February 2022 E-rate, ECF, & EBB/ACP Update

February 11, 2022

Happy February, E-raters!  Below are a few E-rate reminders and helpful hints.  If you have any questions, please don’t hesitate to reach out to me!

Time Running Out to Post 470s

If you haven’t done so already, it’s time to post any last-minute Category 2 Form 470s or PEPPM mini-bids for new equipment, or Category 1 Form 470’s for services needing a new contract or MTM services (MTM must be filed annually).  The very last day that you can post a 470 is February 22, but this only leaves the final day of the Form 471 window – March 22 — to evaluate your bids, obtain local approvals, sign contracts, upload contracts and complete the 471.  Please don’t wait another minute to file your Form 470!  Helpful docs:

Congrats to the PA Entities That Have Submitted 471s!

I’m so pleased that 233 PA schools and libraries have already submitted their FY 2022 Form 471s, and I’m even more excited to report that 73% of those FRNs are already in Wave Ready Status.  From what I’m hearing, applicants are receiving PIA review questions within 48 hours of submitting their application, with some reporting receiving inquiries within minutes of hitting submit.

 

If your competitive bidding is complete and you have obtained signed contracts – or if you’re in a multi-year contract that was signed in a previous year, or are filing using the CABIO bidding exemption – you should proceed with the Form 471 filing as soon as you can to be virtually assured of receiving an early funding commitment decision.  Here are links to a few guides that will come in handy over the next 5 weeks:

E-rate Form 471 Training Announced
Three Form 471 trainings will be held on February 23/24.  The first training will focus on smaller applicants using the CABIO bidding exemption.  The other two trainings will focus on all other application types and will begin with a demo of creating Contract Records in EPC.  There will be plenty of time available to ask questions.  Registration and training details are available at: https://e-ratepa.org/?page_id=745

Category 2 FY 2022 Form 471 Does NOT Require Equipment Listed by Building

As a reminder, E-rate rules no longer require applicants to identify on the Form 471 which school/library buildings are receiving the equipment.  When the system asks, “Is every building receiving the equipment/service?” you just answer Yes.  What a time saver!  Likewise, the Internal Connections Bulk Upload Template now only requires a single tab, making it incredibly simple to create/use.  Even though USAC won’t track which buildings are receiving which equipment, applicants will still be required to maintain an asset inventory to track where every piece of equipment is located (by room).

Reminder to Include Up-to-Date Vendor Tax/Fees

Although it’s tempting to use the Copy FRN feature in the Category 1 Form 471 for your services that haven’t changed from last year, please make sure those amounts are accurate.  Since last year, many Category 1 service providers have increased their taxes and fees so it’s important that you check your vendor’s current invoice and use the correct amounts.  Those taxes/fees are all E-rate eligible (unless it’s an “administrative fee” or a “property tax fee”) and should be included on your E-rate application as a separate FRN Line Item (same FRN) using à Miscellaneous à Taxes/USF Fees (quantity = 1).

February 25 BEAR Filing Deadline for FY 2020
This is a friendly reminder for several PA schools and libraries that their FY 2020 BEAR deadline is fast approaching.  To see if your school or library is impacted, go to:  https://e-ratepa.org/?p=34053.  Most of the FRNs on the list have February 25, 2022 invoice deadlines because they received an extension of their October 28, 2021 invoice deadline.  There are other, later deadlines on the list as well.

New to E-rate?

If you’re new to E-rate or would like someone else in your school or library to learn E-rate (who wouldn’t?!), you may wish to have them review the “Where to Start” link on the www.e-ratepa.org website.  The site contains an Onboarding Guide that provides a brief overview of E-rate, links to valuable resources, and explains how to get set up in EPC and on various E-rate listserves.

ECF Update

In all, PA schools and libraries have been committed $75,909,747 in FY 2021 Emergency Connectivity Funding.   We have a few funding requests still pending and I know USAC is working hard to review these applications and award funding.  Four quick ECF updates and reminders:

  1. Several national organizations representing ECF/E-rate applicants are urging the FCC to grant service delivery deadline extensions for ECF purchases.  Stay tuned to see what the FCC decides.
  2. There is likely to be at least $100 million left over that will be available for a future ECF application window.  I expect the FCC will make a formal announcement about ECF Window 3 in the coming weeks and also expect that if a window does open, it will not occur until after the E-rate application closes.
  3. The ECF Form 472 BEAR reimbursement form may be submitted if you have received an ECF FCDL, the equipment or services have been received, and you’ve obtained the Unmet Needs Certifications (if required).  Be sure to include a packing slip or proof of shipping with your BEAR so USAC can process your reimbursement request.  BEARs without this documentation will not be processed.  If you already filed your BEAR and didn’t include this documentation, you can send it to your reviewer now by adding it to your pending ECF BEAR in EPC by using the Communications Tab.
  4. Schools and libraries must obtain signed Unmet Needs Certifications when distributing devices/services to students, teachers or library patrons, under most circumstances.  Please refer to this message for complete details:  https://e-ratepa.org/?p=33555.  We understand that USAC’s invoicing team is requiring some applicants to provide proof of their unmet needs when the ECF Form 472 BEAR Reimbursement Forms are submitted and we know that these forms will be requested during any ECF audits.  Even if your service provider is submitting the reimbursement form, you must have these signed Unmet Needs Certifications before the vendor invoices USAC and be prepared to provide them to USAC upon request.

EBB Becomes ACP Program

Beginning January 1, 2022, the temporary Emergency Broadband Benefit Program (EBB) that began in May 2021 to provide subsidies for Internet access to low income homes, official became the permanent Affordable Connectivity Program (ACP).  The programs are nearly identical except the subsidy under ACP is only $30 month (instead of $50/month under EBB).  There is also a one-time discount of up to $100 for a laptop, tablet, or desktop computer (with a co-payment of more than $10 but less than $50).

A household that would like the ACP subsidy has several ways to apply.  Schools and libraries can play a huge role in getting out the word to eligible families and the FCC has created a toolkit with helpful fliers and marketing materials.  Just like EBB, families with at least one student attending a CEP school automatically qualify for ACP benefits, even if the household doesn’t meet the income requirements.  Schools may be asked to provide an official statement attesting that a student attends your school and that it is a CEP school.

If you have any questions, please contact me at jtschell@comcast.net!

— Julie

Julie Tritt Schell

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

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