{"id":35170,"date":"2023-11-13T02:51:06","date_gmt":"2023-11-13T02:51:06","guid":{"rendered":"http:\/\/e-ratepaorg.local\/?p=35170"},"modified":"2023-11-15T00:40:08","modified_gmt":"2023-11-15T00:40:08","slug":"fcc-proposes-to-make-hot-spots-e-rate-eligible","status":"publish","type":"post","link":"https:\/\/e-ratepa.org\/?p=35170","title":{"rendered":"FCC Proposes to Make Hot Spots E-rate Eligible"},"content":{"rendered":"<p><span style=\"color: #222222;\">November 13, 2023<\/span><\/p>\n<p>Last week, the FCC released a\u00a0<a href=\"https:\/\/nam10.safelinks.protection.outlook.com\/?url=https%3A%2F%2Fwww.fcc.gov%2Fdocument%2Ffcc-proposes-e-rate-support-wi-fi-hotspots&amp;data=05%7C01%7Cpl-erate%40lists.psu.edu%7C61c3d294d63d41bada4e08dbe499a374%7C7cf48d453ddb4389a9c1c115526eb52e%7C0%7C0%7C638355120747377255%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000%7C%7C%7C&amp;sdata=ol5NVUSlHtrdQhdsOeQ%2Bn0BhKHMGEF%2FpFCF8kq4XYis%3D&amp;reserved=0\" target=\"_blank\" data-saferedirecturl=\"https:\/\/www.google.com\/url?q=https:\/\/nam10.safelinks.protection.outlook.com\/?url%3Dhttps%253A%252F%252Fwww.fcc.gov%252Fdocument%252Ffcc-proposes-e-rate-support-wi-fi-hotspots%26data%3D05%257C01%257Cpl-erate%2540lists.psu.edu%257C61c3d294d63d41bada4e08dbe499a374%257C7cf48d453ddb4389a9c1c115526eb52e%257C0%257C0%257C638355120747377255%257CUnknown%257CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%253D%257C3000%257C%257C%257C%26sdata%3Dol5NVUSlHtrdQhdsOeQ%252Bn0BhKHMGEF%252FpFCF8kq4XYis%253D%26reserved%3D0&amp;source=gmail&amp;ust=1700016047303000&amp;usg=AOvVaw0-9vObncVl9hEz-CrJVZWq\">Notice of Proposed Rulemaking<\/a>\u00a0(NPRM) that proposes to make Wi-Fi hotspots and related mobile broadband services eligible for E-rate for students, teachers and library patrons who otherwise would not have Internet access off campus.\u00a0 \u00a0The FCC is seeking comments on this proposal, as well as more than 140 implementation-related questions.\u00a0 I\u2019ve tried to summarize below the main concepts of their 53-page proposal and where I think the FCC may be headed.<\/p>\n<ul>\n<li><strong>Timing<\/strong>:\u00a0 The comment cycle has yet to be established, but we expect comments will be due mid-December, with reply comments due two weeks later.\u00a0 After that, the FCC will review comments and release an Order with complete program eligibility and details.\u00a0 I would be surprised to see a final Order before mid-January 2024.<\/li>\n<li><strong>Funding Year:<\/strong>\u00a0 The proposal does not explicitly state that hotspots\/mobile Internet will be eligible beginning in Funding Year 2024, but with the Emergency Connectivity Fund (ECF) program sunsetting June 30, 2024, I expect the FCC will try very hard to ensure there is no gap between programs. \u00a0In fact, the NPRM asks whether they should limit initial eligibility to just services (no hotspots) or similarly, just the services associated with the hotspots purchased using ECF program funds.\u00a0 Because of the late-nature of the NPRM release, this may be where the FCC is headed for FY 2024.<\/li>\n<li><strong>Equipment\/Service Eligibility:<\/strong>\u00a0 The proposal closely mirrors the ECF hotspots and related internet services eligibility.\u00a0 One per user, no cellular phones, no multi-user hotspots.\u00a0 However, unlike ECF, hotspots would be subject to E-rate discounts.<\/li>\n<li><strong>Eligible Users:<\/strong>\u00a0 Students, teachers and library patrons who otherwise lack internet access outside of the school or library will be eligible, but not including Head Start and Pre-K students.\u00a0 Unlike ECF, the FCC appears they may be considering a financial hardship component such as a student\u2019s participation in NSLP, in addition to whether the user just lacks Internet access (has an unmet need).\u00a0 Also, the FCC appears to want more than an estimate of how many users will have an unmet needs when they submit their For 471s; they are considering requiring\u00a0schools and libraries to conduct and submit as part of their funding requests their survey results or other documentation that substantiates their student and school staff, or patron population with current unmet needs.