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E-rate Funding for Libraries: Emergency Connectivity Fund Updates

Federal funding for internet access

Updates regarding filing

October 20, 2021

Most CT libraries have NOT received a funding commitment from the Emergency Connectivity Fund.  Commitment letters are being released in waves.  If you were denied funding or are having problems answering the questions of reviewers, the E-Rate coordinator can get involved and try to help solve the problem by reaching out to ECF supervisors.  Email christine.gauvreau@ct.gov.

Also, please note that the E-Rate Task Force of the American Library Association is preparing an evaluation of the ECF experience for libraries and will be using this report to highlight the good done with these funds, as well as the obstacles for libraries born of specific FCC rules around needs documentation, the extreme length of the review process, and other elements of the ECF approach to pandemic connectivity relief. 

 

 

September 15, 2021---

Next Window for Filing Opens September 28 and Closes October 13

Portal for filing and Instructions: emergencyconnectivityfund.org

If you would like to see for which devices and services other CT libraries applied, you can now look it up in the Emergency Connectivity Fund (ECF) Open Data Tool.

Recently answered questions: 

  1. I have not received a Funding Commitment Letter for the application I filed during the first window.

The Funding Commitment Letters are going to come out in rounds. The first batch should have come out this week. You will be able to see the status of your application in your ECF USAC account.

  • Pending” means you did not complete your application by clicking on certification. If you have this status, contact customer support, and ask if you can still be considered for funds or if you should reapply during the September-October window.
  • Certified” means you successfully completed your application and are awaiting a funding commitment letter.
  • When your application has been approved by ECF, your Form 471 status will show as “committed.”

  1. Will ECF cover “Cells on Wheels,” or COWs, also known as Mobile Cellular Sites, and are there any issues to be aware of?

The FCC would want detailed information about how the library is limiting the service to eligible users. We do not have good examples yet of an official FCC response to this kind of request. This remains a big of a gray area.

  1. Can libraries request hotspot service for a bookmobile even though this is E-Rate eligible?

Since the bookmobile is considered library property for E-Rate, it appears that bookmobiles may not be eligible for any ECF support, despite being explicitly named in the ECF order. Laptops for use by eligible users off-site from the bookmobile would be eligible.

  1. Does a library need to be CIPA-compliant if they only are asking for funds for monthly cellular data plans to be used by patrons outside of the library? 

According to FCC ECF FAQ 10.3, the library would have to make all library-owned computers CIPA-compliant to get funded for mobile broadband to be used off-site.

  1. For libraries that request ECF support for a community Wi-Fi set-up (example: internet for local housing authority buildings), what steps must be taken to ensure that service is provided only to eligible patrons? 

The FCC is not proscribing how libraries obtain this information and save it. Some libraries are proposing a Wi-Fi splash page, with a click-through acknowledgment. Some are requiring a credential such as a patron barcode number. See FCC ECF FAQ 8.1 and 8.2 for more specific language. 

  1. If I am filing for an ECF reimbursement, do I use the library’s DUN’s number and SAM.gov registration or the town’s?

In order to receive reimbursement from ECF, the DUN and the EIN must match the information in the FCC registration number attached to your ECF/E-Rate profile. 

If you are having trouble with ECF customer support and need the E-Rate coordinator to intervene, contact Chris Gauvreau at christine.gauvreau@ct.gov or (860) 704-2224. 

 

 

 

August 20, 2021---

As of the end of the first week after the close of the ECF filing window, 17 CT public libraries have applied for more than $266,000 for laptops, tablets, modems, routers, hotspots, or internet services for patrons who need help to become fully included in the digital world.  Good work!

August 10, 2021--

The Emergency Connectivity Fund Program application filing window will be open for 4 more days!  Eligible schools and libraries must apply by this Friday, August 13, 2021 at 11:59:59 p.m. ETDo not wait until the last day to submit your application. During the current application filing window, eligible schools and libraries, in addition to consortia of schools and libraries, can submit requests for funding to purchase eligible equipment and services between July 1, 2021, and June 30, 2022 to meet the remote learning needs of students, school staff, and library patrons who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning.

