FAQs

1.1: The application filing window for FCC Form 484 Part 1 will be September 17 to November 1, 2024. The FCC will announce additional details in a Public Notice. In addition, USAC will share this information with stakeholders that register to receive Pilot-specific information.

1.2: Yes, USAC will provide training that is specifically focused on the requirements of the FCC Form 484. USAC will offer training on the Part 1 application requirements in the coming weeks; training regarding the Part 2 requirements will be provided once Pilot participants are selected. USAC and the FCC will make screenshots of the form available as part of the FCC Form 484 trainings for applicant reference.

1.3: The application window for FCC Form 484 Part 1 will be open for 45-days. In establishing the application window, the FCC expects to balance stakeholders’ desire to expeditiously implement the Pilot Program, with the need to provide sufficient time for applicants to compile the required Part 1 information.

1.4: The Pilot Program is completely separate from the E-Rate program, including the application and funding processes. That said, in implementing the Pilot Program, the FCC will take into account the timeframe for the corresponding E-Rate funding year, as well as school breaks, school/library resource limitations and time needed for applicant training.

1.5: Pilot funds will be available as soon as a Pilot participant receives a funding commitment decision letter (FCDL) from USAC and has successfully completed Part 2 of the FCC Form 484 application. Unlike the E-Rate program, the Pilot does not utilize specific funding years, so participants need not wait until a specific date (e.g., July 1, 2025) to purchase cybersecurity equipment and services provided they have otherwise completed the necessary requirements and have received funding commitment decisions. Pilot participants and service providers will be able to request reimbursement after the receipt or delivery of eligible cybersecurity services and/or equipment through the Pilot Program.

2.1: Yes. Like the E-Rate program, Pilot participants will be required to pay the non-discounted share of the costs of the eligible services and equipment they purchase with Pilot Program funds. The percentage of the eligible costs that a Pilot participant will be required to pay will be based on the participant’s Category 1 discount rate. See 47 CFR § 54.2007(e).

2.2: Participants are not precluded from using other sources of funding to pay for cybersecurity equipment and services. However, to ensure efficient and appropriate use of the limited Pilot funds and avoid duplicative funding, Pilot participants may not receive Pilot funding for the same cybersecurity equipment and services funded through other sources.

2.3: Pilot participants can request reimbursement as eligible expenses are incurred, so long as they do not exceed their overall funding commitment for the three-year term of the Pilot Program. Participants must wait until after the receipt or delivery of Pilot-eligible services and equipment to submit invoices.

2.5: Pilot applicants should make a reasonable effort to estimate the costs associated with their Pilot project. The FCC expects to use this information to get a sense of the different sizes and types of projects that are being proposed, in order to ensure a diverse pool of participants. Where available, applicants can use published pricing or reports, past estimates or incurred costs, or other sources of information.

Once applicants have submitted their cost estimates on the FCC Form 484, they will not be able to modify them. As discussed in FAQ 2.6, however, Pilot Program participants will have an opportunity to adjust their projected costs after completing the competitive bidding process and making final decisions about the services and equipment to be purchased.

2.6: A Pilot participant will not be limited to the cost estimate provided in Part 1 of its FCC Form 484. A Pilot participant can apply, and receive funding, for eligible services and equipment up to its maximum budget.

2.7: Yes, but you may not use Pilot funding to cover the same costs that are funded through another source (i.e., no “double dipping” or duplicative funding). Consistent with our E-Rate rules, you may use another source to cover the non-discounted share of your Pilot-funded project or to supplement Pilot funds in order to fully cover the cost of the solution you intend to implement.

2.8: No. E-Rate Category One or Category Two funding may not be used for advanced cybersecurity services and equipment that is eligible in the Pilot Program. The FCC will explore whether and how universal service funds, including E-Rate funds, could be used to support these types of services based on lessons learned from the Pilot Program.

2.9: Neither. The Pilot Program is separate from the E-Rate program and, as such, the funding is considered neither Category One nor Category Two funding. As noted in FAQ 2.8, the FCC will explore whether and how universal service funds, including E-Rate funds, could be used to support advanced cybersecurity services and equipment after the conclusion of the Pilot Program.