<\/li>\n<li><strong>Bidding<\/strong>:\u00a0 There are no specific bidding rules proposed, but they do ask numerous bidding and cost containment-related questions.\u00a0 For example, should a per plan cap be adopted to ensure a service is cost effective.<\/li>\n<li><strong>Usage Documentation:\u00a0\u00a0<\/strong>The FCC appears to be very serious about ensuring that any E-rate-funded off-campus mobile broadband services are actually used.\u00a0 They propose that service providers must provide the school or library with notice if a user has not used the service within the last 30 days, and prohibit E-rate reimbursements for any service plans that were not used.<strong>\u00a0\u00a0<\/strong>They seek comment on how to avoid having E-rate pay for hotspot service during the summer months.<\/li>\n<li><strong>Documentation: \u00a0<\/strong>Just like ECF, it appears that for each hotspot purchased with E-rate support, a school or library must maintain the device make\/model, the device serial number, the name of the person to whom the device was provided, and the dates the device was loaned out and returned to the school or library.\u00a0 For hot spot services, the school or library\u2019s inventory must include the type of service provided, the broadband plan details (i.e., upload and download speeds and the monthly data cap), and the name of the person to whom the service was provided.<\/li>\n<li><strong>Audits<\/strong>:\u00a0 The program will be subject to the current E-rate audit program and reviews, and the FCC is considering increasing the number and frequency of random or targeted audit of these services in order to detect and prevent unused hotspots and services or where they are not being used for educational purposes.<\/li>\n<li><strong>Duplicative Funding<\/strong><strong>:<\/strong>\u00a0 The FCC wants to ensure that families receiving federal Affordable Connectivity Program (ACP) funding for Internet to the home will not also have access to an E-rate-funded hotspot\/service.<\/li>\n<li><strong>CIPA<\/strong>:\u00a0 The proposal seeks comment on the applicability of the Children\u2018s Internet Protection Act (CIPA) requirements and the off-premises use of E-Rate-supported hotspots and services.<\/li>\n<\/ul>\n<p>If you would like to submit comments to any of the questions\/proposals in the NPRM and need assistance with your submission, please let me know.\u00a0 As I learn more about this initiative, I\u2019ll send details to the listserve.<\/p>\n<p>&#8212; Julie<\/p>\n<p>Julie Tritt Schell<br \/>\nPennsylvania E-rate Coordinator<br \/>\n717-730-7133 &#8211; o<br \/>\njtschell@comcast.net<br \/>\nwww.e-ratepa.org<\/p>\n\n<div class=\"twitter-share\"><a href=\"https:\/\/twitter.com\/intent\/tweet?via=eratepenn\" class=\"twitter-share-button\" data-size=\"large\">Tweet<\/a><\/div>\n","protected":false},"excerpt":{"rendered":"<p>November 13, 2023<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"closed","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[52],"tags":[],"class_list":["post-35170","post","type-post","status-publish","format-standard","hentry","category-listserve_archive"],"_links":{"self":[{"href":"https:\/\/e-ratepa.org\/index.php?rest_route=\/wp\/v2\/posts\/35170","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/e-ratepa.org\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/e-ratepa.org\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/e-ratepa.org\/index.php?rest_route=\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/e-ratepa.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=35170"}],"version-history":[{"count":0,"href":"https:\/\/e-ratepa.org\/index.php?rest_route=\/wp\/v2\/posts\/35170\/revisions"}],"wp:attachment":[{"href":"https:\/\/e-ratepa.org\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=35170"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/e-ratepa.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=35170"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/e-ratepa.org\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=35170"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}