Additional Important ECF Clarifications Issued
August 10, 2021
The FCC and USAC have issued new and additional guidance related to the following important issues. Please review before submitting your ECF Form 471. If you have already submitted your ECF Form 471 and these clarifications impact your filing, you can either refile the application and under Related Actions of the original 471, ask the reviewer to cancel the application – or – you can ask the reviewer to make the modification to your original application (if it were me, I would simply file a new 471 before Friday’s deadline and cancel the original). Also, don’t forget to review my previously issued Do’s and Don’t’s before filing.
1. Is a license to use a connected device eligible for ECF support?
— Licenses, software, content filtering and security services included in the price of the connected devices are eligible for support and do not require cost allocation. However, separately priced licenses, software, content filtering, and security services are ineligible for ECF funding. Service providers may include these items in the price of the connected device. ECF support for connected devices is capped at $400 per device, even if the base price includes the cost of licenses, software, or content filtering and security services.
2. Is a bundled three-year warranty that includes accidental damage protection eligible?
— No. Accidental device protection, or insurance-type warranties, are ineligible. If a manufacturer’s multi-year warranty for a period of up to three years is bundled with the cost of the device, it is eligible for ECF, but it cannot be listed with a separately identifiable cost.
3. For network construction, will service providers be able to request a one-year extension?
— Unlike the E-Rate program, ECF program rules do not allow USAC to provide service delivery extensions for third-party or self-provisioned networks. If special circumstances warrant it, applicants will be permitted to request an FCC waiver of the one-year completion date.
4. For new construction projects in unserved areas, are vendors permitted to submit “progress payment” reimbursement SPIs? If so, is it required that such provisions be in the vendor contract?
— milestone payments. Yes, if in the contract. But 1 year deadline applies so there may be a risk of recovery if they don’t complete it.
5. Does a service provider need a Service Provider Identification Number (SPIN) for ECF?
— Depends. SPINs are not required, unless the service provider will be invoicing ECF for reimbursement.
6. In order to save money, many school districts opted to put their wireless internet plans in “summer mode” where the cost is reduced from $45/month to $10/month. Is the $10/month “summer mode” charge also eligible for ECF?
— Yes.
7. How should a school calculate the eligible amount in Window 1 for a multi-year laptop lease?
— Applicants may request ECF funding for the amount per laptop that they’re paying between July 1, 2021 – June 30, 2022. Finance charges are not eligible for ECF. should apply for what is being charged for that funding year. Not subject to proration up to $400 cap.
8. If an applicant will be using a PO to purchase the equipment or services, should they select ‘Contract’ or ‘Non-Contract’ for the Agreement Type?
— Non-Contract.
9. Should installation/configuration services for a connected device be a separate line item from the “equipment” FRN?
— Yes. The installation/configuration should be requested on the same equipment FRN, but as a separate FRN Line Item.
10. Are home-schooled students eligible for ECF supported devices and services?
— When home-schooled students who lack access to eligible equipment or services are considered to be enrolled in public or non-profit private schools that provide elementary or secondary education, under the law of the applicable state, those public or nonpublic schools can seek support from the Emergency Connectivity Fund Program for funding to provide such students with eligible equipment or services. Similarly, eligible libraries could purchase eligible equipment or services for library patrons, including home-schooled students with an unmet need using ECF support.
— Julie
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org