News of the Week

Wave 36 for FY 2014 will be released on Wednesday, January 14th. Funding for FY 2014 is available for Priority 1 services only. Priority 2 funding is being denied at all discount levels. Cumulative funding for FY 2014 is $2.11 billion.

Wave 79 for FY 2013 will be released Thursday, January 15th. Funding for FY 2013 is available for Priority 1 services only. Priority 2 funding is being denied at all discount levels. Cumulative funding for FY 2013 is $2.13 billion.

Wave 100 for FY 2012 will be released on Tuesday, January 13th. Funding for FY 2012 is available for Priority 2 funding requests at 90 percent and is being denied at 89 percent and below. Cumulative funding for FY 2012 is $2.87 billion.

The FCC Form 471 application filing window for FY 2015 will open at noon EST on Wednesday, January 14, 2015 and will close at 11:59 pm EDT on Thursday, March 26, 2015.

Last week, as a prelude to opening the window, USAC issued a Special Edition News Brief for January 8, 2015, announcing the availability of two Block 4 templates (one for schools and one for libraries). These templates can be prepopulated and then used to upload Block 4 data into online Form 471 applications. Detailed instructions for completing a template, and links to blank versions of the templates, are available on the FCC Form 471 Templates page of the USAC website. Particular attention must be paid to the order in which the template is completed and to the use of the Excel copy/paste function to draw data from other sources.

Applicants, who had already begun to collect and organize Block 4 data based on the “paper” version of the Form 471, in anticipation of easily converting this data into USAC’s templates, will find some formatting differences. The template, for example, combines Item 7a and Item 7b data into a single spreadsheet and reorders the columns. Also unexpected is the requirement to break the NCES number into three components for state, district, and school.

This week, roughly coincident with the window opening, we expect that USAC will make a training version of the new Form 471 system available online, and will provide Block 5 templates that can also be completed offline for ultimate upload into an online Form 471 application. We will be discussing the new online Form 471 system and associated templates in more detail in our next newsletter.

This year, more than any year in the past, we urge applicants to get an early start on filling in their online Form 471 applications. There are several reasons for this.

First and foremost, the new Form 471 is more complicated than in the past, requiring much more data. Most importantly, Item 21 information is no longer a separate attachment; it must be detailed within the application itself. Many applicants had been a bit cavalier about Item 21 attachments in the past, both as to format and to timely submission. Now the format is set. It requires both product and service detail, as well as entity-by-entity allocations. The level of Item 21 detail required for Category 2 applications, in particular, may require a much higher level of cooperation between applicants and their service providers.

Getting an early start on Form 471s also means that applicants, who have not already done so, should get their Form 470s posted for FY 2015. When USAC announced the Form 471 window dates, it also announced that the last possible date to file a valid Form 470 for FY 2015 is February 26, 2015. While technically correct — because a Form 470 must be posted for 28 days — it also means that any applicant waiting until February 26th to file its Form 470 would have to complete vendor selection, sign contracts, and file its Form 471 on March 26th, the last day of the window. This has never been a good idea in the past, and it’s an even worse idea this year.

USAC E-Rate Webinars:

USAC scheduled a series of six instructional webinars on E-rate topics over five weeks that began December 9th. The schedule is shown below. Registration is required to participate in the remaining live webinar and/or to view the recorded webinars.

The S&L News Brief for January 9, 2015 briefly notes the recently revised FCC guidance provided to USAC on the management of cash reserves, and USAC’s resulting calculation that $1.575 billion in previously committed, but unused, funds is currently available  (as of November 30, 2014) to carry forward — or “roll over” — into future funding years. A more detailed analysis of these funding developments is discussed in our newsletter of December 29, 2014.

The combination of the cash reserve change, plus the increased E-rate funding cap approved by the FCC last month, suggests that $5 billion or more should be available to fund Category 1 and Category 2 requests in FY 2015. An actual FCC decision on total funding availability for FY 2015 is not expected until later this spring following the release of USAC’s preliminary demand estimates for next year’s funding.