Let’s Begin E-rate Funding Year 2024!

October 24, 2023

I’m so excited to announce the beginning of the FY 2024 E-rate application process!   Below is a summary of the changes you can expect for FY 2024, important reminders, and a helpful “what to do by what date” chart at the bottom.

What’s New for FY 2024?

1. Wi-Fi on Buses

– On October 19, the FCC approved E-rate eligibility for Wi-Fi on School Buses beginning with Funding Year 2024.  At this time, we only know that services and the needed equipment will be eligible, but don’t have any details surrounding C1/C2 status, competitive bidding requirements, bus leasing or contracting arrangements, whether each bus will need its own E-rate entity number, etc.  I expect the FCC will release draft rules/guidelines in the next few days/weeks after which we can provide feedback.  As soon as the draft is released, I’ll send it to the listserve.  In the meantime, don’t file Form 470s for this service/equipment yet.

2. $3,600 Category 2 Bidding Exemption for Libraries

– Beginning in FY 2024, libraries will have a Category 2 Form 470 bidding exemption) where the total pre-discount price is $3,600 or less per library per funding year.  The cost cannot be averaged across a number of libraries and signed contracts are still required prior to filing the Form 471.  For example, if a library system requests C2 support for 3 libraries, the amount of funding for each library must be $3,600 or less to be eligible for this exemption from filing the Form 470.  Schools are not included in this exemption.

3. 10% Ineligible Internet Usage Safe Harbor

– Beginning immediately, a 10% ineligible usage safe harbor for all applicants is established which says that cost allocation is not required when ineligible usage of Internet is limited to 10% or less of total usage.  This change is a huge relief for our Career Technology Centers that offer adult education classes, schools that operate child-care and health care centers, etc. as they no longer have to worry about whether a nominal amount of their Internet usage is being used for technically ineligible purposes.  “As a means of providing a safe harbor, we adopt a presumption that if at least 90% of an applicant’s requested Internet service is being used for eligible purposes, the remaining ineligible use of the Internet service will be presumed to be ancillary and, therefore, cost allocation is not required.”  The FCC emphasized that applicants are still required to select the most cost-effective Internet service offering to meet its needs, may seek E-rate funding only the amount of bandwidth needed for eligible use.

4. Repeal of C2 NIF Cost Allocation Requirement for Shared Equipment

– Beginning immediately, applicants are not required to cost-allocate the non-instructional facility (NIF) usage of a shared piece of equipment that is located in a NIF. This generally applied to a district switch or wireless controller located in an administrative building or data center.  Unfortunately, C2 equipment that is solely used by the NIF will continue to be ineligible (for example, WAPs in admin buildings).

5. Full Eligibility for Data Network Cabling

– The FCC has clarified that structured cabling in a school or library may be connected to ineligible equipment such as security cameras, voice equipment, smoke detectors, etc.  As long local area network is primarily serving an eligible purpose (i.e., distributing broadband throughout a school or library building), the full cost of the cabling is eligible.  However, networks that are dedicated to an ineligible purpose, such as security networks or voice networks, remain ineligible.

6. Rural Urban Updates from 2020 US Census

– USAC has just updated the Urban/Rural designations in EPC profiles to reflect the updated status, if any, using the 2020 US Census data.  The change impacts relatively few applicants.  If your discount increased or decreased, you would have received a notification from USAC announcing the change.  I should be receiving the list of PA-impacted applicants and I will also let you know if you’re on the list.

7. BEAR to be Updated and Migrated into EPC

– On November 7, 2023, USAC will migrate the new and improved E-rate Form 472 BEAR functionality into EPC!  For those of you who filed ECF BEARs, you’ll already be familiar with the interface.  Much more information about the new BEAR will be coming in the days ahead.  For a really good USAC tutorial of the new BEAR system, visit: https://www.usac.org/e-rate/applicant-process/invoicing/how-to-file-fcc-form-472-in-epc/.

What Else?

8. Changing EPC Account Administrators/Adding New EPC Users
– If you need to change your EPC Account Administrator or Add/Remove EPC Users, be sure to refer to my EPC Guide:  http://e-ratepa.org/wp-content/uploads/2014/03/EPC-Admin-How-To-Guide-2023.pdf. Also, if you need any new E-rate contacts added to the PA E-rate Listserve, please e-mail me their contact information.

9. FY 2024 Form 471 Filing Window Dates
– The FCC has not yet released the official FY 2024 Eligible Services List (ESL) which means that USAC cannot yet announce the official Form 471 Filing Window dates.  However, they indicated recently that they expect the window dates to be very similar to last year, which means it would likely open around the second week in January and close around mid-March, 2024.  For a suggested FY 2024 bidding/filing timeline, see the chart at the bottom of this message.

10. Updating Entity Profiles in the “Administrative Window”
– The “Administrative Window” is the period before the 471 application window, during which time schools update their enrollment and NSLP (or CEP%) data in each school’s EPC profile, update their Category 2 enrollment data (if it increased), and libraries update their square footage (if it changed).  The Admin Window is now open and is expected to close the first week in January.  Schools are required to update their EPC profiles with their fall 2023 data.   In mid-December I will send to the listserve a spreadsheet from PDE that provides the enrollment, NSLP (or CEP%) data along with a guide that will walk you through the process for updating each school’s EPC profile.

