E-rate Update – November 2024

November 20, 2024

Personal note – E-raters, the week before Thanksgiving is my favorite time of year.  Life seems to slow down, our house is cleaned and shined, my (now grown) daughter spends time at home, and I find myself reflecting on how much I have to be truly thankful for.  And you, E-raters, are all counted among my blessings – the educators and librarians that make our kiddos and communities better and for whom I count as friends, despite only knowing many of you via e-mail.  Thank you for doing what you do.  I hope you all have a wonderful, relaxing, safe holiday, surrounded by family and friends.  ~ Julie

Here are a few E-rate updates (some very important) and reminders to keep you on track.  Please review each of these items and let me know if you have any questions.

Carr Nominated as FCC Chair – Last week, Brendan Carr, one of the current two Republican FCC Commissioners, was nominated to be the incoming Chair of the FCC.  The current Chair, Jessica Rosenworcel, is expected to step down closer to January 21, and then a third Republican will be nominated to serve as the 5th FCC commissioner. 

Future of Bus Wi-Fi and Off-Campus Hot Spots – With the upcoming change in administrations, all E-rate eyes are on previous statements made by the two current Republican FCC Commissioners – Carr and Simington – related to the E-rate eligibility of school bus Wi-Fi and off-campus hotspots.  Both commissioners have previously opposed both initiatives, stating that the Telecommunications Act only permits providing Universal Service funding within the physical bounds of classrooms and libraries.  Due to these previous positions, I strongly encourage PA schools and libraries seeking funding for school bus wi-fi and/or off-campus hotspots to ensure their vendor contracts include non-E-rate funding out clauses to protect you in case the future FCC rescinds these programs.  

Constitutionality of USF – In July 2024, the 5th U.S. Circuit Court of Appeals found that the Universal Service Fund (USF) was unconstitutional.  In earlier decisions, both the 6th and 11th Circuit Courts found the opposite – that the USF was constitutional.  Both the Justice Department as well as the petitioners have petitioned the U.S. Supreme Court to hear the case.  Due to the split amount Circuit Courts, we expect the Supreme Court will likely agree to hear the case, with oral arguments coming sometime next year.  In the meantime, E-Rate and the other three USF programs are operating and will continue, “business as usual.”  Please continue with your FY 2025 application process, just as you have in previous years and I’ll keep you posted as the case proceeds.

FY 2025 Form 471 Filing Window Dates — The FCC approved the official FY 2025 Eligible Services List (ESL); however, USAC has not yet announced the FY 2025 Form 471 Filing Window dates.  All indications are that they expect the window dates to be very similar to last year, which means it will likely open around the second week in January and close around mid-late March, 2025.  Regardless of the exact dates – file your Form 470’s now!

Post Form 470’s or Issue PEPPM Mini-Bids Now! – If you haven’t done so already, please review what Category 1 contracts are expiring, and determine what equipment you will need for FY 2025.  My suggestion is to begin your procurements no later than the first week in December, evaluation your bids in January, take the new contracts to your board in February, and then submit the Form 471 in late February/early March.  The sooner you release these bids, the less stress you will feel in February and March.  Here are recent messages to help you with these filings:

Admin Window Open – The E-rate “Administrative Window” is the period before the 471 Application Window opens, during which time schools update their enrollment and NSLP (or CEP%) data in each school’s EPC profile, update their Category 2 enrollment data (if it increased), and libraries update their square footage (if it changed).  The Admin Window is now open and is expected to close the first or second week in January.  Schools are required to update their EPC profiles with their fall 2024 data.  In mid-December, I will send to the listserve a spreadsheet from PDE that provides the enrollment, NSLP (or CEP%) data along with a guide that will walk you through the process for updating each school’s EPC profile.  If your school does not participate in NSLP (some nonpublic schools, for example) please go ahead and update your data in EPC now as there is no need for you to wait for the PDE data (last year’s Guide is available to use). 

New Functionality in EPC to Cancel Form 470 – For the first time since the E-rate program began, applicants can now cancel a certified Form 470.  The only catch is that the Form 470 can’t be cited on any Form 471, regardless of that 471’s status (meaning incomplete, pending or committed).  To cancel a submitted Form 470 that isn’t yet “attached” to a Form 471:  Locate Form 470 > Related Actions > Cancel this FCC Form 470.  Hurray!

New Functionality to Upload RFP Documents – The FY 2025 Form 470 has added the functionality to allow RFP documents to be uploaded to an existing Form 470, even if no RFP document was originally uploaded.  The system will also ask if this is a substantial change, and if you answer yes, the system will reset and extend your Allowable Contract Date by an additional 28 days.  Find 470 > Related Actions > Add RFP Document

Category 2 Budgets – What’s Remaining for Your School or Library — FY 2025 is the 5th and final year of the current 5-year Category 2 budget which spans FY 2021 – FY 2025 so if you need any eligible equipment, licenses or cabling, be sure to begin the procurement process now so you can use these remaining funds in FY 2025!   C2 budgets are calculated based on the C2 multiplier ($167/student – or a minimum of $25,000/building) and the Category 2 enrollment that’s currently in EPC.  The school enrollment or library square footage figure used for C2 budgets can be different from the enrollment used for discount calculations.  Schools can use the same C2 enrollment for the entire budget cycle or modify it if enrollment has increased to take advantage of the higher C2 budget.   To see your remaining C2 budget for FY 2025 (as of 9/16/2024), see:  Remaining-C2-Budgets-as-of-Sept-16-2024-1.xlsx.  If you update your C2 enrollment in EPC or return an unspent commitment from a prior funding year, the C2 budget will change and the results can be found on USAC’s C2 Budget Data Tool at: E-Rate-C2-Budget-Tool-FY2021-/8z69-hkn7.  Simply use the filter on the right side of the page.

Unspent C2 Funding from Prior Years? – If you were committed funding in Funding Years 2021, 2022, 2023 or 2024 and your expenses were not as high as you anticipated or you didn’t need the funding, you may want to file a Form 500 to cancel or reduce the FRN.  Why?  Because these remaining funds will be put back into your Category 2 budget for the remaining year of this C2 budget cycle.  Please note:  If you don’t use the funding and don’t file the Form 500, the funds aren’t automatically reinstated into your account.  You must take this proactive step to reduce the funding commitment to get the funds back into your C2 budget.  To determine if you have undisbursed C2 funds from a prior E-rate funding year since 2021 and learn how to “decommit” those funds back into your C2 budget, see:  https://e-ratepa.org/?p=35679.

Changing EPC AAs, Adding or Removing Users, Removing Old Consultants, Adding Text MFA Option – If you’re looking for instructions on how to accomplish any of these tasks, please see the updated EPC How To Guide:  EPC-How-To-Guide-as-of-Nov-2024.pdf.

If you have any questions about any of these items, please let me know!  Happy Thanksgiving, one and all!

— Julie

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

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