ECF Unmet Needs Documentation Guidance/Examples

August 17, 2021

Attached: Unmet Needs Library Patron Certification

Attached: Unmet Needs Teacher Certification

Attached:  Unmet Needs Parent Certification

The FCC allowed schools and libraries to use ‘reasonable estimates’ when determining what to request on their ECF Form 471, but the rules are different at the ECF reimbursement stage.  At this stage – whether you or your vendor are invoicing ECF – you must have documentation of unmet need for each student, teacher or library patron that is receiving ECF-supported Connected Devices and/or internet access.  We are conferring with the FCC to gather official guidance related to the documentation requirements, but because so many of you already have purchased and will be handing out devices and wi-fi hotspots in the next few days, I want to provide you with my best educated, yet unofficial advice related to this documentation.

Also, I’ve created the attached sample Unmet Needs Certification Statements for parents, teachers and library patrons that you can modify to meet your specific needs or incorporate into your back-to-school data-gathering requirements.

Schools:  Generally, a school must have documentation of unmet need to support their ECF reimbursement request (with two exceptions as listed below).    The evidence could be:

a) A signed statement certifying the unmet need of the student or teacher.  The statement must be signed by an authorized person (parent, legal guardian in the case of a student, or for devices assigned to teachers, the teachers’ signature).  Sample statements are attached.  Or,
b) A survey response stating the student or teacher has an unmet need.  If a school already conducted a survey, then a signed statement is not mandatory but is recommended as a best practice.

Libraries: Libraries are required to distribute an Eligible Use Policy and obtain a signed statement of unmet need from each library patron that checks-out a connected device or Wi-Fi hotspot.  Attached is a sample certification statement that can be used or language that can be incorporated into your online checkout systems.

  • Exception #1:  A school that has a technical restriction that prevents a student or teacher from accessing the school’s remote learning curriculum while off-campus unless the student or teacher uses a school-owned Connected Device may be able to rely on this technical restriction as the unmet need documentation on behalf of each student and teacher that receives an ECF-funded Connected Device.  We are seeking guidance from the FCC whether this is sufficient or whether the school will still be required to obtain signed statement of unmet needs from students/teachers.
  • Exception #2:  If a school is requesting reimbursement for Wi-Fi on buses, they are not required to obtain signed statement of unmet need from students as the lack of internet on the school bus where learning is occurring is a sufficient explanation.

Asset Inventory Reminder:  When the device is distributed, the school or library must record in an asset inventory the following required elements:

- Connected Devices -

✔  Device type (i.e., laptop, tablet, mobile hotspot, modem/router)

✔  Equipment make and model

✔  Serial number

✔  Name of the person to whom the device was provided

✔  Dates the device or other piece of equipment was loaned out/returned to the school or library

✔  If applicable, the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged

✔  For equipment located in school buses or bookmobiles, inventory also must include the name of the school or library employee responsible for that device; and the dates the device was in service (in addition to the device type, make/model and serial number).

- Services -

✔  Type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless)

✔  Service plan details, including upload and download speeds and monthly data cap

✔  Name(s) of the person(s) to whom the service was provide

✔  For fixed broadband service only, such as cable modem internet, the service address and installation date of service and the last date of service

** Unmet Need Definition:  When a student does not have a sufficient COMPUTER and/or INTERNET ACCESS for remote learning when not physically attending school.

  • Sufficient Computer refers to a laptop, desktop or tablet that the student can use off-campus whenever they need to complete homework or attend online classes.  A smartphone is not considered a computer.
  • Sufficient Internet access refers to Internet connectivity that is reliable and enables the student to receive and send electronic information for homework and online classes.
  • Remote learning includes off-campus educational activities while the student is not physically in a school building.  Homework and virtual online classes are both considered remote learning.

If you have any questions, please let me know.  As soon as we receive official guidance on these issues, I’ll post it to the listserve.

– Julie

Julie Tritt Schell

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

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