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Hi folks!

This is a long email – my apologies!

The Emergency Connectivity Fund Program application filing window will be open for 10 more days!  If you want to be considered,  you must apply by next Friday, August 13th.

I’ve had some questions about invoicing, up-front cost assistance and a certification statement on the ECF FCC 471, so I wanted to provide a separate message addressing concerns.

The FCC’s FAQ page for the ECF<https://www.fcc.gov/emergency-connectivity-fund-faqs> (lots of acronyms today!) has some informative answers that might help you.  If you scroll to the bottom of their page, you will find a menu of helpful topics (see below):

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The FCC is adding clarifications and updated guidance consistently to this page, so it’s a good idea to refer to it often.  Updated/new guidance is notated with an asterisk (*).

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CLARIFICATION FOR CERTIFICATION STATEMENT ON ECF 471:

Regarding the certification statement on the ECF 471 that said you had to certify you had already ordered or received equipment – the FCC offered clarification in a public notice on July 22nd regarding the language in this certifications statement.  Please see their guidance below:

*7.1 Q: Do applicants need to have contracts in advance of submitting an application for ECF support?

A: No, contracts are not required under the ECF Program rules, but applicants are required to comply with state, local, or Tribal procurement laws or regulations. Applicants also do not need to have already placed an order for eligible equipment or services prior to filing an application.

Please see DA 21-881<https://urldefense.com/v3/__https:/www.fcc.gov/document/emergency-connectivity-fund-service-delivery-deadline-public-notice__;!!PRtDf9A!776Ds_IyjDIEOuiREpGQrqsls9VfpLutsZTc6oyignkWFTG-C1I-1fc6_gKaVZFqFg$> for more information about the application certification language in 47 CFR 54.1710(a)(1)(x).
Today, USAC indicated that it will update the certifications page language to say: “[t]he applicant or the relevant student, school staff member, or library patron has received, or the applicant has ordered or will order, the equipment and services for which funding is sought.”   So, you do not need to have received or purchased equipment/services before submitting your ECF 471.  You can just make a note in the FRN narrative that no order has been placed, but will be, consistent with the provisions in the July 22 Public Notice (from the FCC).

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INVOICING:

There are two mechanisms available to invoice for ECF services/equipment:


1.)     filing the BEAR form for reimbursement (library receives equipment/services, pays the vendor and seeks reimbursement for costs with the BEAR form).  Copies of the vendor invoices must be uploaded with all reimbursement forms.

2.)     SPI invoicing - working out an agreement for a discounted bill with your chosen vendor.  This means that the vendor is the one invoicing USAC for reimbursement.  Note that vendors are not *required* to provide this type of invoicing.


I’m worried about paying up-front and then seeking reimbursement. Is there a way I can be reimbursed before I pay my provider?

  *   There is a very specific way you can apply for reimbursement (utilizing the BEAR invoicing method) before paying your provider and the FCC has an answer for that 😊:

9.3 Q: Can a school or library apply for reimbursement before paying the service provider?

A: Yes. Applicants can submit requests for reimbursement before they have paid the service provider if they have entered into contractual arrangements or are otherwise legally obligated to purchase eligible equipment and services from their service provider. Applicants must pay their service provider within 30 days after receipt of funds and will be required to certify compliance and provide verification of payment to the service provider.

Can I get my provider to just discount a bill for me?

  *   You may want to ask your service provider about the SPI invoicing option.  This is the invoicing option where the service provider invoices USAC for reimbursement and provides you with a discounted bill. Please note* - service providers are NOT required to offer this option for ECF funds.   You will need to contact them and work this out.

*Remember that if your service provider/vendor is willing to use the discounted billing (SPI) method, you MUST provide a document (when you submit the ECF Form 471) verifying the agreement for the vendor to submit invoices.

Some helpful NEW FCC guidance regarding SPI invoicing and SAM.gov registration and invoicing is below:

*9.5 Q: Does an applicant using SPI invoicing need to register with SAM.gov?

