PY4 funding issues
The SLD released a preliminary demand figure to the FCC this week indicating that the total request for E-rate discounts next year (PY4) is approximately $5.5 billion. Although this figure is “interim,” it is unlikely that the final demand number will be less than the $4.7 billion requested for this year (PY3).
The SLD has not yet estimated demand by service categories. However, assuming that the FCC again authorizes funding at the $2.25 billion level, applicants at lower discount rates should not expect E-rate support for internal connections.
Total applications for PY4 rose to 37,500 including over 31,000 that were filed online. Approximately 8,000 Receipt Acknowledgement Letters (“RALs”) have already been issued for online applications. Others will follow, as certifications for online filings, and complete mailed-in applications, are data entered.
Applicants should review their RALs carefully and should correct any errors found by calling the SLD’s Client Service Bureau (888-203-8100) or by marking changes on the RALs and faxing them back to the SLD. Instructions on correcting RAL errors are contained in the letters themselves. Any applicant, that had been unable to obtain a specific supplier SPIN for a Block 5 request prior to filing, and that had been told to use “143666666” as a temporary SPIN, can use the RAL correction process to provide the proper SPIN.
Anecdotal information suggests that the SLD is rejecting a number of applications (mostly mailed, not filed online) that it believes do not meet its “Minimum Processing Requirements.” In some cases, these rejections can be triggered by relatively minor clerical errors. During the last PY3 application cycle, on the order of one thousand such applications were rejected, some of which are currently the subject of SLD or FCC appeals. It is possible, though not at all certain, that decisions on these appeals or other actions could change the rejection criteria retroactively – but only to applicants with pending appeals! If your PY4 Form 471 is summarily rejected, therefore, we strongly recommend that you file an appeal with the SLD. Please remember that an appeal must be received by the SLD within 30 days of the application’s rejection.
Verizon Wireless, previously called Bell Atlantic Mobile, began providing discounted E-rate billing last year, midway through PY2. Discounts are provided one month in arrears; discounts on eligible service charges in one month appear as a credit on the next month’s bill (in the Other Charges & Credits section).
In PY2, the SLD’s procedures permitted discounts on any given funding request (“FRN”) to be realized through supplier discounts and/or BEAR form reimbursements. This worked well for Verizon Wireless customers since discounted billing did begin until January 2000 (with credits first appearing on the February bills). BEARs had to be filed to realize discounts on services for July-December 1999.
New SLD procedures for PY3 permit either discount billing or BEARs on any FRN, but not both. Verizon customers, who are now receiving discounted bills, must carefully check to see if discounts have been correctly and fully applied. Applicants who received PY3 funding commitments, and/or filed Form 486s, late in PY3 must pay particular attention to determine if discounts were applied retroactively from July 2000. If not, there is no way to use BEARs to recapture the missing discounts.
We have been advised that Verizon’s billing system normally begins discounting service on an ongoing basis only after a Form 486 has been filed and processed. There is no automatic mechanism to credit accrued discounts since July. Requests for these discounts must be made on an applicant-by-applicant basis directly to Verizon Wireless. To do so, we suggest that customers contact Carl Barbera, Verizon’s E-rate coordinator (tel: 800-218-8161, x4575, or fax: 845-365-0905).