Emergency Connectivity Fund (ECF) Overview and Eligibility

Emergency Connectivity Fund (ECF) Presented by: TN State E-rate Coordinator s Office

American Rescue Plan Act of 2021 Established ECF $7.171 Billion ECF was created to address the Homework Gap One-time program for now

Emergency Connectivity Fund (ECF) Purpose Purpose To provide broadband access and connected devices to students and school staff for remote learning away from a school campus Who s Eligible Who s Eligible Schools, libraries, and consortia that are eligible for the E-rate program - even if they don t currently participate in E-rate How Much? How Much? 100% reimbursement 100% reimbursement for most expenditures July 1, 2021 - June 30, 2022 first. No matching portion. No budgets.

Emergency Connectivity Fund (ECF) Limited to Serving Unmet Needs Limited to Serving Unmet Needs Funding is limited to the purchase of eligible equipment and services for students and school staff who would otherwise lack access to Internet connectivity and devices sufficient to engage in remote learning sufficient to engage in remote learning Schools will need to report how they determined unmet needs on application

ECF Remote Learning What if our schools reopen 100% in What if our schools reopen 100% in- -person instruction next school year? Can we still person instruction next school year? Can we still apply for funding under ECF? apply for funding under ECF? The FCC does not predicate funding on whether schools are reopened for in-person instruction. The underlying principle is resolving unmet needs in order to enable students and school staff to participate in remote learning, whenever and wherever it occurs. The FCC refers to this program as closing the Homework Gap which indicates that ECF can be used to connect unserved students and staff for the purpose of after school-hours learning activities away from school.

ECF Unmet Need Can we assume that any students meeting low Can we assume that any students meeting low- -income eligibility requirements for Free/Reduced lunch or other assistance programs demonstrates that there is an Free/Reduced lunch or other assistance programs demonstrates that there is an unmet need? unmet need? No. The FCC does not agree that there should be a presumption of unmet need when a school pays for a device or broadband connection for a low-income student. How do we demonstrate unmet need? How do we demonstrate unmet need? The FCC leaves this up to the school. However, the method must be reasonable and supported by documentation. income eligibility requirements for

ECF Eligible Services Equipment necessary for a Equipment necessary for a broadband Internet service to broadband Internet service to operate: operate: WiFi Hotspots (capped at $250 per device) Modems, Routers Satellite dish or fixed wireless receiver Connected end Connected end- -user devices: Laptops & tablets (capped at $400 per device) Operating software & licenses included in cost of device Manufacturer s 3-year warranty included in cost of device user devices:

ECF Eligible Services Broadband Service Broadband Service Commercially available Commercially available wired and wireless broadband Internet services Fixed broadband service (cable, DSL, fiber, wireless) Mobile broadband service (cellular, wireless) Satellite broadband service Installation, taxes & surcharges Per Footnote 95 regarding term commercially available: We include commercial offerings available only to schools or libraries, or their students, school staff, and library patrons in this term. See FCC Tool: https://broadbandmap.fcc.gov/#/

ECF Eligible Services When Sufficient Commercially Available When Sufficient Commercially Available Broadband Internet Does Not Exist Broadband Internet Does Not Exist School/library must prove insufficiency of service! Construction of new networks or purchases of services that are not commercially available: Private LTE Dark fiber Extended WiFi Equipment* necessary to operate networks Datacasting customer premise equipment *Paragraph 39 limited exception for end-user equipment: To the extent schools expanded their networks or built new networks to serve their students over the last year equipment such as Wi-Fi hotspots, modems, routers may be eligible.

