The FCC has announced that a very short 3^rd application window for the Emergency Connectivity Fund (ECF) will be open from April 28 – May 13, 2022 during which time schools and libraries can submit applications for purchases that will be made between July 1, 2022 – December 31, 2023.   The FCC estimates approximately $1 billion will be available for ECF Window 3, and if demand is greater than available funds, the applicants with the highest E-rate discounts will receive priority, with rural applicants receiving priority within each discount level.  Below (and available on this website) is a summary of what equipment/services are eligible and the rules related to these purchases (which are generally the same as the previous two windows).

Emergency Connectivity Fund (ECF) Window 3 Summary

In March, 2021, Congress passed a new, one-time $7.1 billion Emergency Connectivity Fund to ensure that all K-12 students, educators and library patrons have sufficient broadband for off-campus remote learning.  Two application windows were available that covered purchases made from July 1, 2021 – June 30, 2022 (subsequently extended to June 30, 2023).  The FCC has announced that a third – very short – application window will be opened from April 28 – May 13, 2022 to cover qualifying expenses that will be made from July 1, 2022 – December 31, 2023, using the remaining $1 billion.  The program’s parameters are as follows:

Qualifying Expenses

• Laptops, tablets (“Connected Devices”), up to $400 each (applicants may seek an FCC waiver if devices are more costly for students with disabilities).  Bundled licenses are eligible but only if they are included in the equipment cost and the cost is not broken out separately.
• Internet service – mobile wireless, cable, DSL and satellite Internet services are eligible.  Other broadband services such as leased lit fiber, fixed wireless, and microwave also are eligible but far less common.  Cellular phone plans do not qualify.
• Other eligible equipment/services – modems, routers, cellular air-cards (hotspots), installation, configuration, taxes.  Internet aircards (hotspots) are eligible up to $250 each, with no cap on the monthly Internet cost.
• Internet on student buses is eligible for both “parked” buses and buses transporting students.  For parked buses, access must be restricted to students (meaning it can’t be opened to the community at large).
• Connected devices and internet services used off-campus are limited to school staff who are involved directly with the education of students such as teachers and para-professionals and who qualify under the “needs” test.
• Vendor contracts are not required but applicants must obtain a vendor quote that should be uploaded with the ECF application.

Eligible Coverage Period (ECF Window 3)

• For equipment purchases:  July 1, 2022 – December 31, 2023.  May be ordered prior to July 1, 2022.
• For Internet service purchases:  A maximum of 12 months of eligible services received or delivered between July 1, 2022 and December 31, 2023.  Applicants that received ECF Internet funding in Windows 1 or 2 (FY 2021) must indicate in their Window 3 Form 471 narrative the service start and end dates for the 12 months of service that will be received for FY 2021 so PIA can ensure that no duplicate months will be funded.

Determining Unmet Needs

• The teacher/paraprofessional or student receiving the device or service must have an unmet need – meaning that without the device or service, they otherwise would not have sufficient access for remote learning.

• On the ECF Form 471 application, schools must describe their “reasonable” efforts to determine need for equipment/services.  However, prior to seeking ECF reimbursement, schools must obtain a signed certification of unmet need from equipment/service recipients.  See:  http://e-ratepa.org/?p=33555.
• Library patrons must sign a statement attesting to need when they check out a device.
• ECF is not a 1:1 initiative.

Conditions and Restrictions

• Internet access must be used primarily for educational purposes.  Devices may only be used by credentialed students, staff or library patrons (meaning, they are not to be shared with family members for non-educational purposes).  Devices may be brought to campus but they are not intended to be primarily used on campus.
• Remote learning includes daytime remote learning and also after-school homework.
• ECF will reimburse 1 Wi-Fi hotspot/student or teacher, or 1 fixed broadband internet connection per home (subject to showing of need).
• Internet service may be requested for any off-campus location where remote learning occurs and there is a documented need.  For example, in addition to homes, community centers, churches, and school buses are eligible locations.
• Spare equipment, desktop computers, smartphones may not be requested/reimbursed through ECF.
• ‘Double dipping’ with other pandemic related funding is prohibited – ECF funding cannot be sought where equipment or services have been or will be purchased or reimbursed with other (pandemic-targeted) federal, state or other external funding or gifts.
• If an applicant receives E-rate or ECF funding for internet access or E-rate Category 2 equipment, they must filter all school/library owned devices – whether the device is used on or off-campus.  This is a new FCC clarification.

Where No Internet Service is Available – If applicants can prove that no commercially available internet access is available, ECF can be used for the installation of new service to an off-campus location.  See: http://e-ratepa.org/?p=33382 for information on how to document and apply for this funding.  Note:  Most Windows 1 and 2 applications for this funding have not been approved.

Competitive Bidding – State and local procurement rules apply (no additional federal bidding requirements (i.e. Form 470)).

Application Portal – ECF applications are filed in the One Portal System, most commonly known as EPC.  To gain entry to One Portal, one must be established as an EPC User for the school or library.  For assistance, contact USAC at 888-203-8100.

Reimbursement

• Deadline for applicants or vendors to seek reimbursement from USAC for purchases made in Window 3 is 60 days from the last date to receive service – generally February 29, 2024.  Deadline to seek reimbursement for purchases made in Windows 1 and 2 is August 29, 2023.

• If applicants cannot afford to pay the vendor up-front, they have two choices:
• Request a “pre-reimbursement payment” from USAC after equipment/services have been delivered.  Applicants must then make payment to vendor within 30 days of receipt of ECF payment.  After vendor payment is made, applicants will then submit to USAC verification that the vendor was paid.

• Request that the vendor seek direct reimbursement from the ECF Fund.  If a vendor agrees, the applicant must confirm this in writing and submit this evidence with their E-rate application.

• Applicants must have an up-to-date registration in Sam.gov to receive ECF reimbursements.

If Demand Exceeds Available Funding – Funding will be allocated to applicants with the highest E-rate discount rate, with rural applicants receiving priority at each discount band.

Records Retention – Applicants will be required to keep detailed records of who received exactly which device/service for a period of ten years, as well as asset inventories, vendor invoices, proof of payment, contracts, etc.

Appeals – Appeals must be submitted within 30 days of the FCDL date.

Additional Resources

• USAC ECF Information: https://www.emergencyconnectivityfund.org/
• ECF Application Portal:  https://forms.universalservice.org/portal/login
• FCC ECF FAQs: https://www.fcc.gov/emergency-connectivity-fund-faqs
• PA ECF Resources:  http://e-ratepa.org/?page_id=32310
• SAM.gov:  https://sam.gov/content/home

The content in this message was created by Julie Tritt Schell, Pennsylvania E-rate Coordinator and is reposted here especially for Pennsylvania libraries who may not have received it via other mailing lists.