Policy & Funding

What You Need to Know About the Emergency Connectivity Fund

E-rate received a $7.1 billion boost specifically to cover expenses related to off-campus connectivity. An expert dissects how the ECF could be structured, what it can be used for and how to help your district prepare for its arrival.

The $1.9 trillion American Rescue Plan signed into law in March 2021 included a $7.1 billion fund specifically to provide extra E-rate funding for emergency connectivity and devices for schools and libraries. While the Federal Communications Commission, which oversees E-rate via its Universal Service Administrative Co. (USAC), is in charge, the federal agency is still hashing out the details of how the program might work and who would qualify for the funds. In this interview John Harrington, CEO of E-rate consultancy Funds for Learning, offers his perspective about how use of the Emergency Connectivity Fund (ECF) might unfold.

The interview has been edited for brevity and clarity.

THE Journal: Is the Emergency Connectivity Fund going to be like a mini-E-rate?

John Harrington: I think that the most logical design for the program is something to follow in the footsteps of the E-rate program. E-rate is very good in doing its job for a couple of reasons. Number one is, it provides a framework for eligibility, but it does not prescribe the specific technologies or solutions that a school or library has to choose. From the beginning, the E-rate program had an eligible services framework: Here are the basic things you can try to accomplish, but we're not going to dictate how you do that.

Second is the sliding scale of support -- the communities with the highest percentage of students that qualify for free or reduced-price lunch -- qualify for the most support. There's some support for everyone and more support for the communities with the greatest need.

And then there are some very practical reasons also that it makes a lot of sense to plug this new program into that same framework. This is time-sensitive money. it's about getting the resources out into the community as quickly as possible.

The online [E-rate Productivity Center], the application portal that the applicants use, has been tested and improved, and there is a great comfort level with applicants that this would be a good way to go. In fact, in our national survey last year 82% of the applicants said that they thought this would be the best way to administer a remote learning program.

They already know how to fill in these forms; they already know how to use these systems. There's not going to be much of a learning curve there. There'll be a tweak here or tweak there. But that's very different than a whole new set of forms and a whole new system that you have to get accounts set up and verified for.

A key advantage of this new connectivity fund is that it can be used to pay for some services that E-rate traditionally hasn't covered, right?

Once you walk onto a campus, you are in the realm of where the E-rate program traditionally provides support: the internet connection that comes to a building, the Wi Fi signal that covers that campus, the data cabling, switches, the routers, all that stuff. The moment you step off the property, that is where the E-rate program stops.

That has increasingly been a point of frustration for schools and libraries, as the distinction between the classroom and home, the library and the park [blurs]. It's about having a connection to the Internet, being able to get online, to collaborate, to access files or a class or turn in an assignment, and it doesn't matter so much where you're at to do that. But the E-rate regulations are still stuck in this very brick-and-mortar mindset.

This new emergency connectivity fund provides that off-campus piece -- from the moment students leave that facility -- and allows them to remain connected to the internet and provides them a device so that they can stay online and continue their education. And that is what makes this new program very unique.

Now, it is a one-time program. That means we're not talking about a permanent addition to E-rate. We're talking about a one-time special event.

We do hope though that this will set a precedent and show the FCC or Congress that there is a mechanism to fairly and effectively and efficiently provide support, and that there are ways to address the digital divide that don't break the bank -- that you can manage this, you can do it effectively, there can still be good accountability, and we can make sure that learners are online wherever they might be.

Should there be some enumeration of the students who need continued connectivity as part of figuring out how much districts should be eligible for?

This is where we think it's very important to have flexibility. This last E-rate cycle had about 21,058 applicants. Every one of those schools and libraries has a different story, a different circumstance. And for that reason it is very difficult to come up with a one-size-fits-all solution.

One of the questions that has come up in the debates has been whether the Emergency Connectivity Fund should be retroactive -- allowing for reimbursements for expenses incurred over the course of the pandemic -- or whether should it be focused on new expenditures to keep students connected.

Our philosophy is that it's all of the above. There needs to be flexibility because you want to support the school or the library that needs new support. And you also don't want to penalize someone that maybe was very scrappy and took their budget and found a way to make it happen. In fact, you want to you want to reward, encourage and support that. And there may be other instances where schools used CARES Act funds or the Governors fund or other sources to cover those expenses, and what they need now is to have the next stage covered.

if you have a flexible structure, then you can actually allow all of those. And that way you maximize the opportunity to deliver support that's needed for schools and libraries.

