Emergency Connectivity Fund (ECF)

Keep records that show you followed all ECF rules for at least 10 years from the last date of service or equipment delivery. For most districts, that means through at least mid-2034.

Your records should include:

• Device inventory: type, make and model, serial number, the full name of the person it was loaned to, and the loan and return dates (or the date it was reported lost or damaged)
• Service inventory: type of service, plan speeds and data cap, and who received it; for fixed service, the address and start and end dates
• Shared equipment and services: the responsible employee and dates in service
• How you determined unmet need, bids and contracts, invoices, and proof of payment

ECF recipients are subject to audits, inspections, and investigations. USAC, the FCC, the FCC’s Office of Inspector General (OIG), state education agencies, and other agencies with jurisdiction can request your records.

The FCC OIG has been reviewing ECF spending. Its December 2025 report, based on 98 site visits, found unopened and unused hotspots and computers, unused services, and excess equipment, and led to referrals to the Department of Justice, the FCC, and USAC.

Districts that spent $750,000 or more in federal funds in a year are also subject to the federal Single Audit Act.

If USAC finds that funds were used improperly, it can issue a commitment adjustment or a recovery of improperly disbursed funds. You have 30 days to appeal.

If a demand for payment goes unpaid for 30 days, the FCC’s “red light” rule applies: USAC holds or dismisses your applications and invoices, including E-Rate, and the debt can be sent to the Treasury with interest and fees.

Not answering USAC information requests or failing to provide proof of payment can also lead to recovery.

Yes. The FCC’s ECF order allows schools to use ECF equipment after the emergency period for whatever purposes the school considers appropriate, as long as the equipment is used for educational purposes.

ECF equipment cannot be sold, resold, or transferred for money or anything of value until it is at least three years old. After that it is considered obsolete and may be resold, transferred, donated, traded, or disposed of. Because all ECF purchases had to be made by June 30, 2024, all ECF equipment will be at least three years old by June 30, 2027. Check the purchase dates in your records before disposing of anything sooner.

Keep your inventory and purchase records even after devices are retired or disposed of; the 10-year retention period still applies. We recommend noting the disposal date and method in your inventory so your records show what happened to each device.

Your device inventory should already show the date each lost or damaged device was reported. Keep that documentation with the rest of your ECF records.