ECF FAQ’s

Frequently Asked Questions

Can a school or library submit an application in the third application filing window to continue services that were funded through a first or second window funding request?

Yes, provided they are not requesting duplicative funding for services that are committed and were or will be funded through the applicant’s first or second window funding requests.  To avoid duplicative support and expedite the review of the third filing window applications, applicants should include in the narrative section of the ECF FCC Form 471 application, information regarding services funded through first or second window requests, including the ECF FCC Form 471 application number(s) and the service end date(s) for these services that will be funded through the first or second window funding commitment, as well as the up to 12 months of new services being requested during the third application filing window.  For example, an applicant received a funding commitment decision letter on December 31, 2022 for 12 months of recurring services for its second window application.  If the applicant starts the recurring service on January 1, 2022 (because they were waiting to receive a FCDL before starting services), the applicant would provide information about this application and FRN, as well as the service start and end dates of January 1, 2022 through December 31, 2022 in the narrative section of their third filing window ECF FCC Form 471.  The applicant could also request support for the continuation of this recurring service from January 1, 2023 through December 31, 2023 on its third filing window ECF FCC Form 471 and note in the narrative that these are the service and end dates for the third filing window request for services.

Can we request funding for service for all 18 months of the relevant funding period for the third application filing window?

No.  Applicants may only request support for a maximum of 12 months of eligible services during the third application filing window that covers eligible equipment and services received or delivered between July 1, 2022 and December 31, 2023.  On the ECF FCC Form 471, an applicant should provide the service start and end dates for the 12 months of service that will be requested during that funding period.

What is the deadline for filing for reimbursement for funding requests submitted during the third application filing window?

On March 23, 2022, the Bureau established December 31, 2023 as the service delivery date for all requests for equipment, other non-recurring services, and recurring services submitted in the third application filing window.  Therefore, the invoice filing deadline for these third window ECF funding requests is 60 days from the later of the following dates:

  • The date of the funding commitment decision letter (FCDL);
  • The date of a revised funding commitment decision letter (RFCDL) approving a post-commitment change or a successful appeal of previously denied or reduced funding; or
  • The service delivery date of December 31, 2023. 

This also means that all of these funding requests have an invoice filing deadline of February 29, 2024, unless the FCDL is issued after December 31, 2023 or the RFCDL is still pending.

Please see DA 22-309 for additional information about the service delivery date applicable to third window ECF funding requests.  The modified service delivery date rule (section 54.1711(e)) became effective on April 4, 2022.

What must applicants or service providers, who agree to invoice on behalf of applicants, do to be compliant with the non-usage certification?

The Commission declined to adopt specific non-usage rules for the ECF Program.  Instead, applicants and service providers are required to certify on the request for reimbursement that they are not willfully or knowingly requesting reimbursement for services and equipment that are not being used.  While the ECF program only funds equipment and services that are in use, there may be certain circumstances (e.g., during a school’s winter and summer breaks or sick days) where the services are still eligible for ECF support.  ECF participants should take reasonable actions to monitor and track the usage of equipment and services that are purchased and used through the ECF program.  For example, the Report and Order suggested that applicants could ask their service providers to provide monthly reports or other information on data use as one way to comply with the certification.  ECF participants can take other reasonable steps, such as ensuring a hotspot device is activated.  ECF participants should be prepared to explain what actions were taken, if asked how they complied with the non-usage certification during an audit or other post-commitment review.  

What is the extended service delivery date and invoicing deadline for funding requests submitted during the first and second application filing windows?

Per the FCC’s February 22, 2022 Order (DA 22-176 ), the service delivery date for Emergency Connectivity Fund Program requests for equipment, other non-recurring services, and recurring services submitted during the first and second application filing windows was extended from June 30, 2022 to June 30, 2023.  Based on this Order, the invoice filing deadline is now 60 days from the later of the following dates:

  • The date of the funding commitment decision letter (FCDL);
  • The date of a revised funding commitment decision letter (RFCDL) approving a post-commitment change or a successful appeal of previously denied or reduced funding; or
  • The service delivery date of June 30, 2023. 

This also means that these funding requests have an invoice filing deadline of August 29, 2023, unless the FCDL is issued after June 30, 2023 or the RFCDL is still pending.

USAC is in the process of updating its systems to reflect the new service delivery date for upcoming and existing ECF commitments. Until the systems work is completed, the previous date of June 30, 2022 will still be reflected in your FCDL and in the ECF portal.   

Please note that the Order does not impact funding requests for the construction of new networks or the provision of customer premises equipment for datacasting services.  Applicants seeking support for special construction or customer premises datacasting equipment are provided one year from the date of their funding commitment decision letter to demonstrate that construction is completed and the services have been provided.

If the applicant doesn’t start service until after its funding commitment decision letter is approved for a first or second window funding request, can it still receive the 12 months of service requested and approved?

Yes, the Bureau granted a waiver (DA 22-176 ) extending the service delivery deadline for all first and second window funding requests for equipment, other non-recurring services, and recurring services from June 30, 2022 to June 30, 2023. Applicants may request reimbursement for the 12 months of service that was requested and approved, even if they didn’t start the service until after the funding commitment decision was received.

If the applicant didn’t start service until September 1st and originally requested only 10 months of service, can it now request additional funding for recurring services beyond June 30, 2022 with the FCC’s new service delivery date extension for first and second window funding requests?

No, requests to increase the support amount for a funding request, pre- or post-commitment, will be denied. 

For additional information, please refer to the FCC’s website linked here! Emergency Connectivity Fund FAQs | Federal Communications Commission (fcc.gov)