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Emergency Connectivity Fund Common Misconceptions

Recently, the FCC published a list of common misconceptions about the Emergency Connectivity Fund program in efforts to clear up any confusion. They include:

Misconception #1: Schools cannot apply for funds unless they have surveyed all parents to determine need.

This is false. Schools need only provide best estimates of unmet need in applying for ECF support. It is up to the school to determine how to estimate need – a school can choose to use a survey but is not required to use one.

Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate.

This is false. Even if schools have returned to in-class instruction, they are eligible to seek Emergency Connectivity Fund support for unmet remote learning needs, such as broadband access for homework or lesson planning. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices and/or a broadband internet access connection while off campus are eligible for Emergency Connectivity Fund support.

Misconception #3: If schools have received ESSER or CARES Act funds to buy connected devices/hotspot devices, they are not eligible to participate.

It depends. While schools and libraries may not seek support for equipment or services that have already been fully paid for through other federal or state funding sources (such as federal pandemic relief money), they may seek funding for any portion of the costs of the equipment or services that were not covered. This could include applying for ECF support for the monthly broadband service costs associated with a hotspot device that was purchased using other federal or state funding sources if service was not included as part of the original purchase. They may also seek support to address ongoing unmet needs that are not covered through other funding sources (see ECF Report and Order, paras. 125-128).

Misconception #4: If households receive EBB benefits, they are ineligible to receive devices or service through ECF.

It depends. ECF rules do not permit applicants to receive duplicative support for services that are reimbursed through other federal or state programs. However, a school could receive ECF support to purchase a connected device for a student if needed to support learning, even if the household is receiving internet service through the EBB program.

Misconception #5: Libraries are only allowed to lend devices to K-12 students due to educational purpose requirement.

This is false. While libraries must use ECF support primarily for educational purposes, there is no restriction that devices be loaned to K-12 students, and the Order makes clear that library patrons may include library staff (see ECF Report and Order, para. 64, n.188). “Educational purposes” is defined as activities that are integral, immediate, and proximate to the provision of library services to library patrons in the case of a library (see ECF Report and Order, para. 63).

Misconception #6: Schools and libraries need to conduct competitive bidding, like they do for the E-Rate program.

This is false. While schools and libraries need to comply with state, local and Tribal procurement requirements, there are no federal competitive bidding requirements like there are in the E-Rate program (see ECF Report and Order, paras. 87-89).

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