E-rate Off-Campus Hotspot FAQs/Resources Released
October 14, 2024
~ Webinars Being Conducted This Week ~
USAC has just released a new Off-Campus Wi-Fi Hotspot page that contains a summary of the initiative, an infographic and 31 new FAQs at: https://www.usac.org/e-rate/applicant-process/before-you-begin/off-premises-wi-fi-hotspots-summary-overview/. The FAQs are pasted below for easy referencing (note that several of the questions came from PA applicants). Also, two E-rate Hotspot webinars are being conducted this week – one by USAC and one by me – and I encourage you to attend at least one if you are considering applying for this newly eligible service.
USAC Hot Spot Webinar:
Tuesday, October 15 – 2:00 p.m. Eastern
Register at: https://attendee.gotowebinar.com/register/6143181913311183962?source=Webinars
PA Hot Spot Webinar:
Thursday, October 17 – 10:00 am Eastern
Register at: https://cciu.zoom.us/meeting/register/tJ0vdu-qrzMpGtMtTBkHxT0KhPFhvZXTQVr-
USAC Hot Spot FAQs
1. Who is eligible for Wi-Fi hotspots?
Eligible schools and libraries are able to receive support for Wi-Fi hotspot equipment and services for off-premises use by students or library patrons.
2. Who is ineligible to receive Wi-Fi hotspot devices funded through E-Rate?
Schools may not distribute Wi-Fi hotspots to ineligible Head Start, pre-kindergarten, and kindergarten populations.
Consistent with Category Two budgets, virtual students are eligible for Wi-Fi hotspots and can be included in the budget count if they are enrolled at a brick-and-mortar school.
No.
5. Can we use E-Rate funding to support a 1:1 hotspot initiative?
No. According to paragraph 32 of FCC Order 24-76, the E-Rate program prohibits using Wi-Fi hotspots as part of a one to one (1:1) hotspot initiative, where every student receives a Wi-Fi hotspot. Generally, applicants are prohibited from seeking E-Rate support for a 1:1 hotspot initiative and will be required to certify on the FCC Form 471 application that the hotspots and service will not be used for a 1:1 hotspot initiative. If E-Rate-funded Wi-Fi hotspots are effectively used as part of a 1:1 initiative – either in practice by providing all of the devices to a single school in the district or in conjunction with Wi-Fi hotspots funded via other sources, applicants must document clearly (i.e., individual survey results or attestations) that each individual student needed a Wi-Fi hotspot, in accordance with the applicants’ AUPs, and may not rely on general or estimated findings about income levels. Funding disbursements for applicants without specific documentation to support a 1:1 Wi-Fi hotspot initiative will be subject to denial and/or recovery.
6. If we already have hotspot devices with active services, can we request E-Rate support for this?
ECF or other federally funded Wi-Fi hotspot contracts are not grandfathered, but applicants may seek competitive bids for services to be delivered via ECF or other separately funded Wi-Fi hotspot devices.
7. How do the hotspot budgets work?
The hotspot budget is the maximum amount of pre-discount funding permitted for Wi-Fi hotspots and/or service over three funding years. This is a fixed budget, meaning that once it’s been established, it will not change over the course of the three-year cycle, regardless of if the input changes (students, square footage, Category One discount). Please see this Wi-Fi Hotspots Infographic.
Your discount rate is the Category One discount percentage for the funding year when an applicant first applies for Wi-Fi hotspots and services. For more information on how to calculate your discount percentage, see the Calculating Discounts FAQs.
9. How is the school’s full-time student count or the library square footage determined?
Your most recently verified Category Two data (full-time student count or square footage) during the funding year that an applicant first applies for Wi-Fi hotspot equipment and services is used to calculate the Wi-Fi hotspots budget.
10. Are kindergarten students included in the student count for the budget calculation?
Yes. If the Category Two budget student enrollment includes kindergarten students (or pre-k/Head Start in eligible states), they are counted for determining the hotspot budget. However, those students are ineligible to receive a Wi-Fi hotspot funded through E-Rate.
This means that the applicant is limited to requesting a maximum of 45% of their three-year budget in any particular funding year. For example, an applicant that has a budget of $63,000 would only be able to request discounts on costs up to $28,350 in any single funding year. Even if the applicant first applies in the third year of its budget, they are still restricted to requesting 45% of their budget.
