ECF Asset Inventories, Unmet Needs Documentation, and Audit Preparation

June 29, 2023

The FCC has begun conducting ECF audits, and ECF is also now included under the Federal Single Audit Program for any year an entity receives over $750,000 in federal awards.   We have received feedback from these initial audits that most findings are related to schools lacking the required asset inventory and tracking data, and/or not being able to produce documentation of unmet need from the students/teachers receiving the equipment and services.  All of this documentation must be retained for 10 years and must be presented to auditors, upon request.  In March, the FCC issued a Public Notice reminding ECF recipients of these requirements, which are also listed below.  Please review these requirements and ask yourself if your school or library is in full compliance and can pass an ECF audit.

Audit Required Documentation

If selected for an FCC ECF audit, the auditee will receive a request from the auditing firm Censeo to produce the following documentation:

  • The asset inventory for ECF-reimbursed equipment and services – see below for required elements of asset inventory of ECF devices and equipment.
    • Note: in some cases, auditors are conducting on-site audits where they have required schools and libraries to produce randomly-selected equipment.
  • Documentation of unmet needs assessment (e.g., returned surveys, signed unmet needs certifications, etc.)
  • Records of vendor invoices and payments for ECF-reimbursed equipment and services.
  • If an applicant replaced old equipment with ECF-reimbursed equipment, documentation of how the applicant determined the existing equipment was inadequate.
  • ECF bid documentation (if bidding was required by state, local or other laws or requirements).

The auditors also will require the completion of their ECF Audit Survey to confirm compliance with program rules.  The survey asks:

Q1. Please describe how you determined the unmet need for your school, library, or consortium (i.e., the number of students, school staff, and/or library patrons who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning)

Q2. Please explain what measures and actions you took to track and monitor the usage of the audited equipment/services.

Q3. Please explain the process you went through to procure these devices/services and other equipment being audited, including information related to how you determined the pricing of the audited devices/services were reasonable and that the devices/services met the remote learning requirements of your students, school staff, or library patrons with unmet needs.

Q4. Please describe the methods or internal controls that your organization employed to restrict the use of connected devices for educational purposes by eligible users (students, school staff, or library patrons).

Required Equipment Asset Inventories

For devices, participants must retain an asset inventory tracking all the following items:

1) the device or equipment type (i.e., laptop, tablet, mobile hotspot, modem, router);

2) the device or equipment make/model;

3) the device or equipment serial number;

4) the full name of the person to whom the device or other piece of equipment was provided; and

5) the dates the device or other piece of equipment was distributed (or loaned out) and returned, or the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged.

Required Service Inventories

For broadband services, participants must retain inventories tracking all the following items:

1) type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless);

2) broadband plan details, including: upload and download speeds and monthly data cap;

3) the name(s) of the person(s) to whom the service was provided;

4) the service address (for fixed broadband service only); and

5) the installation date of service (for fixed broadband service only); and

6) the last date of service, as applicable, (for fixed broadband service only).

Additional ECF Compliance Information Issued by USAC

In a recent newsletter, USAC issued additional guidance to ECF program participants regarding compliance with program rules. USAC emphasized the following:

  • Reimbursement may only be requested if there was an actual unmet need;
  • Reimbursement should not be requested for monthly recurring services associated with any devices or equipment that are not being used;
  • ECF funds are not intended to support 1:1 initiatives but may only be used to support students and staff who have a documented unmet need;
  • ECF funds are not intended to support devices and services used exclusively on a school campus, they are primarily intended to support remote learning away from school.

If you are using ECF funds, I strongly encourage you to ensure that you have all of these required documents and data in place to ensure you are in full compliance with ECF program rules and requirements and won’t be at risk of having ECF funding rescinded as a result of an audit.

If you have any questions, please don’t hesitate to contact me at jtschell@comcast.net or reach out to the ECF Customer Service Center (CSC) at (800) 234-9781 or create a Customer Case in your ECF portal.

— Julie

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

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