2.10: A participant’s reimbursable spending on eligible services and equipment is subject to an overall three-year budget cap. The cap is based on a participant’s type (school, library or consortium) and size (student count and/or number of libraries and sites). See 47 CFR § 54.2001(b). To assist participants in determining their three-year budget cap for the Pilot Program, the Bureau has prepared a set of illustrative examples of budget calculations.

3.1: The FCC expects to approve support for a variety of schools, libraries, and consortia, taking into account the varying stages of their cybersecurity experience. Schools, libraries, and consortia are therefore encouraged to apply regardless of their level of cybersecurity experience.

3.2: Non-eligible entities, such as state, local, and Tribal government entities, and other not-for-profit organizations may serve as Consortium Leaders. However, these types of Consortium Leaders are ineligible to receive Pilot benefits, discounts, and funding and therefore must pass through the benefits, discounts, and funding to their eligible school and library consortium members. See 47 CFR § 54.2002(c)(1) (requiring ineligible entities serving as Consortium Leaders to pass through the full value of the Pilot Program benefits to the eligible Pilot consortium members).

3.3: Educational Service Agencies (ESAs), also known as Educational Service Units (ESUs), Local Educational Agencies (LEAs), and Board of Cooperative Educational Services (BOCES), are eligible to serve as Consortium Leaders.

In addition, if a state recognizes an ESA as an eligible school under its state law, the ESA may apply as an applicant and seek support for its eligible members as it is currently allowed to in the E-Rate program. As with consortia applicants, an individual school may not participate as part of an ESA application and as an individual applicant and must decide how it would like to participate in the Pilot Program.

3.4: No. Given limited funding for the Pilot Program and the FCC’s objective to select as many participants as possible, schools and libraries may apply and participate only once as an individual school or library participant, or as part of a consortium.

3.5: To evaluate Pilot Program eligibility, the FCC adopted the same definitions of elementary school, secondary school, library, and library consortium that it uses for the E-Rate program. Therefore, entities that are eligible to participate in the E-Rate program are also eligible to apply for the Pilot Program. A school, library, or consortium does not need to be an E-Rate applicant in order to apply for the Pilot Program.

4.1: Yes. Equipment and/or services are eligible if they “constitute a protection designed to improve or enhance the cybersecurity of a K-12 school, library, or consortia.” The four categories identified by the Commission are examples of eligible equipment and services, but are not the only ones. Other equipment and/or services are eligible if they meet the Commission’s broad eligibility criteria.

4.2: It depends. Pilot funding may be used to pay for existing cybersecurity services and equipment to the extent such services or equipment are not being paid for through another funding source and were awarded consistent with the competitive bidding exemption adopted in the Order. The exemption applies if the services or equipment were awarded pursuant to a master services agreement (MSA) negotiated by a federal, state, Tribal, or local governmental entity on behalf of a Pilot participant(s); and such MSA(s) were awarded pursuant to the E-Rate program FCC Form 470 process, as well as applicable federal, state, Tribal, or local competitive bidding requirements. The services and equipment are otherwise ineligible for reimbursement through the Pilot Program.

4.3: No. Pilot Program funds are intended to be used prospectively, during the course of the three-year funding term.

4.4: Yes. Provided they meet all other procurement and competitive bidding requirements, participants are permitted to seek funding for multi-year licenses for eligible recurring services that are longer than three years. However, only services delivered within the Pilot Program time period can be reimbursed through the Program.

4.5: High availability firewall solutions are eligible as long as all other eligibility and program requirements are met.

4.6: Consulting services tied directly to the actual installation and initial configuration of eligible equipment and services are eligible, provided that all other eligibility and competitive bidding requirements are met. Other consulting services are not eligible for reimbursement through the Pilot Program. See Eligible Services List

4.7: Staff salaries and labor costs are not eligible for reimbursement through the Pilot Program. See Eligible Services List

4.8: The Pilot has a limited amount of funding available, and the Commission has focused on funding specific technologies rather than staff and training programs. That said, training costs are eligible in some scenarios. For example, training is eligible as part of the installation of equipment and services, if it is basic instruction on the use of the eligible equipment and services, directly associated with equipment and services installation, and part of the contract or agreement for the equipment and services. It must occur concurrently with or within a reasonable time after installation.

