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.
- By Dian Schaffhauser
$1.9 trillion American
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
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
offers his perspective about how use of the Emergency Connectivity
Fund (ECF) might unfold.
interview has been edited for brevity and clarity.
Journal: Is the Emergency Connectivity Fund going to be like a
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.
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.
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 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.
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.
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,
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.
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.
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.
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
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.
there be some enumeration of the students who need continued
connectivity as part of figuring out how much districts should be
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
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
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.
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.
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.
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?
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?
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.
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.
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
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.
like a big sandbox. What does that solution look like?
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.
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:
x $157/student x E-rate discount factor = Maximum reasonable
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.
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.
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
the timing for this?
rules will be finalized sometime in May. And we anticipate that there
will be a filing window sometime in June or July.
you offer any guidance for IT leaders to help them prepare for this
coming new source of funding?
this rulemaking period, let your needs be known. Submit
the FCC and to the associations you're part of. That's very
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.
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.
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.