Cybersecurity Pilot Application Window Opens Sept. 17

September 4, 2024

~ Form 484 Details, Additional Trainings & Updated FAQs Below ~

The FCC has just announced that the Form 484 Part 1 application filing window for the $200 million Cybersecurity Pilot Program will open on Tuesday, September 17, 2024 at 8:00 a.m. and will close on Friday, November 1, 2024 at 11:59 p.m.  After the filing window closes on November 1, the FCC and USAC will review applications and determine which schools, libraries and consortia have been selected to participate in the Pilot.  No date has been given for when the FCC will announce selected participants, but I anticipate it will only take a few weeks.

Preview of Form 484 Part 1:  Although applicants will not have access to the Form 484 Part 1 until September 17, a recent USAC webinar gave very detailed descriptions of exactly what information will be requested and in what format (drop downs, narrative text, etc.).  The webinar slides are available at:  https://e-ratepa.org/wp-content/uploads/2024/06/USAC-Form-484-Webinar-Aug-20.pdf.   Slides 8 – 39 provide the most substantial information. 

USAC Cybersecurity Pilot Trainings:  USAC will be hosting a series of additional webinars.  Details and registration links are as follows:   

Schools and Libraries Cybersecurity Pilot Program FCC Form 484 Part 1 Overview and FAQs
September 10, 2024 at 3 p.m. ET – https://register.gotowebinar.com/register/1731546537225721950

Schools and Libraries Cybersecurity Pilot Program FCC Form 484 Part 1 System Walkthrough
September 17, 2024 at 3 p.m. ET – https://register.gotowebinar.com/register/6762279527030024029

Schools and Libraries Cybersecurity Pilot Program Overview for Service Providers
October 15, 2024 at 3 p.m. ET – https://register.gotowebinar.com/register/826117403449932118

Designating Cyber Pilot Users in EPC: Applicants are now able to designate which EPC users will have certain permissions for the Cybersecurity Pilot Program.  To review and set user permission levels, applicants should follow the steps (note – USAC denotes the Pilot at CBR in EPC): 

  1. Log into EPC
  2. From the landing page, click Manage Users
  3. Check the checkbox for your Billed Entity Number (BEN) and select Manage User Permissions
  4. Select CBR User Permissions
  5. Select the appropriate CBR 484 Permission level for each user
  6. Click Submit

I’ll provide specific instructions on how to manage this process as I learn more.

Updated Cyber Pilot FAQs:  The FCC has provided 12 additional updates to the Cyber Pilot FAQs (new FAQs always marked with *).  I’ve pasted 9 of the Q/As below (2 important clarifications highlighted), but did not include the questions related to the bidding exemptions for Master Service Agreements because it is still unclear to me (still) whether the cybersecurity contracts on the PEPPM contract qualify for the bidding exemption.  As soon as I can get these details clarified with the FCC, I’ll let you know. 

* 2.5 Q: How should I estimate the cost of the eligible services and equipment of my Pilot project on the FCC Form 484? I won’t know exactly what it will cost until I complete the competitive bidding process.

A: Pilot applicants should make a reasonable effort to estimate the costs associated with their Pilot project. The FCC expects to use this information to get a sense of the different sizes and types of projects that are being proposed, in order to ensure a diverse pool of participants. Where available, applicants can use published pricing or reports, past estimates or incurred costs, or other sources of information. Once applicants have submitted their cost estimates on the FCC Form 484, they will not be able to modify them. As discussed in FAQ 2.6, however, Pilot Program participants will have an opportunity to adjust their projected costs after completing the competitive bidding process and making final decisions about the services and equipment to be purchased.

* 2.6 Q: Will a Pilot participant’s commitment be limited to the cost estimate provided in its FCC Form 484? If selected for the Pilot Program, can a participant apply for funding greater than their estimated cost, provided it doesn’t exceed their maximum budget?

A: A Pilot participant will not be limited to the cost estimate provided in Part 1 of its FCC Form 484. A Pilot participant can apply, and receive funding, for eligible services and equipment up to its maximum budget.

* 2.7 Q: Can I apply for the Pilot Program even if I’ve already received (or intend to apply for) state funding for cybersecurity services and equipment?

A: Yes, but you may not use Pilot funding to cover the same costs that are funded through another source (i.e., no “double dipping” or duplicative funding). Consistent with our E-Rate rules, you may use another source to cover the non-discounted share of your Pilot-funded project or to supplement Pilot funds in order to fully cover the cost of the solution you intend to implement.

* 2.8 Q: Is there any chance that entities that have uncommitted Category Two funds can have those redirected to services eligible under the Cybersecurity Pilot?

A: No. E-Rate Category One or Category Two funding may not be used for advanced cybersecurity services and equipment that is eligible in the Pilot Program. The Commission will explore whether and how universal service funds, including E-Rate funds, could be used to support these types of services based on lessons learned from the Pilot Program.

* 2.9 Q: Will funding available through the Pilot Program be considered Category One or Category Two?

A: Neither. The Pilot Program is separate from the E-Rate program and, as such, the funding is considered neither Category One nor Category Two funding. As noted in FAQ 2.8, the Commission will explore whether and how universal service funds, including E-Rate funds, could be used to support advanced cybersecurity services and equipment after the conclusion of the Pilot Program.

* 4.10 Q: Can I use Pilot funding to purchase cybersecurity protection for end-user devices, such as tablets, smart phones and laptops?

A: Cybersecurity services used on end-user devices that are owned or leased by a participating school or library are eligible, regardless of whether the services are network-based or locally installed on the enduser device. See Report & Order, FCC 24-63, Appendix B, note 4.

* 4.11 Q: Can I apply for Pilot Program funds to cover the costs associated with a basic firewall if I don’t plan to seek E-Rate funding next year?

A: No. Basic firewalls are not covered by the Pilot Program.

* 6.7 Q: May Pilot participants convert an existing non-competitively bid contract into Pilot-eligible contract based on the Kalamazoo Order from the E-Rate program? That is, can an existing contract, that does not qualify under the CBE, be converted to a qualifying contract if the participant initiates a new bidding process in which it treats the existing contract as a bid received?

A: No, unlike the E-Rate program, the Pilot Program does not allow existing, non-qualifying contracts to be converted into eligible contracts based on the E-Rate program’s Kalamazoo precedent. Existing contracts only qualify for the Pilot if they fall within the CBE.

* 7.4 Q: If an eligible school or library obtains an eligible service from a network provider, but such eligible service is being provided by a third-party vendor, is that still reimbursable under the program?

A: Resale arrangements are reimbursable under the Pilot Program if the applicable eligible cybersecurity services and equipment are received from an eligible service provider (i.e., a service provider that has a valid Service Provider Identification Number (SPIN) and has met all of the other requirements to participate as a service provider in the Pilot Program). The fact that the eligible services and equipment are provided by a third-party vendor to the eligible service provider (who then provides them to the Pilot Participant) does not change their eligibility, as long as the service provider with whom the school or library contracted for the eligible equipment/services is selected through a competitive bidding process that meets all of the Pilot Program’s competitive bidding requirements (Pilot Program FCC Form 470) and the other Pilot program rules are met.

Additional Resources:                                                                                                                

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

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