We note that vendors are also likely to include basic training at no additional cost as part of their sale of the eligible equipment and services and there are many free and low-cost cybersecurity training resources available through CISA and other federal government partners.

4.9: Yes, as is also required in E-Rate, Pilot participants are required to perform a cost-allocation to remove from their Pilot Program funding requests any costs associated with ineligible components or functions of otherwise eligible equipment or services. See 47 CFR § 54.2006(c).

4.10: Cybersecurity services used on end-user devices that are owned or leased by a participating school or library are eligible, regardless of whether the services are network-based or locally installed on the end-user device. See Report & Order, FCC 24-63, Appendix B, note 4.

4.11: No. Basic firewalls are not covered by the Pilot Program.

4.12: Equipment purchased with Pilot funds can be installed or located at a facility that is owned or maintained by an entity that is ineligible for funding, so long as the equipment is for the exclusive use and benefit of the Pilot-eligible schools and libraries.

5.1: Participants will be selected through the FCC Form 484 application process. In the FCC Form 484 Part 1, applicants will be required to provide general information about the schools and libraries seeking support, as well as information about the proposed Pilot project. If selected to participate in the Pilot Program, participants will be required to provide more detailed information about their cybersecurity experiences in Part 2 of the FCC Form 484 application.

To facilitate the inclusion of a diverse set of Pilot projects and to target Pilot funds to applicants most in need of cybersecurity support, the FCC will award support to a combination of large and small and urban and rural schools, libraries, and consortia, with an emphasis on funding proposed Pilot projects that include low-income and Tribal applicants.

5.2: Need generally will be determined based on an applicant’s discount percentage rate. A school’s discount percentage rate is determined based on the percentage of its student enrollment that is eligible for a free or reduced price lunch under the National School Lunch Program. The discount percentage rate for libraries and consortia will be calculated based on the percentage of student enrollment that is eligible for the National School Lunch Program in the public school district in which they are located. The discount rate percentage will then be adjusted by geographic location (i.e., urban or rural) in the same manner as it is in the E-Rate program. See 47 CFR § 54.2007.

5.2a: If demand is greater than the $200 million cap, the FCC will look at applicants’ discount band to select Pilot participants. Consistent with Pilot Program rules, applications in the 90 percent discount band will be reviewed first. If there is not enough support to fund all requests within the 90 percent discount band, the FCC will look at applicants’ specific National School Lunch Program percentages, starting with the highest percentage. To ensure diversity in the applicant pool, application review will also consider the other criteria identified in the Report and Order – applicant type, urban/rural, small/large, and Tribal – within each discount band.

5.3: The FCC expects that it will be able to ensure diversity of geography, size and cybersecurity experience, while prioritizing applicants with the greatest need. The selection criteria adopted in the Report and Order provides the flexibility needed to ensure that a wide array of well-defined projects, submitted by a variety of applicant types, will be selected.

5.4: USAC, together with the FCC, expects to complete review of Part 1 of the applications and select participants as expeditiously as possible. The timing of the selection process will depend on the number and quality of the applications received.

5.5: Given the level of stakeholder interest in the Pilot Program, we expect to fully commit the available funds in the first year.

5.6: Yes, we expect applicants selected to participate in the Pilot Program will be committed to participating for the entire three-year term of the Pilot. In doing so, we expect it will help participants maximize their benefits and ensure the Commission is able to gather the data it needs to fully evaluate the Pilot. Additionally, we hope participants will be mindful of the opportunity to participate in the program and recognize the many others who, if selected, would be eager to participate for the entire three-year term.

Choosing to participate in the Pilot but failing to satisfy Program requirements (such as reporting obligations) by withdrawing early from the Pilot may result in a referral of a participant to the Enforcement Bureau, a hold on future disbursements, a rescission of committed funds, and/or recovery of disbursed funds.

5.7: No. While the FCC hopes to select as many applicants as possible to participate in the Pilot, we anticipate that the demand will exceed the available funding.

5.8: There is no way to know who is going to apply, so we encourage all eligible schools, libraries, and consortia to consider submitting an application for the Pilot Program. The FCC specifically established a streamlined application process to make it easier for prospective participants to submit an application.

