PA CyberPilot Update – July 2025

July 14, 2025

Good morning, PA CyberPilot Participants!  I have several new items of interest related to FCC’s CyberPilot Program (CPP) as well as some reminders.  The CPP Form 471/Form 484 Part 2 deadline is September 15, so if you have not started your procurement process, you will want to do so ASAP in order to have enough time to meet this deadline.

CPP Dropouts – To date, 15 CPP participants nationwide have opted out of the program, relinquishing about $7.9 million.  This should be more than enough to cover the $3.8M that’s needed to fully fund the 16 original partially-funded participants, including 2 in PA, and possibly award participation to other applicants that didn’t make the original cut-off.  Once an applicant opts out of the program, the FCC sends a formal letter saying they will be removed from the program five business days after the letter is issued, and the funding will be reallocated to another participant.  No word yet on how the partially-funded participants will be notified when their budgets have been fully funded, or if/how the FCC will decide to select additional applicants for participation in the CyberPilot. 

Considering Opting Out of CPP?  If you will not be using any of your CPP grant, even if you didn’t meet the July 1, 2025 deadline to notify the FCC of your decision to withdraw, you can still submit your intention to the FCC in writing.  Certainly, we don’t want any PA applicants to withdraw, but if you intend to do so, please do so as soon as possible.

Bid Evaluation Criteria Not Required in RFP – The CPP Form 471 and 471 Guide imply that applicants are required to include their bid evaluation criteria and weights in their RFPs.  USAC has confirmed that this is not an actual requirement.

CPP Form 471 Reviews and FCDLs – It appears that USAC has not yet begun reviewing CPP Form 471s.  Likewise, CPP Funding Commitment Decision Letters (FCDLs) have not yet begun to be issued, and there has been no mention of when either reviews or FCDLs will begin.

Update on How CPP Reimbursements Will be Made – Although the FCC’s CyberPilot FAQs state that CPP payments will be made via SAM.gov, we have learned that this will likely not happen and the reimbursement payments will be issued the same way E-rate BEAR payments are issued which is via the bank account information on the Form 498.  If you don’t have an approved Form 498 on file with USAC, you will want to start this process right away.  Note:  If you create a new Form 498 or modify your existing Form 498, you will be required to list your federal UEI number.  And if you don’t have this number, it can take several months to obtain it from SAM.gov. 

How to Make Modifications to Submitted CPP Form 471 – There will be a new form available after FCDLs are issued, called the CPP Form 488.  On this form, applicants will be able to make modifications, such as Service Substitutions, SPIN Changes, FRN Reductions or Cancellations.  We are hoping that there also will be a method during PIA review to make modifications, similar to the current RAL modification process.  Stay tuned for more information on making changes.

Two Service Provider-Related Issues: 

  • USAC does not send service providers notice or copies of the submitted Form 471s on which their SPIN is listed.  Additionally, there is no public database that shows what Form 471s have been submitted.  Therefore, after you submit your CPP Form 471, please be sure to download and send a copy to your service provider(s) so they have a copy for their records. 
  • Some vendors have stated they are having difficulty downloading RFP documents and we’ve recently discovered that this is a legitimate issue.  USAC has provided this advice:
    • Some browsers may not automatically initiate downloads after clicking on the URL.  In this case you can right click on the URL, select “copy link address” and paste it in a new browser tab to initiate the download.  If a security flag appears, you can select “keep.”

CPP PEPPM Mini-Bid Procedures/Form 471 Filing – If you will be using the CPP PEPPM mini-bid for your CyberPilot procurement(s), begin by reviewing the comprehensive step-by-step CyberPilot PEPPM Mini-Bid Guide, available at: e-ratepa.org/?page_id=35967, and then be sure to use the CPP PEPPM resources on that page.  CPP PEPPM uses different product lines, a different cover e-mail template, and a different mini-bid template than the traditional E-rate PEPPM mini-bid.  

Form 471 Using PEPPM:  If you’re citing PEPPM on your CPP Form 471, you will answer the FRN Procurement Questions as follows:

  • Is this a State Master Contract?  Yes
  • What is the Contract/State Master Contract ID?  You can leave this blank, or you may want to list the PEPPM contract number that corresponds to the product line for which you are purchasing.  See Column H of the PEPPM Cybersecurity Product List.
  • What is the Establishing Form 470?  259999999 (this is a generic 470 number that the CPP Form 471 Guide instructs you to use). 

CyberPilot Form 470 – If you are not using the PEPPM Contract as your procurement vehicle, please post your CPP Form 470 as soon as possible.  Many applicants have been reporting numerous (literally hundreds) vendor questions related to their RFPs, so you will want to build in a 2-week vendor question cut-off date, then upload answers to those questions, and set the proposal due date for 29 days after that.  Be sure that if you are mentioning a preferred product line that you always include “or equivalent” to allow other manufacturers to submit proposals.  CPP Form 470 User Guide:  Pilot-FCC-Form-470_User-Guide.pdf. 

Form 484 Part 2 – CPP Participants must complete the Form 484 Part 2 to provide additional information related to their cybersecurity data and Pilot project information.  This is a confidential, but required, form and may be submitted now, but is not due until September 15, 2025.  Note:  No FCDL can be issued until the Form 484 Part 2 has been submitted.  This form is fairly simple, so don’t put it off.  It can be submitted in advance of our CPP Form 471 submission.  Form 484 Part 2 User Guide:  Pilot-FCC-Form-484-Part-2_User-Guide.pdf.

CyberPilot Form 471 – The CPP Form 471 can be found on the CyberPilot page in EPC by clicking on the waffle (9 squares) in the upper right corner of your EPC Landing Page.  Then click on Actions on the right side of the page.  It’s a fairly easy form, very similar to the E-rate Form 471.  CPP Form 471 User Guide:  Pilot-FCC-Form-471_UserGuide.pdf.

What if I Don’t See the Form 471 (or 484 part 2 or 470) option on our CyberPilot page?  This likely means that your EPC Account Administrator has not given you permission to file this form.  Your EPC AA can grant you permission under Related Actions > Manage User Permissions (see slide 31 at: EPC-How-To-Guide-as-of-Nov-2024.pdf). 

Additional Resources:

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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