ECF Eligible Services Provide clear evidence of lack of commercially available service: Provide clear evidence of lack of commercially available service: Define geographic area Define group of students/school staff and corresponding off-campus locations/addresses lacking access Define bandwidth requirements sufficient for remote learning Document that services were sought from commercial providers and providers were unwilling or unable to provide service FCC Tool searchable by address: https://broadbandmap.fcc.gov/#/

ECF Ineligible Services Full 1:1 devices and Internet where no unmet need exists Private networks if commercially available Internet service exists Desktop computers, smartphones, peripherals and accessories beyond a power cord Cybersecurity and filtering Device and network monitoring and management Replacement of lost, stolen, or damaged devices Administrative costs Unbundled, separately priced: Unbundled, separately priced: Software & user licenses Firewall Warranties and maintenance

ECF Eligibility Restrictions Locations Locations Locations other than a school or library campus Homes School Buses Community centers, churches, or other locations where remote learning is occurring Limits Limits No Duplication No Duplication ECF may not be used if services/devices are purchased with other federal, state, or other specific earmarked funding for remote learning initiatives (e.g. ESSER, EBB, CTF, etc.) Single fixed broadband connection per address except for multi-tenant housing Single device and/or wireless connection per student or staff member Access must be restricted to students and school staff

ECF Eligibility FAQ Is the $250 per WiFi hotspot both subscription and equipment cost? Is the $250 per WiFi hotspot both subscription and equipment cost? The $250 is the cap per device (equipment). The separate monthly recurring Internet service cost is uncapped. Can we get reimbursed for the monthly costs after July 1 on hotspots previously Can we get reimbursed for the monthly costs after July 1 on hotspots previously purchased? purchased? Yes. The first application window is for anticipated eligible expenditures from July 1, 2021 through June 30, 2022.

ECF Eligibility FAQ Is replacement of previously Is replacement of previously- -purchased obsolete devices allowed? purchased obsolete devices allowed? This may be eligible if the single device per student or school staff member with an unmet need requirement is adhered to. Will this be restricted to students in eligible schools? Will this be restricted to students in eligible schools? ECF purchases are restricted to students, school staff, and library patrons of E-rate eligible schools, libraries, and consortia. If we purchase hotspots, is it only one per address? If we purchase hotspots, is it only one per address? No, the per address limitation is for fixed broadband Internet service. For mobile devices, the limitation is one per individual student/school staff member/library patron.

ECF Eligibility FAQ Will students only qualify if "at home" rather than being at a relative's home Will students only qualify if "at home" rather than being at a relative's home participating in remote learning? participating in remote learning? Eligible locations are any place off campus off campus where remote learning occurs. In this scenario, a mobile hotspot service would be a better option rather than a fixed broadband service which would be limited to one address/student. What credentials are necessary to make sure the device and/or internet are only being What credentials are necessary to make sure the device and/or internet are only being used by eligible students and/or school staff? used by eligible students and/or school staff? The FCC is silent on how a school or library applies credentials to students and school staff, leaving it up to the school to determine how to implement this restriction.

ECF Eligibility FAQ All of my teachers have desktop computers at school. Can I use ECF funds to buy All of my teachers have desktop computers at school. Can I use ECF funds to buy them all laptops to use at home if we go to remote learning? them all laptops to use at home if we go to remote learning? If the laptop device is necessary for the teacher to participate in remote learning and there is an demonstrated unmet need, then this would be eligible. Can I apply now for devices and Internet I MIGHT need next year? Meaning, we start Can I apply now for devices and Internet I MIGHT need next year? Meaning, we start off the year in person learning but we may go remote. Can I apply for the devices just off the year in person learning but we may go remote. Can I apply for the devices just in case? in case? You may apply for devices and services you anticipate needing based upon your needs assessment at the time of filing the application. However, it is important that actual reimbursements be based on tangible factors that demonstrate compliance with the rules of the program.

ECF Preparing to Apply First Application Window First Application Window Anticipated expenditures from July 1, 2021 through June 30, 2022. 45-day application window opening as early as June! If funds are not exhausted in first application window, a second window will open. Subsequent windows will be for retroactive reimbursement for purchases made at start of pandemic (March 2020 June 30, 2021).

ECF Competitive Bidding No FCC competitive bidding rules No FCC competitive bidding rules must certify to compliance with state and local rules May use new or existing contracts Review Board purchasing policies to determine if formal competitive bidding is required or if Board authorization is required for purchases using state master and piggyback contracts.