Interested schools and libraries can find more information and apply for support at emergencyconnectivityfund.org

Today’s Focus: Application Process

Question of the Day
How do I edit an incomplete application?
Under the “My Pending Tasks” tab of your dashboard, there will be a task to edit or resume the creation of your incomplete ECF FCC Form 471 application. Please note that if you select the application in "My Applications," you can view what you have done, but you cannot edit or continue your application.

Frequently Asked Questions
Do applicants need to have contracts in advance of submitting an application for ECF support?
No, contracts are not required under the ECF Program rules, but applicants are required to comply with state, local, or Tribal procurement laws or regulations. Applicants also do not need to have already placed an order for eligible equipment or services prior to filing an application.

Please see DA 21-881 for more information about the application certification language in 47 C.F.R. § 54.1710(a)(1)(x).

Can applicants change their service providers after they file their applications?
Yes, applicants may change service providers.

Can applicants change the make or model of their equipment after they file their applications?
Yes, applicants may make service and equipment substitutions after getting a funding commitment.

Will applicants be required to upload proof of ordering or a vendor quote with the Form 471 application?
No, documentation is not required for the application. However, if the applicant would like to upload a contract or proof of order for their funding request, they will still be able to do so on their FCC Form 471.

Will USAC wait to approve applications until the application filing window closes?
Yes. In order to assess the demand for funds, USAC will wait until the application filing window is closed before issuing funding commitment decision notifications.

Will application and pricing information be made available through Open Data?
Yes. The Order states that Emergency Connectivity Fund Program application and pricing data will be made available through Open Data within 160 days after the initial application filing window closes and we are making every effort to make this data available earlier, if possible.

Are applicants required to conduct competitive bidding, like they do for the E-Rate program?
No. There are no Commission-mandated competitive bidding requirements for the Emergency Connectivity Fund, but schools and libraries are required to certify that they have complied with state, local and Tribal procurement requirements.

When I request funding for equipment, what do I use as the service end date in the application?
For equipment or other non-recurring services that have not been received when the applicant submits the application, applicants may use June 30, 2022 as the service end date.

Please see DA 21-881 for more information about the deadline for invoicing for these non-recurring purchases.

Does a service provider need a Service Provider Identification Number (SPIN) for ECF?
No.  Service providers do not need to have a SPIN unless they are invoicing on behalf of the applicants.

The FCC continues to update its FAQs as new questions come in. Additional FAQs are available at: www.fcc.gov/emergency-connectivity-fund-faqs .

Extended CSC Hours
Applicants and service providers can contact the Emergency Connectivity Fund Customer Support Center (CSC) with questions at (800) 234-9781 Monday – Friday from 8 a.m. to 8 p.m. ET. Extended hours will be available during the following days this week:

  • Wednesday, August 11, 2021: 8 a.m. to 10 p.m. ET
  • Thursday, August 12, 2021: 8 a.m. to 10 p.m. ET
  • Friday, August 13, 2021: 8 a.m. to 11:59:59 p.m. ET (Last day of the application filing window)

Need Help?
USAC will continue to host weekly office hours where applicants and service providers can ask questions and get information about the Emergency Connectivity Fund Program application process. Register for this week’s office hours sessions and office hours session for tribal applicants being held this Wednesday, August 11, 2021.

  • Wednesday, August 11 @ 3 p.m. ET: Emergency Connectivity Fund Overview Office Hours – Register
  • Wednesday, August 11 @ 4 p.m. ET: Emergency Connectivity Fund Overview Office Hours for Tribal Applicants - Register

 

 

July 1, 2021--

There is a great deal that is still unknown about the process by which a library will apply for Emergency Connectivity Funds for connected devices, hotspots, modems, routers, and hotspots for educational use off-site.   But more has come to light.

