FCC Issues ECF FAQs
June 25, 2021
Attached: FCC FAQ 6.25.2021
Today, the FCC is holding a live webinar beginning at 2:00 to help launch the new Emergency Connectivity Fund initiative. In advance of this webinar, the FCC has released 39 FAQs that provide some great clarifications that we’ve been seeking. The FAQs can be found at: https://www.fcc.gov/emergency-connectivity-fund-faqs and are also pasted to this message. I encourage you to review them all, but here are the key clarifications they provided, in my opinion:
Q: If a district-owned connected device was assigned to a student, but the device is no longer sufficient to engage in remote learning (for example, a three-year old laptop), can the district request ECF support for a new connected device? A: Yes. If a device is no longer sufficient for a student to engage in remote learning, ECF support can be used to provide a new device. Applicants must certify on their funding application that they are only seeking support “for eligible equipment and/or services provided to students and school staff who would otherwise lack connected devices and/or broadband services sufficient to engage in remote learning.”
Q: Can an applicant request funding for connected devices or Wi-Fi hotspots for all of its students as part of a 1:1 device initiative? A: No. Applicants must certify, as part of their funding application, that they are only seeking support for eligible equipment and services provided to students and school staff who would otherwise lack access to connected devices or broadband services.
Q: Is a license to use a connected device eligible for ECF support? A: Licenses included in the base price of the connected devices are eligible for support and do not require cost allocation, but separately priced licenses are ineligible for ECF funding.
Q: For parked school buses or other multi-user locations, are other members of the community, besides students and school staff, permitted to use the internet access? A: No, other members of the community are not permitted to use the services. Internet access must be primarily used for educational purposes and is limited to intended users.
Q: Are Wi-Fi hotspots designed for many users, such as on a bus (e.g. 100+ users), limited to $250? A: No, the $250 limit is a cap on the hardware cost for a Wi-Fi hotspot provided to an individual student, school staff, or a library patron. As with other eligible equipment and services, however, costs must be reasonable. Applicants should explain in their funding request narratives how the multi-user Wi-Fi hotspot is being used or provide an explanation for the higher cost and why the equipment was selected.
Q: Are monthly services costs limited to $25 per month? A: No. The Order states that services would generally be in the range of $10 to $25 per month, but it did not set a maximum support amount in the way that it did for connected devices or Wi-Fi hotspots. USAC will review monthly service costs to ensure that they are reasonable. Applicants should be prepared to justify the service selection process they used and reasonableness of costs, if requested, during the review process.
Q: For the initial application filing window, are monthly services that were prepaid prior to the adoption of the ECF Order eligible, such as when an applicant prepaid for a multiyear contract last year? A: Applicants may seek reimbursement for services delivered between July 1, 2021 and June 30, 2022 that were prepaid prior to the ECF Order adoption on May 10, 2021, if they can demonstrate that the services were purchased to meet unmet student, school staff, or library patron needs. Such applicants may not seek reimbursement until after the services have been delivered. Prepaid equipment is ineligible for ECF support during the first application filing window, which is limited to equipment and services received, delivered, and paid for between July 1, 2021 and June 30, 2022.
Q: Do approved applicants that receive recurring monthly services need to submit invoices within 60 days of each monthly invoice? A: No. For recurring services that are invoiced on a monthly or periodic basis, approved applicants may invoice within 60 days of the last date of service (i.e., they must invoice at least once by August 30, 2022 for services received through June 30, 2022).
Q: Can applicants pre-pay for a year of services and seek reimbursement as soon as they have a funding commitment? A: No. Approved applicants cannot invoice for services that have not yet been received.
Q: Do applicants need to have contracts in advance of submitting an application for ECF support? A: No, contracts are not required under the ECF Program rules, but applicants are required to comply with state, local, or Tribal procurement laws or regulations.
Q: Can applicants change their service providers after they file their applications? A: Yes, applicants may change service providers.
Q: How should applicants determine their unmet needs? A: The FCC has not prescribed a specific way for applicants to go about estimating what they will need to address unmet needs. In the case of schools, applicants should provide their best estimates about the number of students who did not have access to adequate connected devices, broadband connections, or both when the pandemic began; the number of students who do not currently have adequate access; and how the applicant expects those numbers to change with the requested ECF Program support. While the FCC has not dictated specific data collection requirements for estimating the unmet for students, schools must describe how and when they collected the information that they use for the estimates provided in their responses. There is no such data collection requirement for libraries to estimate the unmet need for library patrons. However, both schools and libraries must certify that they are seeking support for eligible equipment and/or services for students, school staff, and/or library patrons that would otherwise lack adequate access.
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org