Monday, March 23, 2020

E-Rate Gift Rule Guidance and FAQ!

Good morning, Idaho E-rate family,

Based on the questions I have been receiving, it’s obvious that you’re focused on the immediate need of continuity of operations and not so much on your FY2020 E-rate applications. Here is a bit of guidance I have currently and some answers to some common questions from last week (not FY 2020 Form 471 related). Please keep them coming, no matter what they are. 

Filtering School-Owned Devices: Currently, only school-owned devices, using school-provided internet, while on school campus, must be filtered. So, if you’re providing laptops and/or hotspots to students, the current E-rate rules do not require filtering.  

E-rate Eligibility of Hotspots or Air-cards:  Since FY 2015, hotspots or air-cards have very limited E-rate eligibility which is that they can only be used on school or library property, and only in the rare situation where a building cannot have a wireless network installed (such as a bookmobile or juvenile justice facility). In other words, the current E-rate rules do not permit schools/libraries to request E-rate funding for hotspots or air-cards that will be used in student/patron homes.     

Parking Lot Wi-Fi: I’ve heard of several ID libraries and schools who are allowing/encouraging the community to use their free Wi-Fi in the library parking lot, in the safety of their cars. As long as the Internet doesn’t extend beyond the school or library’s property boundary, I don’t think there are any E-rate rules that would prohibit it. In fact, it’s a fantastic idea. If you know of any schools or libraries that are making their Wi-Fi available to the public from their parking lots, please let me know (and share a picture if you can).  

School/Library Internet Beyond Property Boundaries:  Under current FCC rules, allowing anyone to use E-rate-funded Internet beyond your property boundary is not permitted. However, to the extent that you can operationally allow Internet to wirelessly reach student homes, and are interested in providing this service, please let me know ASAP. We at the SDE are putting together guidance that would provide options to reach these homes in need.

Gift Rule Waiver FAQs: 
Q1:  When it mentions service providers, does that only refer to providers that schools and/or libraries are currently using (e.g. on record with USAC as their current provider)? Or could it be a provider they are not currently using? 
A:  Any service provider can be asked for assistance and any provider can offer assistance. 

Q2:  Could E-rate service providers donate ‘other things of value’ such as end-user equipment? 
A:  Yes.  Any service or equipment that is related to continuity of services because of the pandemic is permitted.  

Q3:  What happens to the service or equipment after September 30?
A:  No answers on this yet but don’t worry about that right now. We’ll figure out those details later. 

Q4:  Can schools/libraries request donations/upgrades or must they wait for service providers to offer them? 
A:  It goes both ways; applicants can request donations/upgrades or service providers can offer them. 

Q5:  Are service providers obligated to provide assistance? 
A:  No, service providers are under no obligation to help.

I know most of you are working really long days right now. Please let me know what other questions you have, and how I can help.

Thanks,
Todd


Thursday, March 19, 2020

FCC Waives E-rate Gift Rules Through Sept 30

FCC Waives E-rate Gift Rules Through Sept 30

On March 18, 2020 the FCC issued an Order that waives the E-rate program gift rules through September 30, 2020 to clear the way to allow service providers to offer free or discounted service and equipment to schools and libraries during the COVID-19 emergency.

Specifically the Order permits service providers to offer, and eligible E-Rate schools and libraries to solicit and accept:

  • Upgrades to broadband connections or improved capacity (more bandwidth)
  • Wi-Fi hotspots/aircards and other connected devices
  • Networking gear
  • Other things of value that could help students, teachers, and library patrons affected by school and library closures

The Order goes on to state that to the extent service providers are willing to offer free or reduced-cost Internet access service directly to families with school-aged children, rather than to eligible E-Rate schools and libraries on behalf of students, the E-rate gift rules do not apply.  In other words, there are no rules that will prohibit a school or library from contacting service providers to ask for their assistance in providing Internet access to students, teachers and library patrons that may not have it at home. 

Please let me know if you have any questions.  


Be safe everyone! 

Todd 

Friday, March 13, 2020

FCC Announces the 471 Window Change!!!

Hello Everyone, 

In light of the school closings nationwide due to the COVID-19 virus, the FCC has extended the FY 2020 Form 471 filing window deadline until Wednesday, April 29, 2020 (a 35-day extension).   

During this time, PIA reviews will continue and applicants that have submitted applications will receive PIA inquiries.  However, the FCC has directed USAC to provide all applicants with an automatic 14-day extension for PIA requests.

I strongly encourage you to file by the original March 25, if possible.  The earlier you file, the sooner you will be funded. 

We are going to also request the FCC to consider providing relief to all other deadlines that may occur during this month, including appeals, 486 deadlines, audits, etc. I will be in touch if and when I have any updates about those deadlines. 

Form 470 Deadline:  Although the FCC’s Notice did not mention this, I believe that those of you that missed the original Form 470 deadline have been given an unintentional gift because with this extension, you presumably now have additional time to post Form 470s and be able to meet the new April 29, 2020 deadline.  

During this time, I will continue to be available to assist with your E-rate filings. The best way to reach me is always via e-mail at tlawrence@sde.idaho.gov

I have included a link to the FCC announcement below. 

https://docs.fcc.gov/public/attachments/DA-20-273A1.pdf


Happy Filing and Stay Safe! 


Thanks, 

Todd