11. Category 2 Budgets – What’s Remaining for Your School or Library
– FY 2024 will be the 4th year of the current 5-year Category 2 budget which spans FY 2021 – FY 2025.   C2 budgets are calculated based on the C2 multiplier ($167/student for schools and $4.50/sq ft for libraries – or a minimum of $25,000/building) and the Category 2 enrollment or library square footage that’s currently in EPC.  The school enrollment or library square footage figure used for C2 budgets can be different from the enrollment used for discount calculations!  Schools can use the same C2 enrollment for the entire budget cycle or modify it if enrollment has increased to take advantage of the higher C2 budget (see #12).  To see what your remaining C2 budget is for FY 2024 – FY 2025 (as of 10/23/2023), see:  http://e-ratepa.org/wp-content/uploads/2014/03/Remaining-C2-Budgets-as-of-10-23-23.xlsx.  If you update your C2 enrollment in EPC, the C2 budget will change and the results can be found on USAC’s C2 Budget Data Tool at: https://opendata.usac.org/E-rate/E-Rate-C2-Budget-Tool-FY2021-/8z69-hkn7.  Simply use the filter on the right side of the page.

12. Updating Category 2 Enrollment Data/Library Square Footage in EPC
– If your school participates in NSLP, you may wish to wait until the PDE enrollment data is released mid-December before deciding whether to update your C2 enrollment budget and requesting a C2 budget recalculation with USAC.  However, if you would like to update your C2 data in EPC now, here’s a guide to help:  http://e-ratepa.org/wp-content/uploads/2014/03/Category-2-Replacement-Budget-Requests-2024.pdf.

13. Have Unspent Category 2 Funding from FY 2021 – 2023?
– If you were committed funding in Funding Years 2021, 2022 or 2023 and your expenses were not as high as you anticipated or you didn’t need the funding, you may want to file a Form 500 to cancel or reduce the FRN.  Why?  Because these remaining funds will be put back into your Category 2 budget for the remaining 2 years of this C2 budget cycle.  Please note:  If you don’t use the funding and don’t file the Form 500, the funds aren’t automatically reinstated into your account.  You must take this proactive step to reduce the funding commitment to get the funds back into your C2 budget.

14. Unsure Whether You Need to Rebid Category 1 Services for FY 2024?
– In order to remind you of the status of your current Category 1 contracts (telecom and Internet), soon I will be sending to the listserve a list of all FY 2023 C1 FRNs, and the expiration dates of those contracts.  In the spreadsheet there will be an additional column – “Julie’s Rebidding Status Notes” – explaining whether I think the service must be rebid for FY 2024.  Stay tuned!

15. Extending an Existing Contract for FY 2024?
– If your original contract included (finite, not open-ended) voluntary extensions and you wish to exercise one of those extensions for FY 2024, be certain to notify the vendor in writing of that decision before the Form 471 is filed.  USAC will ask for a copy of that written notification during PIA review, so be sure to retain evidence of that notification.

16. Important PEPPM Reminder
– If you will be using the PA PEPPM Contract as the bidding vehicle for your FY 2024 procurements, ALWAYS download and use the most recent version of the PEPPM Category/Awarded Vendor List when sending PEPPM mini-bids.  The Category/Awarded Vendor List is Attachment C on the PEPPM page:  http://e-ratepa.org/?page_id=6121 and is a live document.  Additional product lines are added, authorized resellers change, and vendor contact information changes, so it’s important that you always use the most recent version.  Also, the updated FY 2024 PEPPM Mini-Bid Guide is available at:  http://e-ratepa.org/wp-content/uploads/2015/01/PEPPM-E-rate-Bidding-Guide-2024.pdf.

17. Funding Year 2024 Suggested Timeline: 
– If you haven’t yet done so, now is the time to file Form 470s for expiring or new Category 1 services, and Form 470s (or PEPPM mini-bids) for Category 2 purchases that you will need for FY 2024 (July 1, 2024 – June 30, 2025).



Step: Timeline:
Post Form 470 in EPC to competitively bid all new/expiring contracts (unless using the PEPPM mini-bid option for C2)  Now – early December (by Thanksgiving, if possible!)
Update enrollment/NSLP data in school EPC profiles    Now – early January (hint: wait for PDE data in mid-Dec)
Conduct bid evaluation  Early January
Obtain school board approval    January or February board meeting (no later)
Sign vendor contracts    By End of February
Create Contract Records in EPC/upload signed contracts    Late February/Early March
Submit Form 471    February/early March
Earliest applicants can purchase C2 equipment  April 1, 2024
Funding Commitment Letters (FCDLs) issued    End of April – Sept 1 (goal)
File Form 486    Upon receipt of FCDLs
Earliest that FY 2023 BEARs or SPIs can be submitted to USAC  July 1, 2024

If you have any questions, please don’t hesitate to contact me!

– Julie

Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o

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