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December 18, 2017

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 (516-801-7814), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

USAC issued a Special Edition News Brief on December 14th announcing the FY 2018 Form 471 Application Window. The Window will:

  • Open Thursday, January 11, 2018 at 12:00 noon EST.
  • Close Thursday, March 22, 2018 at 11:59 p.m. EDT.

The other key date and time to note in this announcement is the day preceding the opening. As of Wednesday, January 10 at 11:59 p.m. EST, USAC will lock every applicant’s entity profile for the duration of the Filing Window. Any changes applicants need to make to their entity profiles — most importantly student enrollment and NSLP eligibility data — for the FY 2018 application cycle must be made before the profiles are locked.

Wave 29 for FY 2017 was released Thursday, December 14th, for a total of $42.8 million. Cumulative national funding through Wave 29 is $1.99 billion. Wave 30 is scheduled to be released on Friday, December 22nd.

FCC Criticism of USAC’s IT Systems:

FCC Chairman Pai sent a letter to USAC last week asking the USAC Board to “redouble its efforts” in the areas of information technology and security. Most specifically, the letter noted:

Recent events highlight oversight and management problems throughout USAC’s technology programs. These persistent challenges have caused delays that have impacted important FCC deadlines, including having a fully functioning E-Rate Productivity Center for the FY2017 funding year…Given the critical nature of USAC’s information systems to the proper function of USF, the inability of USAC to deliver secure and functional systems creates a significant risk to the success of USAC and the FCC.

To be fair, the letter might have mentioned the complicity of the FCC — under both Administrations — in causing EPC problems. The FCC not only directed USAC to expedite the implementation of EPC, without allowing a reasonable period for development, but it continued to push USAC to transition applicant forms into EPC in advance of the system’s corresponding ability to process those forms.

New USAC Guidance on Category 1 Form 470 Options:

USAC has posted, but not yet publicized, a Reference Table for FCC Form 470 Category One Drop-Downs. The table provides additional and long-awaited USAC guidance concerning which Form 470 menu options must be used (for Form 470s filed on or after August 26, 2017) when requesting various combinations of transport and Internet services. The table also notes which combinations of requested transport services affirmatively require uploaded RFP documents.

The descriptions of the requested combinations, shown in the column labeled “If you are seeking,” need to be read carefully. The parenthetical text in the descriptions is critically important. In particular, note:

  • The “Leased Lit Fiber” option includes both fiber transport and bundled Internet.
  • If there isn’t a preferred mode of transport, two menu options should be specified, “Internet Access and Transport Bundled” and “Leased Lit Fiber.”

Additional details on the Form 470 menu options for requesting Internet service, including suggestions for Narrative language, can be found in E-Rate Central’s December 11th newsletter.

USAC’s Schools and Libraries News Brief of December 15, 2017, provides the following Form 470 reminders:

  • The Form 470 must be filed online in EPC.
  • Some billed entity information must be completed in the applicant’s EPC profile before filing a program form.
  • Requests for Proposal (“RFPs”) and/or associated RFP documents must be uploaded to the Form 470. Remember that USAC uses a broad definition of an “RFP.”
  • The Form 470 must be certified online before it is posted to the USAC website.
  • A Form 470 receipt notification will appear in the applicant’s EPC News Feed shortly after the form is certified.
  • Service providers can view posted Form 470s either through EPC or with USAC’s Form 470 download tools.