FCC Extends Procedural Deadlines

Yesterday, April 1, 2020, the FCC provided additional relief to applicants and service providers by extending several upcoming procedural E-rate deadlines due to the pandemic. However, they did NOT extend the April 29, 2020 deadline to file the Form 471. Please let me know if I can assist you with getting everything filed before the deadline.    

Summary of Relief granted:

• PIA Inquiries:  In addition to the 14-day extension the FCC previously granted, applicants will have an additional 30-days to respond to PIA requests. (I don’t believe the EPC system will update the due-dates due to system limitations). Also, please keep in mind that the sooner you respond to these requests, the sooner you’ll receive your funding commitment decision letter (FCDL). 

• Equipment Installation:  Deadline to purchase/install all FY2019 non-recurring services (equipment) is extended from September 30, 2020 to September 30, 2021. By extension, this will automatically make the invoice deadline for all FY2019 non-recurring FRNs January 28, 2022.

• Special Construction: Deadline to complete special construction of FY2019 Category 1 fiber networks is extended from June 30, 2020 to June 30, 2021. In addition, any FY2018 applicants that had already requested/received a one-year extension also will be granted the additional year to complete the special construction.  

• Appeals/Waivers: Deadline to submit appeals to USAC or the FCC is extended from 60 days to 120 days for all USAC decisions dated January 11, 2020 – August 1, 2020. 

• Reimbursement Forms to USAC:  Deadline is extended an additional 120 days for any Form 472 BEAR Reimbursement Form (or vendor SPI) with a current deadline that falls between March 11, 2020 - October 28, 2020. This applies even if you already received an invoice extension for the FRN in question.

• Form 486:  Deadline is extended an additional 120 days for FY2019 Form 486s that would have been due between March 11, 2020 - September 30, 2020.

• Information Requests for Audits, Form 500’s, Appeals, and Invoices:  Applicants will have an additional 30 days to respond to USAC information requests for BCAP Audits, PQA Audits, Form 500s, Appeals and Invoice Reviews. 

In addition, I think the biggest news stemming from yesterday’s Order is actually in the press release, which provided this quote from FCC Chairman Ajit Pai:

“In light of extended school and library closures, we’re granting an across-the-board, one-year extension of the E-Rate special construction deadline for funding year 2019,” said Chairman Ajit Pai. “By providing this proactive relief, we want to ease burdens on schools and libraries to allow them to focus their time and resources on transitioning their students, patrons, teachers, and staff to remote learning during this crisis. This is yet another step the FCC is taking to offer help to students and teachers in need—and I look forward to continue working with Congress to fund a Remote Learning Initiative so that every child can continue being educated during the pandemic.”

Please let me know if you have any questions or how I can help.

Stay safe and health.

Todd

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

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.  

The Order can be found at:  https://docs.fcc.gov/public/attachments/DA-20-290A1.pdf

Be safe everyone! 

Todd 

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 

FCC Form 471 Instruction Guide FY2020

Hello Everyone, 

I have created an instruction guide for completion of the FCC Form 471. This has a few Category 1 examples specifically, but can give a good understanding for a Category 2 filing as well. Please let me know if you have any questions.

471 Guide: FCC Form 471 Instructional Guide

Let me know if there are any questions regarding the process or content. 

Thanks, 
Todd 

Deadline Reminder - FCC Form 470 Filing for FY2020

Hello Everyone, 

I want to remind everyone of the upcoming deadlines. The last possible day to file the FCC Form 470 for FY2020 is February 26, 2020. If possible, please do not wait until this day to file as there will not be any room for error if so. 

This deadline is based on the requirement of the FCC Form 470 must be posted for a minimum of 28 days before action can be made and file your FCC Form 471 in time before March 25, 2020 FCC Form 471 deadline. 

Funding Year 2020 Deadline Recap: 
FCC Form 470: February 26, 2020
FCC Form 471: March 25, 2020 

Please let me know if there are any questions that may come up. 

Thank you, 
Todd 

FCC Form 470 Completion Instructions FY2020

Hello Everyone,

I have created an instruction template for completion of the FCC Form 470. This example is for a Category 1 service, but can be used for Category 2 service as well as there are only a few differences.  Please let me know if you have any questions.


FCC Form 470 Diagram


Happy Filing!
-Todd