Starting Services
Pilot funds will be available as soon as a Pilot participant receives a Funding Commitment Decision Letter (FCDL) from USAC, after they have successfully completed the Pilot FCC Form 471 and submitted Part 2 of the Pilot FCC Form 484 application. Please note that unlike the E-Rate program, the Pilot does not utilize specific funding years, so participants need not wait until a specific date (e.g., July 1, 2025) to purchase cybersecurity equipment and services, provided they have otherwise completed the necessary requirements. Pilot participants and service providers will be able to request reimbursement after the receipt or delivery of eligible cybersecurity services and/or equipment through the Pilot Program.
For purposes of invoicing and calculating the invoice filing deadline, and because the Pilot Program makes funding available to participants for three years from the date of the first FCDL for each FRN, the earliest date to start services for the Pilot Program is March 18, 2025, i.e., the first day of the Pilot FCC Form 471 application filing window. The last date to receive service (which may be different than the contracted service end date) is three years from the date of the first FCDL for each funding request number (FRN). See 47 CFR §§ 54.2001(c) (specifying the duration of Pilot Program funding period) and 54.2008(d) (noting the invoice filing deadline).
For month-to-month services, Pilot participants should use their actual service delivery start and end dates on the Pilot FCC Form 471. For contracted services, Pilot participants should use their contract start and end dates for the requested services on the form.
Thus, for example, if a participant enters into a contract with a service provider for services to be provided from April 1, 2025 to March 31, 2028, the service start date would be April 1, 2025 and the service end date would be March 31, 2028. The participant would specify these dates on the Pilot FCC Form 471 as the contracted service start and end dates. If the first FCDL for this FRN is issued on October 6, 2025, the service end date remains March 31, 2028, but the “last date to receive service” for purposes of calculating the invoice filing deadline would be October 6, 2028, and the invoice filing deadline for this FRN would be January 4, 2029.
If, on the other hand, the service start date for this FRN was November 7, 2025, (i.e., after October 6, 2025, the date the first FCDL is issued for the FRN), the “last date to receive service” for purposes of calculating the invoice filing deadline would be November 7, 2028, and the invoice filing deadline would be February 5, 2029.