On April 6, 2022, Funds For Learning conducted an Emergency Connectivity Fund (ECF) Webinar. Thank you to all who attended the April 6th ECF Webinar. The ECF Webinar recording and presentation slides are available here for download.
Our next webinar is scheduled for April 14th at 11am EST. Register here for the upcoming event.
Check out the list below of frequently asked questions we received in the concluded ECF Webinar, along with answers based on currently available information. All responses are subject to change as the FCC releases additional guidelines.
Unmet Needs
- Do you have any knowledge if schools can “update” their Unmet Needs forms? For example, during W1/W2 they used the same Unmet Needs form. Since those filings, more Chromebooks were found to no longer provide adequate remote learning – can they update that form to include these devices?
ANSWER: ECF applicants certainly can and should update both the documentation that they are maintaining to record their unmet needs information and the unmet needs section of the ECF Form 471. School and library applicants serve changing populations that will likely have different needs from one year to the next. Both increases or decreases are possible for the number of individuals who have an unmet need from one window to the next. - Can I find the Unmet Needs questionnaire somewhere to get a head start on the answers?
ANSWER: At this time, the FCC has not released a new Unmet Needs questionnaire for the third ECF filing window. - How do libraries document unmet need?
Answer: Libraries aren’t required to answer questions on the Form 471 application regarding unmet needs. However, libraries are required to certify on the Form 471 application that the services and/or devices requested will be used by patrons who lack sufficient access to engage in remote learning. To document this, ECF rules require libraries to provide patrons with an eligible use policy. This policy should explain that the equipment or service is intended for patrons who lack access to equipment or services sufficient to meet the patrons’ educational needs. Patrons must sign and return a statement saying they would otherwise lack such access.
Services
- We purchased hotspots and service for those hotspots in Round 2 with service ending 6/30/22. Can we apply for just service for those same devices for 12 more months in Round 3?
ANSWER: Yes, if those devices and service are still necessary to fulfill an unmet need, then you are free to request additional funding in the third ECF window for up to 12 months of service delivered between July 2022 and December 2023. - How will duplicate services be determined when it comes to mobile computing devices? For example, if a school district previously requested “X” laptops but their unmet need had changed and they now need additional “Y” laptops.
ANSWER: If an applicant can demonstrate that additional devices are necessary to meet the new or newly identified unmet needs, then the additional devices should be eligible for ECF funding. Applicants should always be prepared to show how unmet needs estimates were determined, and to demonstrate that they have only sought disbursement for actual unmet needs. - The Applicant was previously approved for a lease payment for eligible hardware in the first window. Would this be considered a recurring service that can be funded in the third window?
ANSWER: Yes, assuming that the leased devices are still being used to meet an otherwise unmet need, an applicant could request additional funding in the third ECF window for the cost of device leases, for up to 12 months of funding between July 2022 and December 2023. - When obtaining pricing from vendors/resellers, do they only cover the Chromebook device only? What about Google licensing, protective covers and/or white glove services?
ANSWER: Licenses, software, content filtering and security services included in the price of the connected devices are eligible for support and do not require cost allocation. However, separately priced licenses are ineligible for ECF funding. ECF support for connected devices is capped at $400 per device, even if the base price includes the cost of licenses, software, or content filtering and security services. - Can a School seek reimbursement for broadband connections that aren’t in use by students, but are still being paid for.
ANSWER: No, applicants should not seek reimbursement for services that are not in use. The service would only be eligible if meeting an unmet need for qualifying individuals. - If we applied for the previous ECF funding you mentioned we should note the previous 471 application number and end dates of service — Do I enter that in the FRN narrative field?
ANSWER: It would be a good idea to include the FRN; however, in the Public Notice DA 22-309, the FCC recommends that applicants should include the ECF Form 471 number(s) and service end date(s) for any services that continue between July 1, 2022 and December 31, 2022. - We provide all of our teachers Chromebooks (purchased by the district) to use at home and school. The majority of those Chromebooks are out of date and do not update. We strongly encouraged all of our teachers to use the Chromebooks at home for remote learning due to easier tech troubleshooting and a common device between teachers and students. Can I use ECF funds to replace all of those teacher Chromebooks?
