FAQs

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Calculating Discount Rates

District-wide Discount: Schools

Q3: What if some or all of the schools in my district participate in CEP? Does that change the way that I calculate my school district discount?
A3:

For each of the schools that are participating in the NSLP’s Community Eligibility Provision (CEP), multiply the total number of students in the school by the percentage of directly certified students, and then multiply the results by the CEP national multiplier (currently 1.6) to convert the percentage into the number of students eligible for the NSLP. The resulting number cannot exceed 100 percent of the students at that school. Remember to indicate which schools are participating in CEP in the “Discount Calculation” section of your FCC Form 471 application so that the online system can do the calculations for you.

Eligible Services

Voice Services

Library

Library Basics

Q2: How do I demonstrate that my Tribal library is eligible to participate in the E-Rate program?
A2:

You can demonstrate your eligibility by providing documentation from an authorizing Tribal government entity (for example, through a Tribal Resolution), as well as documentation that shows that the Tribal library has the three basic characteristics of a library, including regular hours, staff, and materials available to library users. The characteristics of the Tribal library may also be attested to with a signed letter from a state library administrative agency.

Discount Rates

Q10: What documentation do I need to retain regarding my participation in the E-Rate program?
A10:

All E-Rate program participants – applicants, service providers and consortia – are required to maintain documentation that demonstrates compliance with the statutory or regulatory requirements for all E-Rate program purchases of service and equipment for a period of 10 years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request. Examples of such documentation include competitive bidding materials, program forms, contracts, and asset and inventory records of equipment purchased as components of supported Category Two services.

The FCC first established document retention requirements for school and library applicants and service providers in the Fifth Report and Order (FCC 04-190) and provided an illustrative list of examples of the types of documents that should be retained. As provided in the order, you should retain discount eligibility calculation documentation such as supporting worksheets or reports used to populate the C2 budget and discount calculation information:

  • Library square footage documentation/maps,
  • Copies of any policies and procedures related to the discount
  • Calculation process or methodology (i.e., National School Lunch Program (NSLP), surveys, Provision 1, 2, or 3, etc.)

  • Libraries (including Tribal libraries) – Documentation of your square footage for the Funding Year

You may visit the Document Retention page on the E-Rate site for more information and the E-Rate Program List of Documents to Retain for Audits and to Show Compliance with Program Rules.

Children’s Internet Protection Act (CIPA)

Q24: What is required under CIPA?
A24:

Applicants must comply with CIPA to be eligible for funding for Category One internet access and all Category Two equipment or services.  CIPA does not apply if the applicant only receives “telecommunication services.”

The requirements under CIPA include the following: 1) Internet Safety Policy, 2) Technology Protection Measure, and 3) Public Notice and Hearing or Meeting. The details of the policy and these measures are determined at the local level by your community and not by the E-Rate program.  You may find more details on these CIPA requirements by viewing Starting Services of the E-Rate Applicant Process.

Costs associated with technology to implement these protection measures are not eligible for reimbursement through the E-Rate program.

Q25: How long do E-Rate program participants have to implement the requirements under CIPA?
A25:

Applicants do not have to be compliant with CIPA in their first E-Rate funding year as long as they are taking steps towards meeting the requirements.

Applicants are required to be compliant in their second year and going forward.

Q23: What is CIPA?
A23:

The Children’s Internet Protection Act (CIPA) was enacted by Congress in 2000 to address concerns about minor’s access to obscene or harmful content over the Internet. CIPA imposes certain requirements on schools or libraries that receive discounts for Internet access, Internet services, or internal connections through the E-Rate program.

Calculating Discount Rates

District-wide Discount: Schools

Q10: How has the FCC Form 471 “Discount Calculation” section been changed to accommodate the new district-level calculations?
A10:

The “Discount Calculation” section has been revised to accommodate the changes in the rules. School district applicants must now enter all schools in their district (regardless of how many of those schools are receiving service on that application). The online system will automatically look up the urban/rural status for each entity and then calculate the district’s overall urban/rural status.

For any schools participating in CEP, the application will also automatically calculate the number of students considered eligible for the NSLP based on the school’s percentage of direct certification students. For Category Two applications, the school must also provide the number of students that attend on a full time and part time basis, so that the school’s Category Two budget can be calculated.

Finally, the system will total the number of full time students and the number of students eligible for the NSLP, and, using the district’s urban/rural status, display the school district’s discount rate.

District-wide Discounts: Consortia

Q21: How does the district-wide rule affect consortia applications?
A21:

Consortia applications requesting service for all members continue to calculate the simple average of the members’ discounts to calculate the overall consortium discount. However, those members’ discounts will now be each member’s district-wide or system-wide discount, regardless of which schools or libraries in the district or system are receiving service from that consortium. For example, if a consortium provides service only to high schools, the consortium discount is still based on the district-wide discount for the participating school districts, even though the service does not go to the entire school district.

A consortium uses the Category Two discount rate for each member entity (maximum of 85 percent) to calculate the overall consortium discount for Category Two requests.

Eligible Fiber Services

Selecting the Most Cost-Effective Service Offering

Q30: How do I determine the elements for a cost comparison between leased dark fiber vs. leased lit fiber; leased dark fiber vs. self-provisioned networks; and self-provisioned networks vs. services provided over third party networks?
A30:

When comparing the cost effectiveness of the three fiber service offerings – leased lit fiber, leased dark fiber, and self-provisioned networks – the expected useful life of the asset is a key consideration when comparing the combined upfront and recurring costs. To do this, applicants should determine a defensible period of time for the comparison, based on their anticipated use of the assets. Depending on a variety of factors, an applicant may expect to recover their costs for a self-provisioned network or leasing and lighting dark fiber in five, seven, ten, or, in some circumstances, 20 years.

