News of the Week

Wave 13 for FY 2015 will be released on Friday, August 21st. Funding for FY 2015 is available for both Category 1 and Category 2 at all discount levels. Cumulative funding for FY 2015 as of Wave 12 is $1.17 billion.

A few weeks ago in the Special Edition News Brief of July 21, 2015, USAC announced that it would soon undertake an effort to verify Category 1 data on FY 2015 Form 471s. That process began last week. The “clean up” is supposed to be conducted independent of the PIA process, but is likely to be related in some way to applications for which there are apparent discrepancies between the services as described and the bandwidth and/or prices of those services. Applicants who have already been funded may receive questions as well.

Service questions are being sent in emails with the subject line “Additional Clarification for FCC Form 471 Application Number NNNNNNN.”  The introductory text states:

Please provide some additional information about your Schools and Libraries (E-rate) Program application by answering the questions below. This will help us better understand the services you requested.

We will use your responses to verify the broadband connectivity information on your Funding Year 2015 application for [applicant name], and verify that the application correctly identifies the services you requested.

Please reply and put your answers in the body of the email. Please send answers by [5 days hence].

The emails include reported service data and related questions on one or more FRNs. Here are two examples:

FRN # NNNNNNN

For Line Item Number 1

Clarify the use of the service(s) requested in this line item: (Select One)

A: Internet access service that includes a connection from any applicant site directly to the Internet service provider (recorded as Purpose = Internet, WAN = No)

B: Data connection(s) between two or more sites entirely within an applicant’s network (recorded as Purpose = Transport, WAN = Yes)

C: Data connection(s) from an applicant’s hub site to an Internet service provider or state/regional network where Internet access service is billed separately (recorded as Purpose = Transport, WAN = No)

D: Internet access service with no circuit. (a data circuit to the ISP or state/regional network is billed separately). (recorded as Purpose = Internet, Service Type = IA Only (no circuit))

FRN #NNNNNNN

For Line Item Number 1

You selected Ethernet as the connection type. Can you specify the connection type in more detail? For example, if the Ethernet service is delivered over fiber, please select Lit Fiber Service (including Metro Ethernet products provided over fiber). If your service is an Ethernet over Copper service, please let us know that as well. If you chose Ethernet by mistake and the service is based on another technology (e.g. OC-n fiber, Cable Modem, or DSL), please just let us know the corrected service type.

If you are unsure of the service type, it may help to refer to your service provider’s bill or to contact your service provider to assist you.

• Connection Type: ____________________________________

Several points should be noted regarding this “clean up” process and the related questions, namely:

1. The purpose is to provide USAC and the FCC with the best possible data on what services are being used (or requested) by applicants and at what costs. One advantage to individual applicants for getting this data correct is that it should simplify the completion of future forms. For assistance in answering service-related questions:
   1. The emails indicate only that “You can refer to the FY 2015 Eligible Services List for definitions of the services requested.”  However, this will not always be sufficient.
   2. As an alternative, it may be worth having discussions with the associated USAC reviewers. The emails are all being sent by specific individuals, each providing direct telephone numbers.
2. It is not immediately clear why particular cells in the examples above (and in others we have seen) are color shaded. Presumably, the shaded cells are linked to system flags that generated the questions. In these two examples, we would note:
   1. For example #1, the cable modem service, the most likely answer is “A.”
   2. For example #2, the Internet only service, the underlying transport circuit necessary to support a download speed of 5 Gbps is almost certainly fiber.
3. Not all applicants will receive clarification questions, but questions that are sent may reference applications still under review or applications already approved. In the former case, USAC has indicated that, since the “clean up” is a separate process, the “effort will have no effect on the pace of funding decisions.”  In the latter case, USAC has indicated that changes may lead to a revised FCDL, but that there will be “NO IMPACT on the level of funding approved by USAC.”  Our fingers are crossed.

USAC Fall Applicant Training:

As in recent years, USAC will hold eight regional one-day applicant training sessions this fall. Registration at this point is assured at only three of the locations. The full training schedule with registration links is as follows:

The S&L News Brief of August 14, 2015, is the third in a series of News Briefs discussing the basic process of filing a Form 470 for FY 2016. Part 1 discussed setting up an EPC account and beginning a Form 470. Part 2 covered requests for Category 1 services.

The critical point to note is that a Form 470 for FY 2016 can be filed only through USAC’s new E-Rate Productivity Center (“EPC”). To do so, an applicant must have an established EPC portal account.

Last Friday’s News Brief covers the following key steps involved in requesting Category 2 services:

1. If a Form 470 has already been started (see the S&L News Brief of July 31, 2015), log into your EPC account and access your partly completed form.
2. Choose your category of service. Note that, unlike a Form 471, a single Form 470 can be used for both Category 1 and Category 2 services.
3. If you are issuing an RFP, complete the first “RFPs for Service Requests” page. Note that any RFP(s) must be uploaded to the portal before you can submit the associated Form 470. You must also complete the second “RFPs for Service Requests” page to indicate whether the RFP(s) apply to all, or just a subset, of Category 1 requests.
4. Complete one or more “Service Requests: Category Two” pages for services requested. Note that there are three different types of Category 2 services, and that considerably greater detail on equipment and services is required in the FY 2016 EPC version of the Form 470. The following is a real example of a set of Category 2 requests for Internal Connections, including Narrative comments: