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COVID-19 and E-rate: July 2020

As schools nationwide continue to wrestle with how and when to start the 2020-2021 school year, the availability and affordability of distance learning solutions have become a key area of emphasis. While the E-rate program enables schools and libraries to deliver high-speed Internet service to students and patrons on school or library property, as of mid-July 2020 program rules have not been changed or waived to support student connectivity in a safer-at-home world.
 
That isn’t to say the FCC has been silent, however. Recognizing that school and library administrators may be unable to access on-site resources necessary to complete various aspects of the E-rate process, the Commission extended the Form 471 deadline for FY2020 and issued a blanket extension of many deadlines for responding to information requests and filing various program Forms.
 
But deadline extensions for the existing program only go so far. While on-campus connectivity remains a key element of many back-to-school plans, broadband connectivity in student homes is another huge part of the discussion. And for as significant an impact as E-rate has on on-campus connectivity, off-campus access lags behind – whether a function of cost, availability, or both.
 
At Funds For Learning, we see the struggle from many angles. So many of our applicant clients have reached out to us asking if there are any options via E-rate to get underserved students connected. We’ve seen a number of applicants nationwide who have submitted funding applications for various types of off-campus access, even though we assume that they understand that those applications are almost certain to be denied.  And still other schools have reached out to businesses, community leaders, and philanthropic organizations hoping to receive support in the form of cash or in-kind donations of equipment or services to connect students.
 
So to be clear, as of today, the E-rate program administrators have made no substantive changes to program rules which would allow funds to be used to support off-campus broadband Internet connectivity, in any shape or form.  From an E-rate perspective, all of these options – which, incidentally, are technologically feasible and able to be procured in a cost-effective manner – are ineligible for program support:
  • 4G/LTE service for school buses
  • 4G/LTE service for take-home wi-fi hotspots 
  • Wi-Fi service where coverage extends beyond the property line of a school or library location
  • Outdoor Wi-Fi equipment strategically placed to cover large geographic areas
  • Advanced wireless technologies like Internet over television white space
  • Wireline service to high-density low-income populations and facilities
Connectivity is available.  It’s available at a reasonable cost.  The E-rate program is purpose-built to support connectivity at a reasonable cost.  So with only very minor rule changes, the FCC could affect significant and positive changes in broadband infrastructure deployment, K-12 education, and, given our current situation, even public health.
 
The time is now, and the plan is ready. To find out more about how you can help, please visit https://www.shlb.org/policy/remote-learning.
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