ANSWER: If your school determines there are educators who have an unmet need because they do not have access to a device that will support remote learning education, then the devices for those educators should qualify for ECF funding (subject to the $400/device funding cap). Applicants may find previously useful devices which no longer meet the needs of their population and could determine that a new device is necessary. As with any means that you use to determine your unmet needs, be prepared to justify your assessment during the application review process.
Prioritization
- If more funding is requested than is available, will USAC utilize the funding distribution priority table based on rural/urban and %NSLP?
ANSWER: In the Public Notice DA 22-309, the FCC wrote that “in the event that demand exceeds available funding during the third ECF application filing window, we remind applicants that requests will be prioritized based on applicant’s E-rate Program discount rate for category one services, adjusted to provide a five percent increase for schools and libraries.” - If a school is funded at 75% (per the table from the FCC), does the school have to come up with the 25% difference OR can they simply reduce their unmet need to 75% of their total request?
ANSWER: The ECF fund will still reimburse 100% of the eligible costs related to a funding commitment. If the fund is not sufficient to cover the funding requests for the third filing window, the FCC has instructed USAC to begin funding approval for the applicants that qualify for the highest E-rate discount rate first (with a 5% bump on the E-rate discount rate for rural applicants). This will only be used to determine which applicants will be approved for funding but will not affect the 100% ECF discount rate. - Could you clarify how the E-rate program discount percentage % works for libraries?
ANSWER: Just like the E-rate program, the E-rate discount percentage used for prioritization of ECF funding for Library applicants will mirror the discount percentage of the school district in which the main library branch is geographically located
Recipients of service
- Our school district is the sponsoring district for a special education cooperative. That is, the Coop is housed in our district office but their employees go to other school districts in our coop and ours as well. Can I apply for ECF funding for the employees of our COOP?
ANSWER: If the special education cooperative meets the statutory definition of a school, then the cooperative should be able to seek ECF funding for educators with unmet needs for devices that support remote learning education. - Are we allowed to purchase laptops for staff or is this just for students?
ANSWER: Like the first and second ECF filing windows, students and staff are eligible for the third ECF filing window.
General
- I have a customer who was approved for ECF funding this year. They have two accounts with us, but it looks like they only filed for one of the account numbers. How can he get the funding approved for the account he missed.
ANSWER: USAC will not increase a funding request after it has been funded. That means the customer will need to file another ECF application for the account number that they didn’t file for previously. - Does this mean we cannot ask for more Chromebook if we didn’t request enough previously?
Answer: Your entity could request additional Chromebooks if you determined that there was still an unmet need for them after filing in previous windows. - Is satellite Internet service eligible?
ANSWER: Yes, ECF funding is available for Internet service provided by satellite, however funding approval may still be subject to a review confirming the cost-effectiveness of the service, so be prepared to justify why you have elected to use any certain type of service for specific users. - What is the difference between contracted vs non-contracted vs tariff ECF requests?
ANSWER: The FCC wants to know if an applicant is going to purchase the equipment and/or service with a contract, or if it is non-contracted or if it is done with a tariff. While ECF does not require a Form 470, a 28-day waiting period for procurement, applicants must indicate how if they are purchasing the equipment/service via a contract, non-contracted or tariffed. - My library didn’t participate in the first two rounds. Where do I find a “manual” on eligibility and includes the steps to apply.
ANSWER: Funds For Learning has a website that summarizes the ECF regulations. The website can be found here: https://www.fundsforlearning.com/ecf/#what-is-ecf. The FCC has also compiled a FAQ site which can be found here: https://www.fcc.gov/emergency-connectivity-fund-faqs - Will this funding request cycle cover 2022-23 school year?
ANSWER: The funding period is July 1, 2022 to December 31, 2023 (up to 12 months of monthly recurring services). - What would happen to the equipment received from ECF if an entity closes?
ANSWER: The FCC clarified that “Schools and libraries, as the applicants, will own the equipment purchased with ECF support”. - Is there dollar limit to router and modem for wireless broadband connection?
ANSWER: The cost cap for eligible equipment, such as routers and modems, are $400.00 per device. Wi-Fi Hotspots are capped at $250.00 per device.
