On September 8, 2020, the State E-rate Coordinators’ Alliance (SECA) submitted an ex parte comment to the FCC suggesting changes to how charter schools are classified in the E-rate program in order to aid in the calculation of Category Two budgets under the new rules starting in Funding Year 2021.  
Stating that “the existing approach will no longer work because the operationally independent charter schools need to be able to exert direct control over their Category two budgets based on their own enrollment,” SECA recommends that charter schools be classified as operationally “independent or dependent” based on whether or not the charter is “financially responsible for procuring, contracting, and paying for E-rate services and equipment.”  The changes, SECA says, “will provide needed clarity to the E-rate community and are able to be implemented within the existing framework of EPC, and do not require any system modifications.”
SECA’s ex parte may be viewed here