12. Is there a funding floor for the Wi-Fi hotspot program?
There is no funding floor for the Wi-Fi hotspot program. However, each entity will be eligible for at least 10 Wi-Fi hotspots and service lines (i.e., $6,300 pre-discount hotspot budget).
13. When do I round when calculating my hotspot budget?
In the hotspot budget calculation, the value in the brackets [product of A. student count/square footage, B. multiplier, and C. discount rate] always rounds up to the nearest ten before it is multiplied by $630.
Below are some examples of hotspot budget calculations, broken down into each factor of the calculation and step of the equation.
14. How do the cost caps limit my budget?
There are three constraints of the Wi-Fi hotspot initiative to limit funding and allow for the equitable distribution of Wi-Fi hotspots and services to students, school staff, and library patrons, and to ensure cost effectiveness. These constraints are (1) a set budget, (2) annual request limits (the applicant must not request more than 45% of their budget in one year), and (3) funding caps on equipment and services ($15 per month for the wireless service and $90 per Wi-Fi hotspot). Applicants can use their budget at their own discretion as long as it does not exceed the capped amounts and subject to the annual request limit. In other words, the budget calculation is not contingent upon what you purchase.
15. What if I purchase equipment or services that cost more than the funding caps?
Applicants are free to purchase equipment and services that cost more than the funding caps, but applicants are responsible for the amount that exceeds the funding caps. For example, if you purchase an Internet access line for $20 per month for your Wi-Fi hotspot, and you have a 90% discount rate, USAC will cover the capped amount, and you are responsible for 100% of that difference. In this case, that means USAC would pay $13.50 ($15 x 90% = $13.50), and you would pay the non-discounted share ($1.50) plus anything over the $15 cap (i.e. $5.00) for a total of $6.50 per month.
For E-Rate purposes, the remaining applicant costs can come from another funding source, federal or otherwise, provided the funding is not coming from the service provider.
Applicants that select lower-cost Wi-Fi hotspots and/or services, or that find ways to maintain Wi-Fi hotspots for longer, will be able to request a larger quantity of E-Rate supported hotspots or lines of service depending on their individual needs and budget.
18. Can applicants and/or service providers seek reimbursement to the funding caps?
Entities must request E-Rate support based on actual, commercial-based costs. Service providers will be required to certify that the costs of the Wi-Fi hotspots do not exceed commercial value. Note: USAC may modify, reduce, and/or recover funding requests that are determined to be higher than the actual, market-based price of commercially available Wi-Fi hotspots.
19. Do E-Rate funded hotspots need to be used for educational purposes?
Yes, applicants must certify that E-Rate-funded hotspots will be used primarily for education purposes. Additionally, applicants are required to maintain/update their acceptable use policies (AUPs) to clearly state that off-premises use must be primarily for an educational purpose. Applicants are also required to certify on the FCC Form 486 that these requirements have been met and must be able to demonstrate compliance, if asked.
20. Can applicants request extra replacement devices?
No, applicants cannot purchase hotspots in anticipation of future use, loss, or breakage. Applicants must certify to their compliance with this limitation on the FCC Form 471 application. In the event of loss or breakage, applicants may purchase extra devices with other sources of funding to use with the E-Rate-supported service, or they can request devices in the next funding year within their budgets, if devices need to be replaced.
Wi-Fi hotspots will not be considered warehoused so long as the school or library activates the Wi-Fi hotspot device, makes it available for loan, and publicizes the availability of the Wi-Fi hotspots and service to students, school staff, and library patrons via public notice or other means. Wi-Fi hotspots that have not been made available for distribution per these requirements (e.g., if they are never turned on, never publicized, stored in an office, still in the box) will be considered to have been warehoused, and the entity may be subject to a financial recovery. See FCC Order 24-76, paras. 55, 58.
22. How long can my school or library lend a Wi-Fi hotspot?
The details of such a hotspot lending program—such as length of lending periods and how to target the appropriate students and library patrons—will be left to the applicant to determine and tailor the hotspot lending program to their local needs. Entities should structure a lending program in a way that maximizes use of Wi-Fi hotspots and services following the requirements adopted in the Order (FCC 24-76). Such measures to encourage use may include limited lending periods (e.g., 21 days or less).