ECF Application No legally binding agreement No legally binding agreement requirement (unlike E requirement (unlike E- -rate) but will need to document expected purchases and to document expected purchases and payments: payments: Detailed Quote, Pricing Schedule, or Bill of Materials Contract Purchase Order Invoice Proof of Payment Funding request will look similar to E- rate FRNs Documents will be uploaded at the time the application is filed (unlike E- rate) as well as when reimbursements are claimed to speed approvals and disbursements. Expect quick reviews and short deadlines! Inform your accounts payable department to flag invoice and payment documentation at the time of payment. rate) but will need

ECF Needs Assessment Application will present a set of questions regarding the specific unmet needs specific unmet needs that existed at the start of the pandemic and how the ECF is being used to address remaining unmet needs. Questions TBD. Application will ask for a narrative of how the applicant obtained the data to answer these questions and the timing of the data collections or needs assessments. the

ECF Reimbursement Reimbursements may be submitted by: Reimbursements may be submitted by: School or library applicants via Form 472 (BEAR) OR OR Service providers via Form 474 (SPI) *but service providers are NOT required to invoice and may choose not to do so Service providers referenced on applications do not need a service provider identification number (SPIN) if the applicant will be filing for reimbursement. Applicants must gain written acknowledgement from service provider agreeing do SPI, otherwise it is assumed the applicant will file BEARs. Selection of invoicing method must be made at the time the application for funds is submitted.

ECF Reimbursement Services must be received July 1, 2021 Services must be received July 1, 2021 - - June 30, 2022 60-day deadline for submitting invoices: From receipt of service, or from date of funding commitment decision letter or revised funding commitment decision letter (whichever is later) Applicants may request reimbursement before making payment on invoices, but then must pay service provider within 30 days of receipt of reimbursement Any changes from services approved on application must be approved via the service substitution process before invoices will be approved. Service substitutions will be filed via a Form 500 in EPC June 30, 2022

ECF Reimbursement FAQ Is the 60 Is the 60- -day invoice deadline from the end of the funding year (June 30, 2022)? day invoice deadline from the end of the funding year (June 30, 2022)? No, the 60-day deadline is from the date the school or library applicant receives the equipment or service. If we ordered laptops prior to July 1 but have not received them yet, can we apply for If we ordered laptops prior to July 1 but have not received them yet, can we apply for ECF on them? ECF on them? If you do not receive or pay for the laptops until on or after July 1, 2021 then yes, you may apply for ECF for them in the first application window - for services to be received between July 1, 2021 through June 30, 2022.

ECF CIPA In its rules, the FCC clarified that compliance with CIPA is required for any school-owned computers if the school also receives ECF funding for broadband Internet service or the school receives funding for Internet access and/or internal connections in the traditional E-rate program. CIPA compliance is not required if the school receives ECF funding for laptops or tablets but it does not also receive ECF funding for broadband Internet service or funding for Internet access and/or internal connections in the traditional E-rate program. Finally, schools are not required to comply with CIPA on non- school-owned computers.

ECF Application in EPC E E- -rate Productivity Center (EPC) rate Productivity Center (EPC) USAC will administer the ECF program ECF will utilize modified E-rate Forms 471, 472 (BEAR), 474 (SPI), and 500

Register in SAM System Award Management (SAM) System Award Management (SAM) Applicants and service providers seeking reimbursements must be registered with SAM - https://sam.gov/content/home SAM registration is required in order to receive a program reimbursement: make sure bank account information is correct!

ECF Document Retention Document As You Go! Document As You Go! Competitive bidding process (where required) Vendor bids/quotes Contracts Purchase orders Invoices and proof of payment Documentation of unmet need CIPA compliance Asset and service plan inventories Usage reports 10 10- -year documentation retention year documentation retention Broadband service: (a) type of service; (b) upload/download speeds and monthly data cap; (c) person receiving service; and for fixed broadband service; (d) the service address, (e) date(s) service received. Equipment requirements: (a) device type; (b) make/model; (c) serial number; (d) person receiving device; and (e) the dates the device was loaned out and returned to the school or library.

ECF Resources FCC Order with Rules for Program: FCC Order with Rules for Program: https://www.fcc.gov/document/fcc-launch-717-billion- connectivity-fund-program-0 Universal Service Administrative Company (USAC): Universal Service Administrative Company (USAC): https://www.usac.org/ and e-mail sign-up https://survey.alchemer.com/s3/6296809/Emergency- Connectivity-Fund

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