5.9: There is no set number of applicants that the FCC expects to select as Pilot participants. We encourage everyone who is eligible to apply, as we hope to select as many applicants as possible to participate in the Pilot Program.

5.10: Similar to the E-Rate program, prospective applicants may hire a consultant to help prepare their FCC Form 484, but need to include the consultant’s consultant registration number (CRN) on their account profile in the E-Rate Productivity Center (EPC). If needed, consultants may obtain a CRN from USAC. Consultants participating in the Pilot Program application process are subject to the same suspension and debarment rules that apply to universal service programs.

5.11: Yes. USAC is planning special training for small, less-resourced schools and libraries, as well as schools and libraries that have not participated in the E-Rate program. In addition, USAC will host office hours and offer a help desk for applicants that require additional assistance in filling out the forms needed to apply for, and participate in, the Pilot Program. Schools and libraries are also welcome to email cyberpilot@fcc.gov if they have questions.

5.12: Yes. Given the underlying purposes of the Pilot and the importance of the performance goals and data reporting to the Pilot Program, the FCC will consider an applicant’s willingness to provide data when selecting Pilot participants. Specific data reporting requirements will be established in forthcoming Public Notice(s). See FAQ 8.1.

5.13: There is no “right” or “wrong” answer to any of the questions regarding an applicant’s experience, needs, or resources.  Applicants should answer truthfully and thoughtfully about what solutions best fit their needs, given resource and other considerations. One of our goals is to ensure the Pilot contains a diverse cross-section of applicants with differing cybersecurity postures and experiences.

5.14: There is no “right” or “wrong” answer to the question regarding whether an applicant’s Pilot project will be self-sustaining at the conclusion of the Pilot Program. Applicants should answer truthfully and thoughtfully, based on their best estimate regarding resources that will be available at the conclusion of the Pilot Program.

A project is considered “self-sustaining” if it can remain operational (i.e., the applicant has the ability to continue the service or maintain the equipment) without additional Pilot funds at the end of the program. Applicants will be requested to identify what funding source, if any, they expect to utilize, including federal, state, local, Tribal, or other funding sources.

5.15: Yes, Pilot participants may modify their Pilot project after they submit their FCC Form 484 Part 1. However, once the FCC has issued a Funding Commitment Decision Letter approving a participant’s requested cybersecurity services and equipment, any subsequent changes would require approval consistent with the Pilot Program rules.

5.16: Individual and consortia applicants should make every effort to ensure that an individual school or library is applying only once to participate in the Pilot Program. An applicant should contact USAC as soon as it becomes aware of any duplicative applications.

If an applicant inadvertently applies both individually and as part of a consortium, it will need to decide which application it wants to be included on and which application USAC should remove it from. If the applicant decides to pursue an individual application and asks USAC to remove it from a consortium application, the applicant should notify the Consortium Leader that it no longer wants to be listed on the consortium application so that the consortium may modify its application accordingly.

Failure to correct the duplicative applications could result in the applicant and/or the consortium being removed from the Pilot Program.

5.17: Yes, Consortium Leaders are required to collect and retain letters of agency (LOAs) from their consortium members affirming their authorization to act on the member’s behalf in the Pilot Program, similar to the requirement in the E-Rate Program. If the Consortium Leader is authorized by the terms of an existing LOA, a Consortium Leader may rely on the existing LOA to act on behalf of the consortium member for the Pilot Program, otherwise a new LOA is required for the Pilot Program. The Consortium Leader is also required to retain LOAs from their members as required by the program rules and provide upon request.

If an individual Pilot applicant provides an LOA to a Consortium Leader authorizing them to apply in the Pilot Program on their behalf, they should not also submit an individual application.

5.18: We expect that applicants selected to participate in the Pilot Program will be committed to participating for the entire three-year term. Applicants are urged to carefully evaluate whether they are able to satisfy Pilot obligations prior to submitting their FCC Form 484 Part 1 applications. To the extent a Pilot participant determines that it must withdraw from the Pilot, it should contact the Wireline Competition Bureau (by emailing cyberpilot@fcc.gov) for additional information about the withdrawal process.

