FCC Expands Ways to Determine Unmet Needs for ECF

July 22, 2021

Today, the FCC provided several very positive clarifications/changes related to the Emergency Connectivity Fund (ECF).  They are:

1. Expansion of Ways to Determine Unmet Needs:  To determine “unmet need” for the Form 471 application, the FCC has clarified that applicants are not required to rely on student/family surveys and may also consider publicly available information, including but not limited to free and reduced lunch participation, census data, and broadband maps.  This is a wonderful development and hopefully will encourage more schools and libraries to apply.  Note that applicants, however, should be able to demonstrate proof of unmet need of the students/teachers/library patrons at the ECF reimbursement stage.  To do this, I strongly recommend that schools obtain a signed statement of need, either online or on paper, when the devices are distributed (libraries already have this requirement).

Links to Publicly Available Data:  Below are links to the 2019 NSLP Participation for PA schools and U.S. Census data.  (Note:  The census data shows the percentage of households that lack internet and/or computers entirely, so these percentages are likely much lower than your actual unmet need which is defined as students that lack access to a computer (one per student) and/or Internet access that is sufficient to participate in two-way online learning while off campus.  The data also is not specific to households with K-12 students.)  The data was downloaded from the NTIA website, filtered for PA, and uploaded to the www.e-ratepa.org website under the ECF tab.  Here are the direct links:

>    2019 NSLP Eligibility for PA Schools (the last year that NSLP participation was based on poverty)

>    Census Broadband & Device Needs Data by School District

>    Census Broadband & Device Needs Data by County

>    Census Broadband & Device Needs Data by Census Tract

2. Invoice Deadline for Equipment Extended:  The invoice deadline for equipment and other non-recurring services funding requests has been changed to 60 days from the last date to receive equipment.  Because the last date to receive equipment for ECF Window 1 will generally be June 30, 2022, the invoicing deadline for both recurring and non-recurring FRNs will now be August 29, 2022.  I strongly encourage all applicants to not modify the 7/1/2021 – 6/30/2022 dates on the ECF Form 471.  Why?  If you list an earlier Service End Date, the system will then give you only 60 days from that date to submit a reimbursement form.

3. Clarification of Ordering Date Rules:  The ECF rules contained confusing language related to when applicants must place orders for ECF eligible equipment/services so the FCC clarified that applicants are not required to actually have orders placed at the time they submit their Form 471.

If you have any questions about these clarifications or ECF, please let me know!

– Julie

Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o

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