Applicants should then identify a specific and comprehensive total cost for each of the responsive proposals received:

  • Self-Provisioned Networks: Consider all costs of owning, operating, and maintaining a network (e.g., recurring fees for maintenance and operations, Network Equipment).
  • Leased Dark Fiber: Consider all of the costs of leasing, lighting, maintaining, and/or operating the dark fiber.
  • Leased Lit Fiber: Comparison should project demand for bandwidth over the comparison period and how costs of bandwidth will vary over time.

Once that is done, applicants should divide the total cost for each option by the number of years in their comparison period to determine annual cost. Compare that annual cost against the annual cost of other responsive proposals received over the duration of the defensible time period. From this comparison, applicants should provide documentation of their findings to their reviewer via EPC with a narrative that summarizes the logic of the comparison. Presenting comprehensive comparison data is an important piece of the cost-effectiveness review process. By providing detailed information it helps the reviewers assess the validity of the cost-effectiveness of a solution more efficiently.

Applicants should be prepared to explain any assumptions made, such as how they set their comparison period, and cost for Network Equipment for leased dark fiber or self-provisioned fiber and any equipment refresh needs.

Program Integrity Assurance (PIA) Review

Q42: I understand the questions, but I do not have all of the information that PIA reviewer has requested. Do I still have to respond to the questions? If so, what do I do?
A42:

Applicants are required to respond to all PIA review questions, even if they are requesting information that is not currently in the applicant’s possession. The failure to respond to the PIA review questions may result in the denial of an applicant’s funding request.

If a question asks for information or documentation about a fiber service or project that is not currently in an applicant’s possession, they should request the information or documentation from their service provider. If the service provider does not understand the information request, applicants should ask their service provider to call the PIA reviewer to discuss the questions directly. Applicants do not have to be on the line when this call occurs, but participating in the call may help them better understand why the information is being requested, and prepare applicants for future PIA reviews.

If the service provider does not provide the required information in response to an applicant’s request, applicants should let their PIA reviewer know right away that they have requested the information and are having difficulty obtaining it. The PIA reviewer may reach out to the service provider directly to seek the requested information.

General Tips

Q44: Does USAC have representatives who can explain the rules and help provide basic guidance as we consider the self-construction option?
A44:

Yes. E-Rate participants that need additional information or guidance can call the USAC Customer Service Center at (888) 203-8100 to ask questions or receive other assistance.

Hurricane Relief Orders

Eligibility

Q16: My school increased its student population by over five percent of my pre-Hurricane count due to an influx of displaced students. My school is not located in an area designated by FEMA as eligible for individual assistance as result of Hurricanes Harvey, Irma, or Maria. Can I still seek relief?
A16:

Yes. You do not have to be located in any specific county or state to be eligible as an Indirectly Impacted School. You need to demonstrate that you experienced a 5 percent or more increase in the pre-Hurricane student population at your school, which is causing an unanticipated increase in demand for E-Rate eligible services. You will also need to certify that you meet the requirements set forth in Order FCC 17-139.

Consortia

Q1: What documents does E-Rate require to establish a consortia?
A1:

The E-Rate program rules require that a consortium members have a signed letter of agency (LOA) with the consortium lead that authorizes the consortium lead to take specific actions on behalf of each consortium member.  The letter of agency should be tailored to accurately describe what specific actions the consortium lead may take on behalf of the consortium members (e.g., file the FCC Form 470, conduct competitive bidding reviews, request funding, and/or invoice) and that the consortium member is eligible to participate in the E-Rate program and will comply with the E-Rate program rules.  More details about the LOA and a sample LOA are available here.

Eligible Services

Bus Wi-Fi

Q13: What school vehicles are eligible for Wi-Fi?
A13:

School bus Wi-Fi services are eligible for buses that are school-owned, as well as leased or contracted school buses, provided that the school buses are used primarily to transport students to and from school or school-related activities for educational purposes as defined by FCC rules. Occasionally used chartered buses (e.g., used for school field trips), municipal, or city buses are ineligible. Other types of school-owned vehicles (e.g., cars and vans) are also ineligible, even if a school replaced all school buses with vans and now only uses vans to transport students.

Q14: What are the restrictions for Wi-Fi on school buses?
A14:

Equipment and services must primarily be utilized for educational purposes as defined by E-Rate rules. Content and network restrictions should be implemented consistent with those placed on building-based broadband networks. This includes, but is not limited to, Acceptable Use Policies (AUPs) and other school policies that limit network access and Children’s Internet Protection Act (CIPA)-required content filtering capabilities. Wi-Fi should only be active during school bus normal operating hours (i.e., when students are being transported to and from school or school-related activities) or when there is a clear educational purpose for enabling school bus Wi-Fi connections outside of these hours. Bus Wi-Fi service must be disabled outside of these hours and cannot be utilized for community use purposes. 

Q20: If buses equipped with Wi-Fi are parked, may the Wi-Fi be available for educational purposes by allowing students and/or teachers to log onto the Wi-Fi with their credentials?
A20:

Paragraph 12 in the FY 2024 ESL Order explains that the school bus Wi-Fi may be used for educational purposes.  “[W]e permit applicants to enable E-Rate-funded school bus Wi-Fi connections during a school bus’s normal operating hours (i.e., when students are being transported to and from school or school-related activities) or when there is a clear educational purpose for enabling school bus Wi-Fi connections outside of these hours.”  Two examples of parked school buses being used for educational purposes are when a school uses the Wi-Fi connections to allow parents to participate in virtual parent-teacher conferences or when a school bus is used to provide Internet service to students in the face of an unexpected network outage that would impact students’ ability to complete school homework assignments.