On May 5,2021, an ex parte comment was filed by Schools, Health & Libraries Broadband (SHLB) Coalition, State E-Rate Coordinators’ Alliance, Funds For Learning, State Educational Technology Directors Association, Urban Libraries Council, Consortium for School Networking, American Library Association, providing recommendations to further ensure maximum reach of the Emergency Connectivity Fund (ECF) benefits and to improve the effectiveness of the E-rate program.
The suggestions include:
- A single filing window covering eligible costs incurred from March 1, 2020, when school and library closures swept across the country, through June 30, 2022, the end of the upcoming school year should be adopted in place of two separate windows covering different periods.
- The risk of oversubscription should be mitigated by adopting a policy of an across-the board percentage pro-ration if necessary. Applicants that cannot afford to pay the total costs of prospective eligible equipment and service should be allowed to apply for ECF reimbursement upon either issuing a purchase order based a bona fide vendor quote or payment of a vendor invoice subject to appropriate verifications that guard against waste, fraud and abuse
- “Unmet need” certifications should be clarified, and low-income students should be presumed to need a school-purchased connected device and/or Internet access service.
- The performance measurements governing USAC’s administration of the ECF Program should be clarified to require user input and review of the ECF filing platform during implementation and before it is finalized.
- The Commission should ensure that for students, school staff and library patrons without sufficient services, extension and installation of broadband facilities for remote learning and online library services will be permitted upon meeting certain prerequisites.
- We encourage the Commission to allow E-rate funded Internet access to be used off-campus.
The groups’ ex parte may be accessed here