The FCC unveiled its Final Report and Order for the $7.171 billion Emergency Connectivity Fund ("ECF") on May 11.
Congress created the ECF as part of the American Rescue Plan Act as a means to help address the "Homework Gap." The basic principle of ECF eligibility is the concept of “unmet need.” The ECF is thus intended to ensure that “at need” students and educators have access to a device and services that fosters off-campus learning. To achieve that end, the ECF will reimburse 100% of the costs associated with the purchase of "eligible equipment" and/or advanced telecommunications services. Click here to download an ECF Fact Sheet.
The FCC will open an initial 45-day filing window, most likely in late June.
The initial window will address prospective purchases of eligible equipment and services made between July 1, 2021 and June 30, 2022.
To be eligible for the initial window, delivery of eligible equipment may not occur prior to July 1, 2021.
The ECF will leverage the existing E-rate funding application (i.e., FCC Form 471) and other E-rate processes (to the extent possible).
Additional Filing Window
If funds remain after the initial window, a second application window will address funding requests for funding for purchases made between March 1, 2020 to June 30, 2021.
If demand exceeds available funds, eligibility for reimbursements will be prioritized based on applicants’ E-Rate discount rate for Category One services. Schools entitled to a higher discount will receive funding before those entitled to a lower discount rate.
Equipment and Services Eligibility
Eligible Equipment
"Eligible equipment" is defined as (1) Wi-Fi hotspots, (2) modems, (3) routers, (4) devices that combine a modem and router, and (5) other "connected devices."
"Connected devices" are defined as laptop computers, tablet computers, or similar end-user devices. Note that desktop computers are NOT eligible for funding support under any circumstances. Also no break/fix or replacement allowance.
Must be used primarily for “educational purposes”, which are defined as “activities that are integral, immediate, and proximate to the education of students.”
Eligible Services
Advanced telecommunications and information services” are defined as commercially available services providing a fixed or mobile broadband connection for off-campus use by students, school staff, or library patrons.
Hotspot data plans are eligible for ECF support provided the monthly cost is deemed “reasonable” by USAC.
Eligibility Limitations
One device/hotspot per student.
One fixed connection per home with no minimum bandwidth standards.
Smartphones and desktops are not eligible for ECF support.
Caps on Reimbursement
Reimbursement on connected devices will be capped at $400.
Reimbursement on hotspots will be capped at $250.
There are no guidelines yet for the “reasonable” cost of commercially-available internet service; USAC has discretion to determine whether costs are reasonable.
Competitive Bidding
No mandated competitive bid process.
Applicants must comply with state and local procurement requirements and certify as much in their funding applications.
Application & Invoicing Process
The ECF will leverage the existing E-rate funding application (FCC Form 471) and other E-rate processes.
Invoicing & Related Issues
Applicants will be required to provide all purchase orders, invoices, and other related documents to USAC prior to receiving a funding commitment.
Applicants will be able to use either the BEAR or SPI invoicing method.
Applicants who have entered into contractual arrangements to purchase eligible equipment and servicesmay submit requests for reimbursement before they have paid for the requested equipment and services. In such cases, applicants must pay within 30 days after receipt of funds and will be required to certify compliance and provide verification of payment.
You will be required to indicate your preferred method on the Form 471 when submitting funding request(s).
SAM Registration
Applicants will be required to be registered in the federal.
Applicants who are not registered may still file for ECF support but will not receive disbursements until the SAM registration process is complete.
Inventory and Document Retention
Applicants must keep an inventory of devices provided to individuals, including who the device was loaned to and when it was returned (similar to other circulation records). Applicants must retain ECF-related documents for at least 10 years.
Certifications
As part of the application process, applicants will be required to make the following certifications as part of their funding applications (along with several other standard certifications):
Complied with all applicable local and state procurement requirements for any equipment and services purchased, or that will be purchased, with ECF Program support.
Seeking support for eligible equipment provided only to students and school staff who would otherwise lack access to connected devices sufficient
to engage in remote learning.
Seeking support for only eligible services provided to students and school staff who would otherwise lack broadband services sufficient to engage in remote learning.
The equipment and services are being primarily used for educational purposes by students and school staff, and both the applicant and service provider(s) are not willfully or knowingly requesting reimbursement for equipment or services that are not being used.
Not seeking ECF support for eligible equipment or services that have been purchased and reimbursed with other federal pandemic-relief funding (e.g., CARES Act, EBB Program), targeted state funding, etc.
CIPA Compliance
CIPA requirements apply to all school-owned connected devices unless the applicant does not receive E-rate funding support on either category of service or ECF support on eligible services.