  1. The window for applying opens on June 29, 2021 and runs for 45 days. Basic preliminary information is available in USAC live sessions and module training. 
  2. Libraries will access the ECF portal from the USAC.org homepage.  When you sign-in, there will be a dropdown menu and you will choose to go to the ECF rather than E-Rate section. Once in, you will a special Form 471 for the costs for the eligible devices and services.
  3. If your library already regularly files for E-Rate for fiber maintenance or internet service, a special ECF account will automatically be set up for you by the E-Rate folks. You will get an email notification when it is accessible.  
  4.  If you have never filed for E-Rate, you will get set up for an ECF account by calling the customer support number 800-234-9781.  When you call this number, you should already have your FCC registration number in hand.  You should have applied for your SAM.gov registration but you do not have to have received final notification confirming your registration. You may file your Form 471 while waiting for your SAM registration confirmation.  No funds will be committed to your library while it is pending.
  5. To get notices about clarifications as the process unfolds: Sign up on this webpage to get announcements about these sessions.  In addition, there will be weekly ECF customer support office hours beginning June 30.  You will be able to send questions and ask that they be addressed in an upcoming open session.  If you have very specific questions regarding your own account, you should be addressing these to the ECF customer support at 800-234-9781.
  6. There is no cap on the total amount of money a library can request for eligible services.  There are only the caps on what will be awarded for laptops (up to $400) and for hotspots (up to $250, not including service contracts).  And there are limits on the number of internet connections per location. You may be asked to justify the number of devices for which you request payment with user statistics.  There will be rules about collecting statements from patron users and keeping inventories of the devices.
  7. Eligible devices and services can be found in Appendix B of this FCC Order.
  8. A library will be able to approach receiving funds in several ways.  If your vendor has a SPIN number in the E-Rate system, you will be able choose to have the vendor invoiced for the devices or service.  If your vendor does not have a SPIN number in the system, after your funds are committed, you will follow procedures for what is called BEAR invoicing.  You can request that the payment come directly to your library, but you must show documentation showing that the vendor was paid within thirty days of your filing.  You can also simply submit for reimbursement using BEAR invoicing.
  9. Need advice about CIPA requirements?  See ALA guidance below. 
  10. The ECF program requires that you collect (1) statements from patrons who are loaned devices and hotspots, and (2) that all records be retained for 10 years.  The ALA, in the wake of a failure to get this policy changed to conform to library privacy systems,  has written a letter to the FCC, asking that the implementation of this requirement be delayed so that libraries can come up with acceptable systems for dealing with this. See this letter below

 

Feel free to call CSL E-Rate Consultant Chris Gauvreau at 860-704-2226 or email christine.gauvreau@ct.gov.

American Library Association Interpretations of ECF Order

More on Records Retention and Patron Privacy

The FCC updated its Frequently Asked Questions Page on the issue of Record Retention and Privacy:

 

*8.1 Q:  Do I need to modify my library inventory system to track all of the required recordkeeping data in a single report?

A:  No.  While a library is responsible for retaining all of the information required by the Commission's rules, it does not need to be managed or maintained in a particular format.  Libraries can determine how they format, extract and save the required data.  For example, if a library separately tracks its inventory, circulation history and patron data, and collectively all required information is retained for the requisite period of time, no modifications to the library's recordkeeping system would be needed.    In requiring libraries to collect and document this information, we commit to ensuring that if the Commission or USAC staff need to access this information (e.g., for audit purposes), they will request and safeguard the information in accordance with the applicable privacy laws and guidance, including using de-identified and anonymized information whenever possible.

Discoveries about the filing system!

  • To reopen a Form 471 in progress, you must use the link under the My Pending Tasks tab.
  • To review a Form 471 in progress (without the ability to edit or updates), click on the application number that comes up in the My Application tab.
  •   A public data tool will become available later in the summer
  • Waiver requests for devices for people with disabilities must be filed with the FCC
  •    Service providers don't have access to the ECF portal at this time (and maybe won't at all?)
  •  State coordinators will be copied on PIA notices
  • The ECF portal can't generate a draft PDF copy of the 471, but users in the system should be able to access the in-process application if they have the appropriate permission level.  State coordinators can see details of your  in-process Forms 471 under the 'My Applications' tab, including the funding requests and line items.
  •   Users can contact the reviewer about revising a 471 in review. 

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