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September 10, 2012

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.

Funding Status

Wave 10 for FY 2012 will be released on Tuesday, September 11, 2012, for $27.8 million.  Priority 2 funding is being provided at 90%, and is being denied at 89% and below.  Cumulative funding for FY 2012 is $1.1 billion.

Wave 60 for FY 2011 will be released on Wednesday, September 12, 2012.  Priority 2 requests are being funded at 88% and above, and denied at 87% and below.  Cumulative funding for FY 2011 is $2.35 billion.

No funding wave for FY 2010 is scheduled for release this week.  Within the next month or two, we would expect USAC to announce the end of regular waves for FY 2010.  Once this occurs, USAC will send status letters to applicants who are still awaiting decisions and who have not been in recent contact with USAC.  As shown in the table below comparing FY 2010 with the preceding five funding years, there have now been more regular funding waves for FY 2010 than in earlier years. The length of time since the end of the funding year, however, has not quite reached the almost 16-month point experienced in FY 2009.

Last Regular Funding Wave History
 
 
Funding Year       Last Regular Wave  
FY End Date   Wave Date No. Days from End  
2010  6/30/2011   Current 100 438 as of 9/10/2012
2009 6/30/2010   10/17/2011 95 474  
2008 6/30/2009   02/24/2010 80 239  
2007 6/30/2008   05/14/2009 80 318  
2006 6/30/2007   08/01/2007 60 32  
2005 6/30/2006   01/17/2007 66 201  

E-Rate Updates and Reminders

Non-Recurring Service Delivery Deadline:

The nominal deadline for receiving non-recurring (e.g., installation) services for FY 2011 is September 30, 2012.  The deadline was established to provide applicants with an additional three months, after the normal June 30th end of the funding year, to complete projects during the summer.  Several important points should be noted:

  1. USAC will not pay invoices associated with work performed after the service delivery deadline.
  2. A non-recurring service delivery deadline may be automatically extended by a year if the associated FRN is funded or modified (e.g., by a SPIN change or service substitution) after March 1st of a funding year.  This means that the service delivery deadline for a FY 2011 non-recurring service may be September 30, 2013.  But it also means that the deadline for a FY 2010 (or earlier) service, may be September 30th of this year.
  3. A non-recurring service delivery deadline, which is not automatically extended, may be extended upon request if the applicant can show that the project was delayed as the result of circumstances beyond its control.  A request to extend a service delivery deadline, however, must be filed on or before the date of the current deadline.
  4. One way to check if a service delivery deadline has been extended is to search by funding year and FRN in the SLD's Display FRN Extensions database.  If the FRN deadline has been extended, it will be listed with both the new service delivery deadline and the new invoicing deadline.  If the FRN is not listed, no extension has been granted.
  5. Often, when a service delivery deadline is extended, it will be necessary to formally extend the associated contract, and to the notify USAC of the contract extension by filing a Form 500.

FCC Comment Deadlines:

Comments on the SECA petition seeking clarification on "free" bundled end-user equipment (see DA 12-1325) are due today, September 10th; reply comments are due September 24th.  E-Rate Central's comments, submitted last week, supported SECA's requests to clarify — and limit — the conditions under which "free" equipment or services could be bundled with eligible products and services without requiring cost allocation.  Funds for Learning's comments, also submitted last week, took a contrary position, arguing that the FCC's current guidance was sufficient to prevent misuse of E-rate funding.

What is it with Minneapolis?

For several weeks running, the SLD has been announcing that registration is still open for its fall training session in Minneapolis on October 30th.  Registration for the other seven regional training sessions has been either closed or available only on a waiting list basis for some time.  As a public service, for those worried about weather conditions, we note that the average historic temperature range on October 30th in Minneapolis is 46°-65° Fahrenheit — hardly a serious deterrent for those seeking quality E-rate training.

Schools and Libraries News Brief Dated September 7 – End of Summer Deferment

The SLD News Brief for September 7, 2012, reminded applicants that the summer contact deferral period ended Friday, September 7th.  If USAC had not been able to contact an applicant over the summer, action on that applicant's Form 471 application(s) was placed on hold.  Held applications will now be placed back in the queue for review.  Failure to respond to inquiries may mean that funding requests will be reduced or denied.