ECF Updates/Clarifications/471 Hints Do’s and Don’t’s

August 4, 2021

Attached: ECF Form 471 Application Data Needed – Libraries

Attached: ECF Form 471 Application Data Needed – Schools

~ Checklists of Info Needed for Form 471 Attached ~

There are 9 days remaining to submit your ECF applications for Window 1 which is for connected devices and internet access services purchased between July 1, 2021 – June 30, 2022 for students, teachers and library patrons with unmet needs while off-campus.  So far in PA, 50 school/library application have been certified and an additional 97 are being drafted.  I encourage you to submit as soon as you can and not wait until the August 13 deadline!  I have not heard any indication from federal officials that they are considering a deadline extension.

Below are clarifications/updates we’ve learned in the last two weeks, both related to program eligibility and how the Form 471 should be submitted.  Also, I’ve created ECF Form 471 data checklists – one for schools and one for libraries – that I encourage you to review prior to completing the Form 471.  The school’s checklist also includes the ECF 471 Unmet Needs Survey questions that you can complete in advance and then just cut/paste your answers.

I’ll soon be announcing two additional Q/A webinars shortly to answer your questions in real time.  As always, if you have any questions, please e-mail me!

Clarifications/Updates:

  • Vendor quotes must include quantities.
  • Licenses must be bundled with device cost.  Separately priced licenses are not eligible.
  • 3-year manufacturer warranties are eligible if they’re is bundled with the cost of the device.  This does not include accidental device protection or insurance-type warranties which are not eligible for support.
  • $250 wi-fi hot spot cap does not apply if the hot spot is serving multiple users.  Be sure to explain in the FRN narrative that the service is for X number of users being used on school buses (or whatever the location is).
  • $250 hot spot cap is just for the hardware.  Applicants can seek separate reimbursement for monthly services and those are not subject to the cap as long as they’re reasonable.
  • A connected device cannot serve as both a connected device and wi-fi hotspot and collect both the $400 and $250 caps.
  • The costs of taxes, installation, configuration and other eligible charges are counted in the $400 device cap (or $250 hot spot cap).
  • Deadline to seek reimbursements is now August 29, 2022 if 471 lists service end date of 6/30/2022 (which is the default).  The only exception is if equipment was received between July 1, 2021 and date 471 was submitted.  Those FRNs have 60 days to invoice ECF.
  • Cannot invoice for services that have not yet been received, even if pre-paid.
  • Can change vendors, make/model after 471 submitted.  Details on how to do this have not yet been released.  If you realize you need to make a change before the August 13 deadline, simply file a new ECF Form 471.
  • Laptop/tablet leases are eligible, but only for prorated amount for FY 2021, subject to the $400 total device cap.
  • Applicants don’t need a SAM.gov registration if their vendor will be seeking reimbursement from ECF.
  • Only “reasonable estimate” of unmet need required at 471 stage, along with a explanation of how you determined the reasonable estimate (publicly available data, PAIU/PSU survey, district survey, etc.).  Must have documentation to support unmet needs at reimbursement stage.  Before seeking reimbursement, I recommend obtaining a signed statement from student or family attesting to unmet need at home.  I’ll create and send an example to the listserve soon.
  • Can seek ECF “commitment” for X number based on reasonable estimate, but then only invoice for less, based on actual student data.  Consider invoicing ECF in stages as devices are distributed throughout the year.
  • Students/teachers are permitted to bring laptops to campus but districts cannot require devices to remain on-campus.
  • If a school or library is receiving E-rate funding for Internet or internal connections, or ECF funding for internet, they must filter all school/library-owned computers, including those used off-campus.
  • You can use a survey from 2019 or 2020 as the basis for your “reasonable estimate” of unmet need.  But you should have a signed statement at the reimbursement stage.
  • It is not considered duplicative service to provide wi-fi on buses and also provide those same students with at-home internet.
  • The FCC’s FAQs provide great clarifications on determining unmet needs:  https://www.fcc.gov/emergency-connectivity-fund-faqs.

ECF Form 471 Hints, Do’s and Don’t’s:

  • Create different FRNs for Equipment and Internet.  Wi-Fi Hotspot devices and monthly internet service costs must be on separate FRNs (one is equipment and the other services).
  • If you’re requesting Internet on buses, list total eligible cost and explain in the narrative that the cost exceeds $250 because it is multiple (x number) of students.
  • If a connected device costs more than $400, just list $400.  Don’t list the actual price of the device.
  • If seeking installation, configuration or taxes, list these on the same FRN as the device/service, but as a separate FRN Line Item – don’t bundle the cost with the device cost.  Also, if these are charges related to equipment, you don’t have to list a separate “services” FRN.
  • Installation, configuration and taxes must be provided by the same vendor as the underlying equipment/service.
  • If a school is filing multiple 471s, their Unmet Needs Survey should list identical data on each 471.  Libraries aren’t asked these questions.
  • Upload your vendor quote in the FRN, even though it’s not a mandatory field.  PIA has been asking applicants to submit them if they weren’t uploaded with the application.
  • Vendor quotes should include make and model or service type, quantity, unit cost, service dates.  Don’t just list a quantity of 1.
  • Signed contracts not required.
  • If # of devices/internet service plans on 471 exceeds the quantities listed in the 3rd question of the Unmet Needs Survey, explain the reason for the difference in the narrative.  For example, the survey asks for data related to students, but your FRN may include students and teachers.
  • Use the form’s default service delivery dates of 7/1/2021 – 6/30/2022.  The detailed cost section will ask you to enter the # of months that service is being provided and doesn’t automatically calculate using the calendar dates like the E-rate Form 471 does.  Be careful.
  • If you indicate that vendor will be seeking ECF reimbursement, you must upload proof from vendor that they’ve agreed to this.
  • If you get logged out before submitting, go to “My Pending Tasks” to see your draft application (not “My Applications”).  Also, as with the E-rate EPC portal, there’s a very short timeout setting.
  • If you submit the form and realize you’ve made a mistake, there’s a Modification feature under the Related Actions tab to ask your PIA reviewer to make changes.
  • There’s no way to download a PDF of a DRAFT 471, but you can download a PDF of the certified form by using the “Generated Documents” link in the left toolbar and then clicking on “Original Version.”

Additional Resources:

Julie Tritt Schell

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

 

 

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