E-Rate and Online Learning Challenges

Deborah Sovereign, CPA, CEMP, Owner of Kellogg & Sovereign Consulting

LATE BREAKING NEWS – The Oklahoma Corporation Commission on Thursday, September 17, 2020 extended support for emergency bandwidth upgrades due to COVID-19 to June 30, 2021.

LATE BREAKING NEWS – The FCC issued an Order on Wednesday, September 16, 2020 to allow schools to file an additional E-Rate Form 471 during a second filing window for FY2020. The second filing window is designed to ease the remote learning burden on school networks.

Period of support: July 1, 2020 to June 30, 2021

Application window closes October 16, 2020

Eligible Services: On campus category one Internet access and/or data transmission services needed as a result of the COVID-19 pandemic

No competitive bidding required IF the applicant:

Filed a Form 470 previously for the services

Filed a Form 471 for FY2020 and has received funding or funding is pending associated with the Form 470 that was previously filed

Is requesting bandwidth upgrade through the existing service provider or a new one

Note: Funding is limited to the price per megabit in the original contract. (May use other per unit terms such as same cost per 1 Gbps)

See: https://www.fcc.gov/document/fcc-opens-second-e-rate-application-window-funding-year-2020-0

Contact Deborah Sovereign, Kellogg & Sovereign Consulting, 580-559-8302 for further details.

E-Rate FY2021-22 Category Two (“C2”) budgets will reset at $167 per student for a five-year period beginning July 1, 2021. The budget cap is calculated district-wide so you can allocate the funding among school sites as you see fit. The minimum budget has increased to $25,000.

For those of you who are working with the challenges of supporting online learning, you may need to upgrade your bandwidth immediately and plan for upgrading your firewall this spring. Firewalls fall under E-Rate C2 funding and can be purchased as early as April 1, 2021 for E-Rate FY2021-22.

Existing Contract Allows Upgrades – Yes:

If your existing contract is multi-year and allows for upgrades, you can upgrade bandwidth with your existing provider, request support for the incremental cost from OUSF through December 31, 2020, and then file E-Rate support on the higher bandwidth beginning July 1, 2021.

Existing Contract Allows Upgrades – No:

Contact service providers to find out your upgrade options. You can make temporary arrangements to upgrade immediately. Competitively bid as soon as possible following E-Rate and OUSF guidelines for the increased bandwidth, and then file for E-Rate support on the new services for FY2021-22.

For E-Rate FY2020-21, file a service substitution for the upgraded service. In general, there is no support for the incremental cost from E-Rate until July 1, 2021. *

If the upgrade is in response to COVID-19, incremental costs may be eligible for support from OUSF through December 31, 2020. **

Keep in mind that there is no E-Rate support for the incremental cost until July 1, 2021.*

Both E-Rate and OUSF will support bandwidth levels recommended by SETDA.

• WAN bandwidth recommendation is 10 Gbps per 1000 users.

Internet Bandwidth

• Small District - 4.3 Mbps / Student

• Medium District - 3 Mbps / Student

• Large District - 2 Mbps / Student

* Several organizations have petitioned the FCC to request a waiver of the E-Rate competitive bidding rules to allow schools and libraries to upgrade during the COVID pandemic. However, as of this writing, the FCC has not yet approved any waivers. You can voice your support by submitting comments to the FCC here: https://www.kelloggllc. com/docs/fcc/fcc_ecfs_howto.pdf

** The Oklahoma Corporation Commission may provide support for bandwidth increases in response to COVID-19 through December 31, 2020. Upgrades are reviewed for reasonableness and evidence supporting the need for additional bandwidth. Find more information at: http://www. occeweb.com/PU/OUSF/OUSF.htm