E-Rate December 2024 Updates
Good morning E-Rate Community,
I apologize up front for the lengthy list of items in this update, but this is proving to be a very busy E-Rate filing season, with lots of information to share! So, here we go:
Supreme Court Takes USF Constitutionality Case – You may have heard that the 5th U.S. Circuit Court of Appeals found that the Universal Service Fund (USF) was unconstitutional. In earlier decisions, both the 6th and 11th Circuit Courts found the opposite – that the USF was constitutional. Both the Justice Department as well as the petitioners petitioned the U.S. Supreme Court to hear the case, and the high court agreed to hear the case. The briefs are due by mid-January, with oral arguments expected to take place in late March. We expect a decision in June 2025. In the meantime, E-Rate and the other three USF programs are operating and will continue “business as usual.” Please continue with your FY 2025 application process, just as you have in previous years, and I’ll keep you posted as the case proceeds.
Update Enrollment/NSLP Data in EPC Now – The period before the Form 471 window opens when schools and libraries make sure their EPC profiles are up to date is called the Admin Window. The Admin Window deadline for FY 2025 has not been announced, but it is expected to be around January 10. Applicants are required to update their enrollment and NSLP (or CEP%) each year. If you are participating in CEP, I’ve uploaded a new CEP-only copy of the MR-81 with the most recent information, located at https://www.ohio-k12.help/e-rate-support/resource-library/. It includes schools with CEP base years 2021- 2024. If your school does not participate in CEP, it’s recommended that you use the October counts reported by your cafeteria. That should match what will be listed in the traditional MR-81, typically released early/mid-February. If you use something different, document how the counts were determined.
Begin Your FY 2025 Bidding If You Haven’t Started – If you have a contract that needs to be rebid or seek Category 2 funding for FY 2025, be prepared to file a Form 470. How do you know if you have to bid? Here’s a reminder: 1) If a service is covered on a Month-to-Month basis (meaning no contract exists – these are mostly cable modem-type services) AND your services do not qualify for the CABIO bidding exemption; 2) At the beginning of any new contract. Note: If you posted a Form 470 in a previous year and then signed a multi-year contract that expires on or after June 30, 2026, you are not required to file a Form 470 for FY 2025. 3) If you’re upgrading service and the upgrades and associated prices are not included in the original contract.
Extending an Existing Contract for FY 2025 – If your original contract includes (finite, not open-ended) voluntary extensions and you wish to exercise one of those extensions for FY 2025, be certain to notify the vendor in writing of that decision before the Form 471 is filed. USAC will ask for a copy of that written notification during PIA review, so be sure to retain evidence of that notification.
Spam/Robo Bids – We have all experienced receiving spam or “robo” bids when filing the Form 470. We have raised our concerns about these bids with USAC on multiple occasions, and they have provided the following guidance/requirements and advice for language to include with your Form 470 or RFP: “All bids received should be retained during the competitive bidding process. Disqualification factors can be applied to bids received that do not meet minimum bid requirements, do not include site- or project-specific details, and/or are not responsive to the applicant’s requests. Applicants may include language in their FCC Form 470 narrative or request for proposal (RFP), such as, “SPAM and/or robotic responses will not be considered valid bid responses and will be disqualified from consideration.” By doing this, applicants can disqualify bids based on this factor. The decision to disqualify any non-responsive bids should also be memorialized and retained to demonstrate compliance with the E-Rate competitive bidding rules.”
FY 2025 Form 471 Window Dates—The Form 471 window filing dates have not yet been announced. We expect to have the dates before the holiday break, and they will be very similar to previous years, which is that the window will open mid-January and close mid-late March. The Form 470 deadline will determine the Form 470 deadline. I will provide Form 471 webinars in late January/early February, and conduct both Category 1 and Category 2 sessions. So, watch for the training dates.
Do You Have Category 2 Funding Remaining? Don’t forget that FY 2025 is the 5th and final year of the current 5-year Category 2 budget cycle! To view your remaining C2 budget for FY 2025, use USAC’s C2 Budget Data Tool at https://opendata.usac.org/E-rate/E-Rate-C2-Budget-Tool-FY2021-/8z69-hkn7. Use the filter on the right side of the page to select your BEN. Unused C2 budgets will not roll over into FY 2026, but a new C2 budget cycle will begin on 7/1/2026.
FY 2024 Form 486s – The Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later. If you file your Form 486 after the original deadline, you must also file an appeal with USAC to request that the Service Start Date be adjusted to 7/1/2024 so you don’t lose any E-rate funding. If you requested Internal Connections, a one-time purchase, and the purchase/installation is completed after 7/1/2024, be sure to update the date when filing the Form 486.
Off-Campus Wi-Fi Hotspot Eligibility and Calculator – Although there is some uncertainty about how the incoming administration will regard off-campus hotspots, schools, and libraries that need this service should proceed with their plans but consider signing contracts that are contingent on receiving an E-Rate funding commitment. USAC has created a helpful hotspot budget calculation tool to help schools and libraries determine the maximum amount of funding they may request each funding year at: https://opendata.usac.org/stories/s/d5st-k49w. Also, USAC has extensive resources related to this new initiative at: https://www.usac.org/e-rate/applicant-process/before-you-begin/off-premises-wi-fi-hotspots-summary-overview/.
EPC Log-in Errors and How to Resolve – In the last few months, many have reported they are continuing to receive the following error message when logging into EPC after they go through multi-factor authentication: “AuthSDKError: Unable to parse a token from the URL”. To overcome this error, try the following: 1) Clear your cache and allow third-party cookies. 2) Press and hold the ‘CTRL’ key on your keyboard. While holding the ‘CTRL’ key, press the ‘F5’ key once to perform a hard refresh. 3) After receiving the error, enter this URL, which often takes you directly into EPC without requiring a new authentication: https://portal.usac.org.
Cybersecurity Pilot Program (CPP)—If you applied for the pilot, we are still waiting for the FCC to announce the selected participants. At this point, they’ve not given any indication as to when that will happen. If you are selected, you will need to file a Form 470 to request quotes, but there will be a CPP-specific Form 470, not the one we use for E-Rate purposes. This version of the form will have its own filing window and will not be tied to the deadline for the E-Rate Form 470.
If you have any questions, please don’t hesitate to contact me at lorrie.germann@education.ohio.gov.
I wish you all a very happy holiday season!
Lorrie
Lorrie Germann
State E-Rate Coordinator
On behalf of the Ohio Department of Education
lorrie.germann@education.ohio.gov
www.ohio-k12.help/erate
Office: 740-223-2420
Cell: 740-253-1153