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February 19, 2018

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

FY 2018:

The FY 2018 Form 471 Application Window opened Thursday morning, January 11, 2018.  The Window will close Thursday, March 22, 2018 at 11:59 p.m. EDT.  PIA review is well underway for filed applications.

FY 2017:

Wave 39 for FY 2017 was released Thursday, February 8th, for a total of $8.85 million.  Wave 40 for special hurricane-relief applicants was released Friday, February 9th, for $937 thousand.  Cumulative national funding through Wave 40 is $2.17 billion.  Wave 41 is scheduled for Friday, February 16th.

Form 470 RFP Addendum Uploads:

Applicants attempting to upload additional RFP documents to posted Form 470s continue to report occasional error messages erroneously indicating that updates cannot be made “At This Time” because the “Form 470 is currently being edited by another user.”  This problem is more likely to occur when multiple documents are being uploaded into one Form 470.  

     E-rate Form 470 RFP Addendum Uploads

Callers to the Client Service Bureau (“CSB”) are being told that this is a known system issue and that they should wait 24 hours and try again.  With the short remaining Form 470 window for FY 2018, posting of RFP addendums is critical.  In our experience, the upload problems can sometimes be solved by:

  • Waiting a few hours (not necessarily 24 hours)
  • Logging out of EPC and logging back in
  • Pushing CSB to escalate the problem; there may be a manual IT fix

Upcoming 2018 E-Rate Dates:

February 22 Form 470 for use with a Form 471 application for FY 2018.  Whenever possible, Form 470s should be filed well before this date.  If a Form 470 is filed on this date, the 28-day posting requirement is not over until March 22nd.  On that day, an applicant using that last day Form 470 would have to select vendors, sign contracts, and complete the Form 471, all on the last day of the Application Window — never a good filing strategy!
February 26 FY 2017 Form 486 deadline for funding committed in Wave 22.  Other upcoming Form 486 deadlines include:

Wave 23         03/05/2018
Wave 24         03/12/2018
Wave 25         03/19/2018

Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” in EPC.  The Reminders will afford applicants with 15-day extensions to submit their Form 486s without penalty.

February 26 Extended invoice deadline for FY 2016 recurring service FRNs for which extensions were requested and granted of the original October 30, 2017, deadline.
March 22 FY 2018 Form 471 Application Window closes at 11:59 p.m. EDT

Charter SPIN Changes:

Charter Communications (a.k.a. Spectrum Enterprise) emailed letters to all its customers notifying them that Charter was consolidating all of its E-rate SPINs into one parent company SPIN effective January 9, 2018.  The key portion of the letter reads:

Today we are notifying you of an important change to the E-Rate Forms you file with the Universal Service Administrative Company (USAC) related to services provided by Charter Communications. For E-Rate Funding Year 2018, Charter Communications is consolidating multiple state-specific Service Provider Identification Numbers (SPINs) into a single SPIN, or 498 ID, issued to Charter Communications Operating, LLC (CCO), the parent company of Charter Fiberlink, Charter Advanced Services, Time Warner Cable Business and Bright House Networks. The new CCO SPIN is 143050436.

To identify Charter Communications as your provider of broadband Internet and/or telecommunication services eligible for discounts under the federal Schools & Library Program, you must change the SPIN, or 498 ID, to 143050436 as of January 9, 2018, when submitting Forms 471, 472, 474 and 486 to USAC. The new identifier will properly identify Charter Communications as your service provider and prevent delay in the processing of funding requests your organization has submitted to USAC. If you have already submitted paperwork with the former SPIN, we will be in touch with you to update your form.

We look forward to continuing to provide the solutions you rely on backed by the operational excellence you've come to expect. For more information about Spectrum Enterprise and our services and offerings, please visit enterprise.spectrum.com. For more information or questions concerning this notice, please contact DLGSPDept@charter.com.

Charter’s announcement has raised a series of questions that are still being addressed concerning how to best file for: (a) FY 2018 services under existing contracts, and (b) BEAR invoices for FY 2017.  Pending further clarification, our advice is as follows:

  • For new services as of FY 2018, file both the contract and the FRN under the new COO SPIN 143050436.
  • For ongoing FY 2018 services under an existing multi-year contract, continue to use the existing contract and the original SPIN.  If guidance to the contrary is received, the contract can be refiled under the new COO SPIN, and the RAL Correction can be made to update the SPIN in the FRN.  If the contract is refiled, we recommend giving it a contract name such as, “UPDATED for SPIN Change — Charter Original Contract is <Insert Original Contract ID>.”
  • For FY 2017 BEARs, unless and until Charter files a Service Provider Annual Certification (“SPAC”) for FY 2017 under the new COO SPIN — so far only FY 2018 is covered — do not request a SPIN change and then try to file BEARs under the new COO SPIN.

New Broadband Satellite Initiatives:

FCC Chairman Ajit Pai proposed to approve an application by Space Exploration Holdings (d.b.a. “SpaceX”) to provide satellite-based broadband service both nationwide and internationally.  This would be the fourth new satellite system that the FCC has approved to provide coverage, in part, over the United States.  The other three systems are from companies in Canada, Norway, and the United Kingdom.  All are designed to provide affordable broadband connectivity, particularly to those in more remote rural areas.

Unlike traditional geostationary satellites orbiting 22,000 miles above the equator, and effectively fixed in space, the new systems utilize a “constellation” of linked satellites (as many as 720) in non-geostationary orbits.  The new orbits, in some cases polar and much lower to earth, provide major advantages in terms of coverage in the higher latitudes and greatly reduced transmission delays.

 

USAC’s Schools and Libraries News Brief of February 16, 2018, provides reminders for applicants still filing Form 470s for FY 2018, namely:

  • Watch the step-by-step instructional videos on the Form 470 filing process in USAC’s Online Learning Library.
  • Wait the full 28 days.
  • Upload your RFP and associated RFP documents to your Form 470.
  • You may need to restart your 28-day clock.
  • You may need to certify a new Form 470.
  • You must include any disqualification reasons in your Form 470 and/or RFP.
  • Provide clear and complete information so that service providers can submit responsive bids.
  • Do not accept gifts from service providers.
  • Give the highest point value in your evaluation to the price of eligible products and services.
  • Note that if your state certified a Form 470, you may be able to purchase from a state master contract signed pursuant to that form.
  • You must retain your program documentation.