ECF to End June 2024 – FCC Extends Certain Deadlines

May 15, 2023

Attached: FCC ECF Extension – Public Notice

Attached: All PA Data as of May 15 2023

The FCC has announced that as a result of the official expiration of the COVID-19 public health emergency, the Emergency Connectivity Fund (ECF) will sunset on June 30, 2024.  In doing so, they also extended certain ECF service delivery deadlines and, by extension, their invoicing deadlines, and stated they do not intend to grant invoice deadline extensions.  Please review closely the following summary of the adjusted deadlines, noting that services, equipment and new construction-related FRNs are treated differently.

New Service Delivery Deadlines:

  • Applicants in Windows 1 and 2 (FY 2021) that received an FCDL or RFCDL approving support for services (not equipment) dated on or after July 1, 2022 have a service delivery deadline of June 30, 2024 or 14 months after the date of the letter, whichever is sooner. These FRNs are still only eligible for 12 months of services.
  • Applicants in Windows 1 and 2 (FY 2021) that received an FCDL or RFCDL approving support for equipment dated on or after January 1, 2023 have a service delivery deadline of 180 days from the date of the FCDL or RFCDL letter, but not to exceed beyond June 30, 2024.
  • Applicants in Window 3 (FY 2022) for all services and equipment have a service delivery deadline of June 30, 2024.
  • The service delivery date for approved recurring services associated with a new construction funding request is extended to June 30, 2024 if the FCDL or approved RFCDL for the new construction services was dated on or after July 1, 2022. However, no changes were made to the service delivery deadlines for completion of new construction which remains as 1-year from FCDL date. (However, the FCC has case-specific waiver requests for applicants/service providers that have shown they cannot meet the 1-year deadline).
  • Applicants or service providers with appeals, waivers, or post-commitment change requests that are still pending at USAC or the FCC as of June 30, 2024 will also have a service delivery date of June 30, 2024 (this date will not be extended, regardless of the outcome of the decision). Applicants, in such a scenario, must have purchased the eligible equipment and/or services by June 30, 2024, to be eligible to be reimbursed, but do so at their own risk if the funding decision is ultimately denied.

Invoicing Deadlines:  The invoicing deadlines remain unchanged – BEAR or SPI must be submitted 60 days from the FCDL, RFCDL, or service delivery deadline, whichever is later.  Reminder:

  • Windows 1 and 2 (FY 2021) – For funding requests with a service delivery date of June 30, 2023, ECF requests for reimbursement must still be filed by August 29, 2023. For funding requests with a different or later service delivery date, ECF requests for reimbursement must be filed within 60 days of the service delivery date.
  • Windows 3 (FY 2022) – For funding requests with a service delivery date of June 30, 2024, ECF requests for reimbursement must be filed by August 29, 2024. For funding requests with a different or later service delivery date, ECF requests for reimbursement must be filed within 60 days of the service delivery date.

FCC special note regarding strict invoicing deadlines:  To reduce processing delays near the invoice filing deadlines, the FCC recommends filing requests for reimbursement as soon as the eligible equipment or services are received. They will de-obligate unused funds as soon as the invoicing deadline has passed to make them available for the remaining timely-filed third application filing window funding requests. The FCC also does not expect to grant waivers of the ECF invoice filing deadline date, absent extraordinary circumstances.

ECF Data for PA Applicants:  Attached is a list of every ECF funding request submitted by PA schools and libraries, along with the information you need to figure out your relevant deadlines.  For most Windows 1 and 2 FRNs, the deadline to invoice is August 29, 2023, but because of these firm deadlines, and because it can sometimes take several months to have invoices processed due to the unique requirement to have an updated sam.gov account containing EIN data that matches your Form 498 data, it’s important that you submit your invoices as early as possible.

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

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