each funding year to learn from our mistakes.  In all, FY 2020 was a pretty successful year in terms of funding approvals but there’s always room for improvement.  Here are the stats related to our funding denials:

• Only 10 FRNs denied = .3%
• 3 libraries, 3 districts, 3 nonpublic schools
• 1/2 used consultants
• 4 Category 1 Denials:  3 redundant internet, 1 price of eligible services not most heavily weighted factor
• 6 Category 2 Denials:  2 requested ineligible firewall features, 1 470 for MIBS didn’t provide enough details, 1 requested ineligible product, 1 exceeded C2 budget (and didn’t reduce it to come into compliance), 1 contract signed before 28-day waiting period expired

– I also know that a few applicants forgot to submit a Form 471 and those fell into 2 categories – turnover in E-rate staff and applicant mistakenly thought that a multi-year contract meant a multi-year funding commitment.

12)  Upcoming E-rate Training

– I will be conducting several E-rate training webinars in the coming weeks (listed below) and registration will be announced shortly.  (If you missed one of the previous beginners or veteran training workshops, visit http://e-ratepa.org/?page_id=745 for copies of the presentations.)

• Category 1 Eligibility & Form 470 Bidding
• Category 2 Eligibility & Bidding Public Schools (will include PEPPM mini-bid option)
• Category 2 Eligibility & Bidding Non-Pubs/Libraries

– USAC’s fall training workshops are being held this week, beginning tomorrow.  Details and registration information is at:  https://apps.usac.org/sl/tools/news-briefs/preview.aspx?id=979.

13)  Funding Year 2021 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 – early January.  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	February/early March
Earliest applicants can purchase C2 equipment	April 1, 2021
Funding Commitment Letters (FCDLs) issued	End of April – Sept 1 (goal)
File Form 486	Upon receipt of FCDLs
Earliest that FY 2021 BEARs or SPIs can be submitted to USAC	July 1, 2021

Julie Tritt Schell

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