Congress Requires FCC to Rescind Portion of ECF Funds

June 11, 2024

Attached: Unexpired FRNs as of June 11 2024

~ Please return unused funds – potential list attached ~

The FCC has just announced that as the result of a provision in the Congressional General Appropriation Act of March 2024, the FCC is required to rescind $1.768 billion from the $7.171 billion allocated to the Emergency Connectivity Fund (ECF).  ECF was one of many federal programs that was cited for funding rescission.  What is the impact to ECF applicants and service providers?

Good News:

  • No existing funding commitments will be required to be returned.  If you have an ECF funding commitment, that funding is secure (provided you don’t need to make one of the changes outlined below)
  • BEARs and SPIs will be processed/paid for existing funding commitments.
  • Service/equipment substitutions will continue to be approved, as will changes to UEI numbers and changes to service start and end dates.

Bad News:  Because of this rescission, the FCC/USAC is constrained in its ability to make changes to existing funding commitments and obligate any new funds for any reason, including to resolve an appeal.  Therefore, although the following requests may continue to be submitted, USAC is prevented from processing them until after the $1.768b has been returned:

    • SPIN Changes (changing service providers)
    • Invoice Mode Changes (changing from BEAR to SPI or SPI to BEAR)
    • Approval of funding requiring an appeal or waiver.

USAC has issued a series of FAQs regarding the rescission and they are listed below.

Please Return Unused or Unneeded ECF Funding Commitments

We know that some of the $1.768 billion will come from the undisbursed ECF funding from Windows 1 and 2.  But a sizable (yet unknown) amount is still needed to be found and the quickest way for the FCC to meet the rescission requirement is for Window 3 applicants (and Windows 1 and 2 applicants with unexpired invoice deadlines) to cancel/return any funding commitments that they have not or will not be using.

Attached to this message is a list of all Pennsylvania ECF commitments from Windows 1, 2 and 3 with unexpired FRNs, meaning their invoice deadline has not yet passed.  The deadline to receive equipment/services from Window 3 is June 30, 2024 (deadline for Windows 1 and 2 was June 30, 2023).  If your name is on the attached list, and you do not need the commitment or remaining commitment shown in column M, please file a Post Commitment Request (PCR) to decommit the funds.  To do this, follow these easy steps:  Log into ECF Portal > My Forms and Requests > Click on the ECF 471 Application Number > Related Actions > Create a Post-Commitment Request.  Then simply select that you want to reduce (or cancel) a committed funding request, then cite in the narrative the amount you will not need and would like to decommit.


USAC’s ECF Rescission FAQs:

Q: What does the language in the Congressional government funding bill mean for the ECF program? 

A: The government funding bill passed in March 2024 rescinds $1.768 billion from the ECF program. This means that Congress has canceled part of the FCC’s budget authority for the ECF program as a measure to reduce government spending. The FCC cannot make any new commitments from ECF funding until the rescission is satisfied and the full $1.768 billion is returned by the FCC to the U.S. Treasury.

Q: What is a commitment and an obligation?

A: When USAC issues a funding commitment decision letter, the funding is committed for the services and equipment detailed in the terms of the letter (i.e., named service provider, dates, types of equipment, and services). At the same time, the FCC records an obligation in its books and records pursuant to the Recording Act, 31 U.S.C. § 1501.

Q: What impacts does rescission of unobligated funding have on ECF applicants and service providers? 

A: In addition to requiring the FCC to return uncommitted funds, the rescission means that the FCC cannot make new commitments in the course of administering the ECF program. Because of the way that the obligation process occurs, the FCC and USAC are therefore prevented by the March 23, 2024 law from: processing post-commitment requests to change service providers or invoicing methods; approving a commitment if an appeal or waiver is granted; or making upward commitment adjustments to resolve errors.

The following types of post-commitment requests will continue to be processed (as long as there is no increase in the committed amount) because they do not change the recorded obligation: service start and end dates; unique entity identifier (UEI) and taxpayer identification number (TIN) changes; service/equipment substitutions; commitment reductions and cancellations, and recovery of funds. Post-commitment requests with currently prohibited changes cannot be processed at this time.

Q: Will I need to return ECF disbursements I’ve already received?

A: No. The rescission does not impact previously obligated and disbursed ECF funds or our ability to reduce a commitment and/or to recover improperly disbursed funds. Program participants may also continue to voluntarily return funds if needed.

Q: If I already have a funding commitment, can I continue to submit invoices?

A: Yes. The rescission does not impact prior funding commitments. Program participants may submit invoices for eligible equipment and services purchased by June 30, 2024, the program’s sunset date, and USAC may process invoices so long as the invoice filing deadline has not passed. However, certain changes (such as a request to change service providers or invoicing methods) are prohibited even with an existing funding commitment. See FAQs 15.3; 15.8.

Q: Are there any pending applications that will be affected?

A: No. All ECF funding applications submitted have been reviewed and processed (i.e., funded, cancelled, or denied).

Q: What happens if I have an appeal or waiver request?

A: The rescission does not impact the ability of participants to submit timely appeals or waivers pursuant to section 54.1718 of the program rules. However, the rescission means that the FCC cannot make new commitments in the course of administering the ECF program unless and until the full amount of the rescission is satisfied. If granting an appeal and/or waiver request would require making a new obligation, the FCC is prohibited by law from doing so unless it has unobligated funds. The FCC will not have unobligated funds available for new ECF commitments unless and until it satisfies the full amount of the rescission. See FAQ 15.3. If you have ECF funding or commitments that you know you will not be using, you can voluntarily return those funds to the program. See FAQ 5.9.

Q: Do any of the deadlines associated with the sunset of the ECF program change? 

A: No. The ECF program service delivery and invoice filing deadlines will not change. June 30, 2024 is the final service delivery date for most remaining ECF funding requests. August 29, 2024 is the invoice filing deadline for ECF funding requests with June 30, 2024 as the service delivery date. Un-invoiced ECF funds will be de-obligated following the August 29, 2024 invoice filing deadline.

Q: How do I reduce a funding commitment or return funding if I no longer need it? 

A: To reduce the funding amount on a committed request or to cancel a funding commitment, applicants should file a Post-Commitment Request with USAC. Instructions on how to file a Post-Commitment Request may be found here: To return excess disbursed ECF dollars, applicants should call the ECF Customer Support Center (CSC) at (800) 234-9781.

If you have any questions, please don’t hesitate to contact me or the ECF customer service center at: 800-234-9781.


Julie Tritt Schell

Pennsylvania E-rate Coordinator
717-730-7133 – o


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