Penalties for failure to comply with Pilot Program rules may result in a referral of a participant to the Enforcement Bureau, a hold on future disbursements, a rescission of committed funds, and/or recovery of disbursed funds. See 47 CFR §§ 54.2004(d)(5) and 54.2004(e). The scope of any potential consequence for non-compliance with the Pilot Program rules will depend on the specific circumstances, including whether any funds have been disbursed. The FCC does not anticipate routinely referring Pilot participants to the Enforcement Bureau for rule violations.

5.19: Prospective applicants on Red Light status (or prospective applicants that share a Taxpayer Identification Number (TIN) with an entity on Red Light) must resolve outstanding debts on or before the FCC Form 484 Part 1 application deadline, November 1, 2024, to be eligible to be selected participate in the Pilot Program. To confirm that your entity is eligible to be selected to participate in the Pilot Program, visit the FCC’s CORES webpage, to check your financial status with the FCC. If your entity is on Red Light, you must pay the amount(s) owed and resolve the Red Light status on or before November 1 to be eligible to be selected as a Pilot Program participant.

6.1: The Pilot FCC Forms 470/471 are modeled on the forms used for the E-Rate program but will be their own distinct forms. There will not be any material difference in the information required.

6.2: Yes. We expect to make the data from the FCC Forms 470/471 available through Open Data.

6.4: Pilot participants are not required to perform a new competitive bidding process when seeking support for equipment/services from a Master Services Agreement (MSA) or State Master Contract (SMC) awarded pursuant to the E-Rate FCC Form 470 process and applicable federal, state, Tribal, or local competitive bidding requirements if the MSA or SMC was negotiated by a governmental entity on behalf of the Pilot participant. The MSA or SMC will need to be reviewed and will be posted to USAC’s website as an approved contract under the CBE.

Selected Pilot participants who want to rely on an MSA or SMC that do not qualify under the CBE may seek a waiver of the FCC’s competitive bidding rules by providing evidence demonstrating that the MSA or SMC was negotiated using procurement and vendor selection requirements identical or equivalent to those of the governmental entity-negotiated contracts that qualify under the CBE.

6.4a: Yes, Pilot participants may only seek an CBE for FCC Forms 470 that were posted in E-Rate Funding Years 2023, 2024, and 2025. Entities that would like to start competitive bidding for new state master contracts may use the E-Rate FY2025 FCC Form 470 to initiate the procurement process.

6.5: To qualify, an MSA must have been negotiated by a federal, state, Tribal, or local governmental entity, either directly or through a separate governmental entity created by a federal, state, Tribal, or local government for the purpose of providing services to schools and libraries. Other entities, such as non-governmental corporations and other not-for profit entities that were not created by a state legislature, do not qualify for this exemption.

6.6: Yes, with one exception. When a CBE-qualifying MSA identifies multiple vendors for the same services/equipment, a Pilot participant must perform a mini-bid process, using the price of the eligible equipment and services as the primary factor, to select among multiple-award schedules for the MSA. The mini-bid process is not required, however, if the vendors were ranked by lowest price in the MSA and the Pilot participant selects the lowest-price vendor.

6.7: No, unlike the E-Rate program, the Pilot Program does not allow existing, non-qualifying contracts to be converted into eligible contracts based on the E-Rate program’s Kalamazoo precedent. Existing contracts only qualify for the Pilot if they fall within the CBE.

6.8: Prospective Pilot applicants and selected Pilot participants who want to rely on a non-qualifying MSA or SMC must file a waiver request and include in the waiver request a copy of the MSA or SMC for FCC review. FCC staff will determine if the MSA or SMC meets the required standard of identical or equivalent procurement and vendor selection requirements as compared to a competitive bidding exemption (CBE) qualifying contract. Petitioners should provide relevant supporting documentation to demonstrate the requirements of the CBE qualifying contract were met.

6.9: The Pilot Program contemplates that participants would file one Pilot FCC Form 470 and one Pilot FCC Form 471 to cover the entire three-year term of the Pilot. To the extent a Pilot participant seeks to receive support for a license or service that covers only part of the term of the Pilot Program, it should solicit bids for those services when it files the Pilot FCC Form 470 at the beginning of the Pilot and then request the services for the term of the Pilot Program to be covered by the new or extended contract using the Pilot FCC Form 471.

