The FCC signed into law the American Rescue Plan Act (“ARPA”) on March 11, 2021. As a part of ARPA, Congress established the Emergency Connectivity Fund to provide $7.17 Billion in funding support to schools and libraries to help address the homework gap.

The ECF is intended to ensure that students and educators in need of broadband connectivity have access to a connected device and telecommunication services sufficient to engage in remote learning. To achieve that end, the ECF will reimburse 100% of the costs associated with the purchase of eligible equipment and/or services. 

The foundational principle of ECF eligibility is the principle of “unmet need.”  In the case of schools, applicants will provide their best estimate of the number of students who did not have access to adequate connected devices, broadband connections, or both when the pandemic began; the number of students who currently do not have adequate access; and how the applicant expects those numbers to change with the requested ECF Program support.

While the FCC has not dictated specific data collection requirements for estimating the unmet need for students, schools must describe on the Form 471 how and when they collected the information that they use for their estimates provided.

There is no such data collection requirement for libraries to estimate the unmet need for library patrons. However, both schools and libraries must certify that they are seeking support for eligible equipment and/or services for students, school staff, and/or library patrons that would otherwise lack adequate access.

Click here to access the FCC’s FAQ section on the ECF.

Filing Window

Equipment & Services Eligibility

Limitations & Reimbursement

Invoicing Process

After reviewing the funding requests submitted during the initial filing window this summer, the FCC has determined to open a second window for purchases of eligible products and services made during the 2021-22 fiscal year. The FCC will therefore open this second 15-Day filing window on September 28, 2021 and close on October 13, 2021. 

At E-Rate Consulting, Inc., we submitted over $50 million in ECF funding requests during the initial window. In a very short period of time, we have developed the subject matter expertise necessary to successfully marshal our clients through this new regulatory scheme.

Eligible Equipment: Wi-Fi hotspots, modems, routers, devices that combine a modem and router, and other connected devices. These eligible connected devices include chromebooks, laptop computers, tablet computers, and similar end-user devices. 

Licenses, software, content filtering and security services included in the price of the connected devices are also eligible for ECF support. However, separately priced licenses are ineligible.  Note also that manufacturers’ warranties of up to 3 years are eligible for ECF support.  

Installation and configuration services in relation to eligible equipment are also eligible but asset tagging and inventory management services are not.

Eligible Services: Commercially-available broadband internet service that provides a fixed or mobile broadband connection for off-campus use. Hotspots and mobile broadband plans for individual users and school buses are the most common services; however, other services may be available under certain circumstances.

Limitations & Reimbursement

Limitations: One device/hotspot per student. One fixed connection per home with no minimum bandwidth standards. There will also be no break, fix or replacement allowance. Desktop computers and smartphones are NOT eligible for funding support.

Caps on Reimbursement: Reimbursement on connected devices is capped at $400 per device. Hotspots are capped at $250 per unit.  These caps are exclusive of applicable taxes, which are also eligible for ECF support.

There are no guidelines yet for the reasonable cost of commercially available internet service; USAC has discretion to determine whether the costs of a particular service is reasonable.

Invoicing Process

Invoicing: Applicants will be required to provide all purchase orders, invoices, and other related documents to USAC prior to receiving a funding commitment. Either the BEAR or SPI invoicing method can be used.

Those who have entered contractual arrangements to purchase eligible equipment and services may 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. 

SAM Registration: If not already registered, applicants will be required to register in the federal SAM System. Those 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. Applicants must also retain ECF-related documents for at least 10 years.

Certifications: As a part of the funding process, applicants will be required to make several certifications. For example, you must certify that the equipment and services that require funding will primarily be used for educational purposes by students and school staff. Both the applicant and service provider(s) must ensure they are not willfully or knowingly requesting reimbursement for equipment or services that are not being used.

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.

Please contact to discuss any questions you may have regarding the ECF or the information we have provided above.