ECF Update – August 2022
August 29, 2022
Attached: PA ECF FRN Status as of Aug 26 2022
As of August 26, PA’s schools and libraries have received more than $103 million in Emergency Connectivity Fund (ECF) funding commitments. A complete analysis of all PA FRNs, their funding status, funding amount, and disbursement amount (as of August 26, 2022) is included in the attached spreadsheet. I’ve also included a column that shows the reimbursement deadline, and the funding year eligible service/equipment delivery dates.
ECF Window 3 Funding Cut-Off?
More than $2.8 billion was requested nationwide in ECF funding in Window 3, with only approximately $1.5 billion available. This means that applications will be prioritized to fund schools and libraries with the highest economic need first, with a preference for schools and libraries located in rural areas. Currently, USAC is funding ECF Window 3 applications to applicants at the 85% level which are 80% E-rate discount applicants located in rural areas. This does not mean that you will only receive a percentage of your funding; it is simply a way for USAC to determine order of funding priority. No final determination has been made where funding will be cut off, which is good news. See next item for a way you can help.
Return Unused/Unneeded ECF Funding Commitments
Out of the $103 million approved for PA applications, only $29,424,465 has been disbursed thus far. If you do not need all of your ECF commitment, please file a Post Commitment Request in the ECF Portal to decommit the funds so that more applications can be funded in ECF Window 3. To do this, follow these steps: Log into ECF Portal > My Forms and Requests > Click on the ECF 471 Application Number > Related Actions > Create a Post-Commitment Request.
Can You Seek Reimbursement if Hotspots/Internet Not Being Used?
Some schools have asked whether they can seek ECF reimbursements if their ECF-funded hotspots/internet access are not used in a particular month. Such situations are occurring due to summer recess and return to in-person classes.
We have asked USAC and the FCC several times whether schools can continue to seek ECF reimbursement when there has been no data usage for the month and they will only point us back to the ECF FAQ 9.12 which states (the underlines are mine, with my suggestions below):
Q: What must applicants or service providers, who agree to invoice on behalf of applicants, do to be compliant with the non-usage certification?
A: The Commission declined to adopt specific non-usage rules for the ECF Program. Instead, applicants and service providers are required to certify on the request for reimbursement that they are not willfully or knowingly requesting reimbursement for services and equipment that are not being used. While the ECF program only funds equipment and services that are in use, there may be certain circumstances (e.g., during a school’s summer break, sick days) where the services would still be eligible for ECF support. ECF participants should take reasonable actions to monitor and track the usage of equipment and services that are purchased and used through the ECF program. For example, the Report and Order suggested that applicants could ask their service providers to provide monthly reports or other information on data use as one way to comply with the certification. ECF participants can take other reasonable steps, such as ensuring a hotspot device is activated. ECF participants should be prepared to explain what actions were taken, if asked how they complied with the non-usage certification during an audit or other post-commitment review.
** Julie suggestions: If you’re in this situation, I suggest taking (and documenting) these actions in order to explain to an auditor what steps you took to comply with the non-usage certification:
- Send a reminder message to all students/faculty that have the hotspots stating that if they are not being used, they must be returned to the school.
- If different students/faculty need the hotspots, it’s fine to transfer them but you must update your asset inventory to track where they are and when they were loaned. If no other students/faculty have unmet needs for the returned hotspots, you should terminate the service and do not invoice USAC for the remaining months.
- The FAQs suggest that you can ask for usage reports to know when the hotspots aren’t being used, but this isn’t a requirement. If you’re not tracking usage, at a minimum, be sure that the hotspot is activated as suggested in the FCC’s FAQ.
- Finally, don’t forget that the hotspots can be used for completing homework when students/teachers don’t have reliable internet (school buses, home, babysitter’s house, etc.), not just when classes are occurring remotely. You may want to remind recipient families of this allowance.
Submitting ECF Form 472 BEAR Invoices to USAC
If you opted to pay the vendor in full and then seek ECF reimbursement using the ECF BEAR Form 472 (see Column J, attached), don’t forget to file this form by the required deadline(s). For ECF Windows 1 and 2, the invoicing deadline is August 29, 2023. For ECF Window 3, the invoicing deadline is February 29, 2024. A Form 472 BEAR Filing Guide is available at: http://e-ratepa.org/wp-content/uploads/2020/03/ECF-Form-472-BEAR-Reimbursement-Filing-Guide-updated-June-2022.pdf. Don’t forget to upload both the vendor invoice AND proof of delivery or shipping, and be certain your SAM.gov account is active and up to date.
Languishing BEARs
If your BEAR was submitted more than 30 days ago and you have not received any inquiries/requests for additional information, and you don’t have any post-commitment requests pending, call USAC’s ECF Customer Service Center (CSC) at (800) 234-9781 Monday – Friday from 8 a.m. to 8 p.m. ET, or submit a case in their ECF Portal, and ask for your BEAR to be escalated. Two weeks ago, I compiled and sent to USAC a list of PA BEARs that appear to be languishing with no PIA contact or post-commitment requests pending to try to help move these along.
Is Your SAM.gov Registration Up-To-Date?
The biggest reason USAC cites for the delays in BEAR/SPI processing, besides applicants and vendors not uploading copies of their vendor invoices and proof of shipment, is that their SAM.gov accounts are not up-to-date. Please check to make sure that your SAM.gov account’s registration has not expired (they must be renewed every 12 months). Also, in April 2022, the FCC announced the transition from the Data Universal Numbering System (DUNS) number to the Unique Entity Identifier (UEI) number that is generated by SAM.gov. At this time, most organizations that participate and receive ECF payments already are registered with SAM.gov and have already been issued a UEI number. If your organization does not have an active SAM.gov account, you should begin this process right away as you will also be required to obtain an UEI number which can take some time. If you need help with your SAM.gov registration, see http://e-ratepa.org/wp-content/uploads/2020/03/SAM.gov-Assistance.pdf or contact the ECF Customer Service Center (CSC) at (800) 234-9781.
Changing Equipment/Service Providers
Several schools and libraries have decided to change the manufacturer, model and/or service provider of their ECF-funded equipment due to supply chain issues, or other reasons. If you would like to make such modifications to your application, it must be done through a Post-Commitment Request (PCR) in EPC. Here’s where to find this module: Log into ECF Portal > My Forms and Requests > Click on the ECF 471 Application Number > Related Actions > Create a Post-Commitment Request. It usually takes just a few weeks to obtain the approval. If your post-commitment request was submitted more than 30 days ago and you have not received any inquiries/requests for additional information, call USAC’s ECF Customer Service Center (CSC) at (800) 234-9781 Monday – Friday from 8 a.m. to 8 p.m. ET, or submit a case in their ECF Portal, and ask for your PCR to be escalated.
If you have any ECF questions, please let me know, or contact the ECF Customer Service Center (CSC) at (800) 234-9781 or create a Customer Case in your ECF portal.
Happy end of summer, everyone!
– Julie
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org