Participants are reminded that the Pilot Program does not allow existing, non-qualifying contracts to be converted into eligible contracts based on the E-Rate program’s Kalamazoo precedent. Existing contracts only qualify for the Pilot if they fall within the competitive bidding exemption. See FAQ 6.7. Participants are also reminded that they must carefully consider all bids received and select the most cost-effective service offering using price of the eligible services and equipment as the primary factor in their bid evaluation process.

Only services delivered within the three-year Pilot Program time period can be reimbursed through the Program. See FAQ 4.4.

6.10: The Pilot Program contemplates that participants would file one Pilot FCC Form 470 and one Pilot FCC Form 471 to cover the entire three-year term of the Pilot program. Pilot participants that plan to request services on a month-to-month basis should do so when they file their single Pilot FCC Form 470 at the beginning of the Pilot and request the month-to-month services using their single Pilot FCC Form 471 for the 36-month period of the Pilot Program. Participants are reminded that they must carefully consider all bids received and select the most-cost effective service offering using price of the eligible services and equipment as the primary factor in their bid evaluation process.

7.1: Consistent with the E-Rate program, Pilot participants have the option to select which invoicing method they prefer. See 47 CFR § 54.2008(f).

7.2: Requests for reimbursement may be submitted after equipment is received or services are provided. Any requests for reimbursement must be submitted within 90 days after the last date to receive equipment/service as set forth in the first funding commitment decision letter. See 47 CFR §§ 54.2001(c) and 2008(d).

7.3: USAC’s website lays out the process and requirements for becoming a service provider. Consistent with E-Rate program requirements, all service providers will be required to file an FCC Form 498 and obtain a service provider identification number (SPIN) if they do not already have one to be able to participate in the Pilot Program. Note that a prospective service provider does not need a SPIN in order to submit a bid but will need a SPIN to provide the eligible services/equipment and receive funding through the Pilot Program through either the Billed Entity Applicant Reimbursement (BEAR) or the Service Provider Invoice (SPI) invoicing methods.

7.4: Resale arrangements are reimbursable under the Pilot Program if the applicable eligible cybersecurity services and equipment are received from an eligible service provider (i.e., a service provider that has a valid Service Provider Identification Number (SPIN) and has met all of the other requirements to participate as a service provider in the Pilot Program). The fact that the eligible services and equipment are provided by a third-party vendor to the eligible service provider (who then provides them to the Pilot Participant) does not change their eligibility, as long as the service provider with whom the school or library contracted for the eligible equipment/services is selected through a competitive bidding process that meets all of the Pilot Program’s competitive bidding requirements (Pilot Program FCC Form 470) and the other Pilot program rules are met.

7.5: The Service Start Date for the Pilot Program will coincide with the opening of the Pilot FCC Form 471 application filing window. That date will be announced in a forthcoming Public Notice.

7.6: A Pilot participant may place an order for Pilot-funded equipment and services before it receives a Funding Commitment Decision Letter (FCDL) from USAC, but it assumes the risk to the extent the funding commitment amount on the FCDL may be less than the cost of what was purchased.

The service start date for the Pilot Program will coincide with the opening of the Cybersecurity Pilot Program FCC Form 471 application filing window.  That date will be announced in a forthcoming Public Notice. See FAQ 7.5.

8.1: Applicants that are selected to participate in the Pilot Program will be required to submit periodic reports, consisting of initial, annual, and final reports. Pilot-specific data reporting requirements, including the format for reporting such data and metrics, will be established by the FCC in forthcoming Public Notice(s). Please note that the failure to submit initial, annual, and final reports may result in a referral to the Enforcement Bureau, a hold on future disbursements, a rescission of committed funds, and/or recovery of disbursed funds. See 47 CFR § 54.2004(e).

8.2: Annual reporting requirements are expected to largely mirror the information that is required in the FCC Form 484 (Parts 1 and 2). Pilot participants may also be asked to answer a series of yes/no or multi-select questions to provide additional detail regarding their cybersecurity expertise and any cyber events that have taken place during the reporting term.

In establishing reporting requirements, the FCC is sensitive to balancing its need to collect Pilot Program data with the burden it puts on Pilot participants. All reporting requirements are subject to the Paperwork Reduction Act approval process.