23. What happens if a student doesn’t use the Wi-Fi hotspot for more than 90 days (like in the summer)?
Applicants that know that Wi-Fi hotspots will not be used are encouraged to work with their service providers to pause service. The FCC prohibits E-Rate support for lines of service that have not been used for approximately three consecutive months (90 days). Specifically, after 60 days of non-usage, service providers are required to provide 30 days’ notice to the applicant before terminating the unused line of service. This approach appropriately accounts for limited, legitimate instances of non-usage, such as a school’s summer break, while also providing sufficient time to allow schools and libraries to work with their service provider, as well as their student, school staff, and library patron users to remedy the non-usage without being unnecessarily penalized. Service providers may not bill the applicant during this non-usage period.
Applicants may work with their service provider to restart services that have been terminated (e.g., where a hotspot is redistributed) once per funding year. However, applicants that take such action to restart service after termination will be subject to program integrity reviews and therefore, applicants should take steps to ensure that they have the associated need prior to restarting services terminated for non-usage.
In the event of a terminated line of service resulting from the non-usage requirement, service providers are prohibited from billing the applicant for the balance that was not paid for by the E-Rate program. Service providers will be required to certify on their FCC Form 473 (Service Provider Annual Certification (SPAC) Form) that they will comply with this non-usage notice and termination requirement and will not charge applicants the balance for the terminated services.
26. What records do I need to keep if I request funding for Wi-Fi hotspots?
For each Wi-Fi hotspot, applicants are required to maintain an asset and service inventory that identifies: 1) the equipment make/model; 2) the equipment serial number; 3) the full name of the person to whom the equipment was provided (for schools only) (Note: Entities may anonymize or deidentify any personally identifiable information when producing asset and service inventories); 4) the dates the equipment was loaned out and returned, or the date the school was notified that the equipment was missing, lost, or damaged; and 5) the service detail (i.e., a phone number or unique identifier for the line of service).
No. However, both schools and libraries are required to adopt and provide notice to the Wi-Fi hotspot recipients of an acceptable use policy (AUP) that highlights that the goal of the hotspot lending program is to provide broadband access to students and library patrons who need it. Per FCC Order 24-76, it is up to the schools and libraries themselves to determine who should be getting hotspots and how people should request them. This approach will not require applicants to document whether a particular student, school staff member, or library patron has unmet need. However, there is an exception for one-to-one initiatives (see Question 26).
28. How do I apply for Wi-Fi hotspots on the FCC Form 470?
— For recurring mobile wireless Internet services, select “I seek bids for wireless Internet services that can be delivered with a Wi-Fi hotspot for off-premises use.” This can be found under: “I seek bids for internet access and/or data transmission service.”
— For Wi-Fi hotspot devices, select “I seek bids for Wi-Fi hotspots for off-premises use.” This can be found under: “I seek bids for Category One network equipment or maintenance and operations.”
29. Should the Wi-Fi hotspot and the service be requested on two separate FCC Forms 471?
No, off-premises Wi-Fi hotspot devices and associated service lines may be requested on the same FCC Form 471. However, for ease of administration and to streamline review of funding requests, Wi-Fi hotspots, services, as well as any eligible components or fees should be requested on separate funding line items when seeking support for these equipment and services, and applicants and service providers should itemize eligible components when invoicing. Additionally, off-premises Wi-Fi hotspots and services should be requested on a separate FCC Form 471 from requests for on-premises Category One and Category Two equipment and services.
30. Is an RFP required for Wi-Fi hotspots or service?
No, but applicants should ensure they provide sufficient information for potential service providers to bid, such as the anticipated service area.
CIPA applies to school- or library-owned computers if the school or library receives E-Rate (or ECF) support for Internet access, Internet service, internal connections, and/or the related network equipment. Wi-Fi hotspots qualify as eligible “Network Equipment” for Internet access, Internet service, or internal connections and therefore triggers the need for CIPA compliance. Specifically, CIPA requires schools and libraries that have computers with Internet access to certify that they are enforcing a policy of Internet safety that includes the operation of a technology protection measure (e.g., a filter). Schools and libraries are required to block or filter visual depictions that are obscene, child pornography, or harmful to minors across all sites, including social media. CIPA also requires monitoring the online activities of minors and providing education about appropriate online behavior, including warnings against cyberbullying.
Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org