Emergency Connectivity Fund Reimbursement Update and Reminders
December 9, 2021
~ Be sure to include proof of delivery with BEARs ~
Funding Commitment Update
In all, PA schools and libraries requested $132 million from the federal Emergency Connectivity Fund (ECF). To date, 5 funding waves have been issued, committing $58,496,641. Waves are released every two weeks and Wave 6 is expected to be issued in the next few days. No funding commitments have been issued yet for applications submitted in the second ECF application window, nor does it appear that any commitments have been issued for network build-out to unserved homes.
FCC Sets Uniform Reimbursement Deadline for All ECF FY 2021 Applications
The FCC’s original ECF Order stated that the invoice deadline for equipment delivered prior to the Form 471 submission date was 60 days from the FCDL date to submit reimbursement invoices. The State E-rate Coordinators’ Alliance (SECA) sought an emergency waiver from the FCC to make August 29, 2022 the uniform reimbursement deadline for all ECF FY 2021 funding requests, and last week the FCC issued an Order, granting SECA’s request. Therefore, the invoice filing deadline for all FY 2021 ECF funding requests is now 60 days from the date of the funding commitment decision letter (FCDL); a revised funding commitment decision letter (RFCDL) approving a post-commitment change or a successful appeal of previously denied or reduced funding; or August 29, 2022, whichever is later. The only exception to this deadline will be for network build-out FRNs which will have 60 days from the last date to receive service (which is 1 year from the FCDL date).
Libraries Being Asked for Copies of Acceptable Use Policies
We have recently heard that some libraries are being asked during the ECF invoicing (BEAR) review process to submit copies of the AUPs that they’re distributing to patrons when ECF-funded laptops/tablets and hotspots are being checked out. AUPs are required to be distributed to these patrons, along with obtaining a signed Statement of Unmet Need. Be sure to have these policies on-hand as you submit your ECF BEARs.
Proof of Equipment Shipping or Delivery Date
In order to ensure that equipment was delivered after July 1, 2021, USAC requires that all reimbursement requests (BEARs or SPIs) include a copy of the vendor invoice – and proof of the shipping or delivery date. If a vendor invoice does not include a delivery or shipped date, supporting documentation that demonstrates that the equipment or services have been delivered or shipped (e.g., a packing slip or other proof of delivery) can be uploaded with the BEAR or SPI. The supporting documentation must be consistent with the timing of the delivery date that was listed on the BEAR or SPI. Note: I think this is what’s causing the biggest delay in ECF BEAR processing. If you already submitted your BEAR and the vendor invoice didn’t contain this information, find your ECF BEAR in the ECF Portal, and use the “Contact Reviewer” button in the top right corner of the page and upload proof of the equipment delivery or shipping date. If you need help finding your BEAR in the ECF Portal, see screenshots below.
Also, be sure that the make and model of the equipment and services listed on the vendor invoice matches what is listed on the ECF Form 471. For lengthier invoice documents, USAC recommends including a ‘cover letter’ with the vendor invoice document or as a separate attachment that identifies where the listed equipment and services, the delivery date, cost breakdowns, and service start and end dates can be found within the vendor invoice. This will aid in expediting the review process.
BEAR/SPI Invoicing/Payment Process Explained
After the applicant has submitted the ECF BEAR or the vendor has submitted the ECF SPI, USAC will review the request (along with the vendor invoice) to ensure it has met ECF rules. Once USAC has completed its review of a request for reimbursement, USAC will send an e-mail ECF Reimbursement Decision Notification through the ECF Portal to all users with access to the request for reimbursement. USAC issues this notification when it has sent the payment batch to the FCC for processing (this is a different procedure than is used for E-rate reimbursements, because ECF is federally-appropriated funding, not USF funding). It can take up to five business days for the FCC to process the payment with the U.S. Treasury, and for the funds to be disbursed into the bank account on file with SAM.gov. The U.S. Treasury will then issue a notification to the contacts listed in the applicant or service provider’s SAM.gov account when amounts are deposited.
Where to Find the Status of Your ECF Form 472 BEAR
The ECF Portal will show the status of the reimbursement request, although not in very granular terms. To find the ECF reimbursement status, follow these steps:
1. Log into One Portal at: https://forms.universalservice.org/portal/login and select Emergency Connectivity Fund (ECF) – last option on the list:
2. From ECF Dashboard, click “My Forms and Requests”
3. Then select “FCC Form 472” from the drop-down list:
4. This page will show all of the BEARs submitted to date and the 5th column will show each BEAR’s stage (Incomplete, Certified, Processed). To see the actual BEAR Status/Decision, click on the hyper-linked Form 472 BEAR Number:
5. Then click on “Reimbursement Request Line Items”:
6. The BEAR Reimbursement Status will be showing to the far right (Pending, Approved, Partially-Approved, Denied):
7. To determine why a reimbursement was modified, refer to the Communications Tab.
Where to Find Detailed ECF Application and Reimbursement Data for All Applications
USAC maintains a vast amount of E-rate and ECF-related data in their Open Data platform. The ECF-specific data can be found at: https://www.emergencyconnectivityfund.org/open-data/.
If you have any questions, please don’t hesitate to contact me!
– Julie
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org