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