It's hard to overestimate the full extent of what schools and libraries have had to shoulder. And quite frankly, it will be pretty hard, I think, to get out too far in front of them, because of the responsibility they've had to shoulder for the past 15 months.

That is quite a variation from E-rate, which is a discount program, where you have to justify what you're spending and how. Is USAC up to managing those kinds of variations?

This is how we look at the overall program. If you divide that $7 billion up, it ends up being a fairly modest amount of funding -- $117 per student, $23,286 per library branch. It's a lot of money, but not a lot when you spread it all out. The key becomes, how do you dial it in for maximum impact?

Many of the services it's meant to cover are not "one-and-done" moments in time. This isn't like we go out, build the road, and now we've got the road to use. Much of this is ongoing connectivity, monthly services or connected learning devices that need to be updated, that need to be repaired, that need to have new software installed. It's not something that's ever really going to be done.

Somehow, we have to figure out how to structure it. We've been told it's $7.171 billion. We know it's for remote learning. And it's 100% reimbursement of reasonable expenses.

And there are a couple other factors that that we would add to it. Number one is "fair and equitable." We think that the funding should on balance be provided more to the communities with the greatest need. There are students in every corner of the country that need support. At the same time, we believe that communities that have the highest poverty levels should have access to the most funding. We also think there should be flexible solutions, providing the right support for the right problem in order to make sure that the schools and libraries are getting the support that best fits their particular needs.

Also how do you provide timely support? How do you get the funds out quickly? That's one of the reasons it makes really good sense to leverage the E-rate program. And then fiscal accountability -- making sure that the public is aware where those funds have gone, that there's been oversight, that we can research the impact of this, we can see how many devices were purchased and how many Wi Fi hotspots were delivered -- all of that.

It's like a big sandbox. What does that solution look like?

What we imagine is a system that follows the E-rate program structure and ties the maximum reimbursement amount to the size of the school district, as measured by enrollment or the size of the library building based on the square footage, times the E-rate discount. That would be the basic formula.

Let me just show you quickly what that would look like. You'd take a school district's enrollment times a factor -- in this case would be $157 per student -- times the E-rate discount rate, to calculate the maximum reasonable reimbursement for that school:

Enrollment x $157/student x E-rate discount factor = Maximum reasonable reimbursement

In a school district with 2,500 students qualifying for a 40% E-rate discount, the maximum reimbursement for that district would be $157,000. If they were at the highest E-rate discount of 85%, they would qualify for $333,625.

This provides a mechanism where every community could get some support. But communities with the greatest economic need would have a higher reasonable amount for which they would qualify.

And then within that amount, we envisioned that they would have the freedom to invest in whatever particular mix of connections, devices and other ancillary types of services and support that are required when you're deploying devices out to thousands of students -- such as cybersecurity.

What's the timing for this?

The rules will be finalized sometime in May. And we anticipate that there will be a filing window sometime in June or July.

Can you offer any guidance for IT leaders to help them prepare for this coming new source of funding?

During this rulemaking period, let your needs be known. Submit comments to the FCC and to the associations you're part of. That's very important.

And then from an IT planning perspective, the challenge that you're facing today is still the unknown, of course. Where will students be? Where will teachers be? Is there going to be another surge? Prepare for that hybrid network of connected students: More students with more devices on campus, more students with more devices off campus.

Survey your various funding sources to identify which funding sources are going to address the various aspects of what you need to put together that comprehensive network. We know that E-rate will provide the on-campus connections. We know that this Emergency Connectivity Fund will support both connections and devices. There are other funding sources, such as the Emergency Broadband Benefit (EBB) program, which is intended to help homes get connected. One scenario would be leaning on that EBB program to get the connections, the hotspots into the community, and then leaning on ECF for the devices themselves. The very best practice here is to sit down and look at these major funding sources and really map out what they target -- how they can be plugged in. And then set up a timeline for each of those in how you move forward.

I think the schools that do an effective job of recognizing those big funding buckets and leveraging them in conjunction with one another will have the most success and will find themselves this fall best situated to serve their community and keep their students, their teachers and their staff connected.