Apply for FCC Funding to Improve Your Cybersecurity

The Federal Communications Commission (FCC) released a public notice announcing the Cybersecurity Pilot Program application filing window for K-12 Schools and Libraries.

The Application Window
Opens: Tuesday, September 17, 2024, at 8am EST
Closes: Friday, November 1, 2024, at 11:59pm EST

The three-year, $200million program aims to support K-12 schools, libraries, and consortia in enhancing their cybersecurity infrastructure by providing funding for eligible cybersecurity services and equipment.

Important highlights include:

• Application Process: Interested schools, libraries, and consortia must submit Part 1 of the Form 484 to provide basic information about their cybersecurity needs and plans.
• Eligibility: The program is open to all schools and libraries that meet the E-rate Program’s eligibility requirements, including those that have not previously participated in the E-rate Program.
• Budget: The program offers up to $13.60 per student annually for schools and $15,000 per library annually, with funding caps based on the size of the applicant institution.
• Eligible Services and Equipment: Funding can be used for advanced firewalls, endpoint protection, identity protection, and other cybersecurity measures. Some items, such as basic firewalls and certain staff salaries, are ineligible.
• Application Requirements: Prospective applicants must have an FCC Registration Number, a Billed Entity Number, and be registered with SAM.gov. They must also ensure they are in good financial standing with the federal government.
• Evaluation and Selection: Applications will be evaluated based on various criteria, including the applicant’s cybersecurity needs and the ability to meet program objectives.

The FCC’s Public Notice can be viewed here.

USAC conducted a webinar last week to preview the first form — FCC Form 484 Part 1 — to be used by schools and libraries seeking to participate in the Cybersecurity Pilot Program.  As previously discussed, Part 1 of the Form 484 will be used to review prospective participants in the Pilot.  From that review, the FCC will select what we expect to be a much smaller number of applicants to participate in the program itself by filing the next three forms:  Form 484 Part 2, and Pilot versions of the Form 470 and Form 471.

For those schools and libraries who might have thought that Form 484 Part 1 would be used to simply express their interest in the Cyber Pilot, last week’s webinar was a revelation.  The successful completion of Form 484 Part 1 will require a thorough understanding of cybersecurity and a well-thought-out plan for participation in the Pilot.

We strongly recommend that any potential Pilot participant watch — or even re-watch — last week’s webinar (see online recording and slides). The slides have information that will help in preparing Form 84 Part 1. A summary of the key points is provided below.

• Access to the Pilot Program and its forms will be via a new section in EPC, much like the sections currently in EPC for E-rate and ECF.  The Pilot section will become available today (see USAC Newsletter discussed below).  The Form 484 Part 1 will not be available until the FCC announces the opening of the Form 484 Part 1 window this “fall.”  Basic information for existing E-rate applicants will be pre-populated into the Pilot section.
• Consultants will see the Pilot section in their EPC accounts but will not have access into their clients’ Pilot accounts unless proactively granted access by those clients.
• Once into the Pilot section, a user can start a Form 484 Part 1 by clicking the “waffle” in the upper righthand corner of the home screen (see red arrow).
  

• The Form 484 Part 1 itself will require:
  • A project summary is limited to 5,000 characters; longer summaries can be uploaded as an attachment.
  • Identification of services and equipment proposed to be purchased.
  • Description of how Pilot funding will be used to protect the network, again limited to 5,000 characters and/or an upload.
  • List of cybersecurity risks to be addressed.
  • Selection of primary area of focus.
  • Selection (from a list) of goals and objectives.
  • Yes/no questions focusing on best practices of national cybersecurity recommendations by CISA (Cybersecurity and Infrastructure Security Agency), NIST (National Institute of Standards and Technology), and the U.S. Department of Education.
  • Yes/no questions on cybersecurity expertise and other sources of funding.
  • Yes/no questions on cybersecurity incidents and implementation of best practices.
  • Yes/no questions on staffing and use of other free or low-cost cybersecurity resources.
  • Estimated costs and access to funding to cover non-discounted costs.*
  • Yes/no questions on metrics to evaluate Pilot Program outcomes.
• Based on a review of the Form 484 Part 1 submissions, the FCC will select a subset of applicants to move forward in the actual Pilot.  Unstated in the webinar, but implicit in the information requested in Form 484 Part 1, is that selection to continue further in the Pilot will depend critically on an applicant’s answers to the requirements listed above.
• As a separate objective for selection, the FCC indicated that it would seek to include “a diverse set of Pilot Program projects and to target Pilot Program funds to the populations 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.”  Diversity aside, it appears that only higher discount rate applicants are likely to be chosen.

One other point that was clarified during the Q&A sections of the webinar dealt with consortium applications.  As applicant information is carried over from the E-rate portion of EPC into the Pilot portion, all members of an E-rate consortium will be included with that consortium.  If an E‐rate consortium plans to file a Pilot application, not all the consortium members need to be included.  However, the Form 484 Part 1 must clarify which members are to be included and which members are not.  Alternatively, the participating members may create a new consortium and apply for a new consortium BEN.  Members of a Pilot consortium cannot also apply as individual Pilot applicants.