ECF Audits and Other Updates – February 2023
February 17, 2023
Attached: PA ECF FRN Status as of Feb 16 2023
As of February 16, 2023, PA’s schools and libraries have received more than $111 million in Emergency Connectivity Fund (ECF) funding commitments from Windows 1, 2 and 3. A complete analysis of all PA FRNs, their funding status, funding amount, and disbursement amount 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 Audits Have Begun
Several applicants have been selected for ECF audits and based on their feedback, we now have a clear roadmap of what’s required. Unlike E-rate audits, ECF audits are conducted entirely by the FCC, using the audit firm Censeo. If selected for an audit, the auditee will receive a request to produce the following documentation:
- The asset inventory for ECF-reimbursed equipment and services (in some cases, auditors are conducting on-site audits where the have required schools and libraries to produce randomly-selected equipment)
- Records of payment for ECF-reimbursed equipment and services
- Documentation of unmet needs assessment (e.g., returned surveys, signed unmet needs certifications, etc.)
- If an applicant replaced old equipment with ECF-reimbursed equipment, documentation of how the applicant determined the existing equipment was inadequate
- ECF bid documentation (if bidding was required by state, local or other laws or requirements)
- ECF-related invoices
The auditors also will require the completion of their ECF Audit Survey to confirm compliance with program rules. The survey asks:
- Q1. Please describe how you determined the unmet need for your school, library, or consortium (i.e., the number of students, school staff, and/or library patrons who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning)
- Q2. Please explain what measures and actions you took to track and monitor the usage of the audited equipment/services.
- Q3. Please explain the process you went through to procure these devices/services and other equipment being audited, including information related to how you determined the pricing of the audited devices/services were reasonable and that the devices/services met the remote learning requirements of your students, school staff, or library patrons with unmet needs.
- Q4. Please describe the methods or internal controls that your organization employed to restrict the use of connected devices for educational purposes by eligible users (students, school staff, or library patrons).
If you haven’t done so already, be sure to review these questions with your staff and ensure that you are prepared for an audit.
ECF Window 3 Funding Cut-Off?
Because more funding was requested in Window 3 than is remaining in the ECF appropriation, USAC is awarding funding to applications for schools and libraries with the highest economic need first, with a priority for those in rural areas. Currently, USAC is funding ECF Window 3 applications to applicants at the 65% level which are 60% 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 $111 million approved for PA applications, only $49,345,727 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. The FCC has provided guidance via FAQs and the ECF audit survey, which I have posted here, along with my recommendations: http://e-ratepa.org/wp-content/uploads/2020/03/Guidance-for-Non-Usage.pdf.
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. A sam.gov user guide is available at: http://e-ratepa.org/wp-content/uploads/2020/03/SAM.gov-Assistance.pdf, or assistance is available at: https://www.fsd.gov/gsafsd_sp or through 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. 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 Presidents’ Day Weekend, everyone!
– Julie
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org