A: No, applicants in the ECF Program whose service providers will file invoices on their behalf for ECF reimbursement (SPI invoicing) are not required to register in SAM.gov.
How do I invoice for my recurring monthly services?  Do I need to submit invoices within 60 days of each monthly invoice?
Again, from the FCC FAQ:

9.1 Q: Do approved applicants that receive recurring monthly services need to submit invoices within 60 days of each monthly invoice?

A: No. For recurring services that are invoiced on a monthly or periodic basis, approved applicants may invoice within 60 days of the last date of service (i.e., they must invoice at least once by August 30, 2022 for services received through June 30, 2022).

What if I ‘pre-pay’ for a year? Can that be reimbursed?
9.2 Q: Can applicants pre-pay for a year of services and seek reimbursement as soon as they have a funding commitment?
A: No. Approved applicants cannot invoice for services that have not yet been received.
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UPCOMING TRAINING:

Another reminder – USAC is offering weekly ‘office hour’ sessions every Wednesday!  To view the most recent (or past) session recordings OR register to attend next week’s session on August 4th at 3:00 pm EDT, please visit the USAC’s Live Sessions training page<https://www.emergencyconnectivityfund.org/training/live-sessions/>.   These are very helpful sessions where other applicants and providers attend and ask questions for clarification.

Additionally, today USAC released information about an FCC webinar today at 2:00 pm EDT.  Please see below for that announcement with links on how to attend!

The FCC will host a webinar<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=903c022e660f64a1fe19155d49334ec4e3c8dcc245d9dd081a5c10b04437c51b86883b7fdaa89c7ce982282d04f58e4e8314018fbb0f3924__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQqIvgj7fQ$> TODAY at 2 p.m. ET on fcc.gov/live<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=903c022e660f64a1f9fe2c6540ff610c47bd02833417ece86ab1d468d735a139155bc7cc3b625d868498e3d33f4bc4bb58ce08f7f802d3ec__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQqpXs51DA$> to highlight frequently asked questions and answer questions submitted by potential applicants. No registration is required for this event. The webinar will be recorded and be available on the FCC’s website<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=903c022e660f64a1b1cd1bf7e0d1e6e844beccb65abc22d468f88d77996ecbc4b5c9bec54e9167ba922e3c55dd8b4c4c2550b1071fdf3b19__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQp6OoYDZQ$> for viewing after the event.

The FCC added newly updated resources, including an application process overview<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=324251937bcf13741a4dc6f6324fd9ae6792201f3f4d02b0cf2dceec489808f60aa2fa2263f3dd1f77fdefa3cf050b77e05dfad3d3d3d0a3__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQr8dO9FMw$> and a program flyer<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=324251937bcf1374e388cd95425add4378cf680a96d79d5f51f9e47d2bbcbb7224b8a63ec79fd87f6aecbe0c72f161c646ffc0cfc7239903__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQroAG-ejQ$>.  You may also review additional Frequently Asked Questions about the Emergency Connectivity Fund Program here<https://urldefense.com/v3/__https:/click.outreach.usac.org/?qs=324251937bcf1374ea7f6395ead9cfb8f7354d26b6ee52e4e8c65a3a81587b637fc5f5f4c8dd5ba8eca0c019817dc636b67d2532d69a424f__;!!PRtDf9A!5N1EHhN31UMoiLOdS5DrEi3Nbo2_AS3XJ8ZaJtPMWm9UM7gYTwnCPZ8xzQpI1fWmow$>.



I hope this is helpful to you all – lots of information to digest!

Happy filing!

Liz

Liz Thigpen Schreck | Director
Ocoee River Regional Library
State E-rate Coordinator for Public Libraries
Office of Tennessee Secretary of State Tre Hargett
718 George St., NW, Athens, TN 37303
P. (423) 745-5194 – office;  (423) 649-1583 - direct
Regional Toll Free - (855) 692-8186
Fax (423) 649-1501
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