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November 5, 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.

Hurricane Sandy

E-Rate Central's main New York office, including its phones and servers, were out of operation since last Monday, and are just now being restored.  As a result, this week's newsletter is somewhat abbreviated.  E-Rate Central's funding search tools may also be a little out of date until later this week.  We apologize for the inconvenience and thank all for their concern and patience.  We are happy to report that the entire staff is safe and sound, albeit still with power outages and gas shortages in New York and Pennsylvania.

Funding Status

Wave 68 for FY 2011 will be released on Wednesday, November 7, 2012, for $4.3 million.  Priority 2 requests are being funded at 88% and above, and denied at 87% and below.  Cumulative funding for FY 2011 is $2.44 billion.

No funding waves for FY 2012 or FY 2010 are scheduled this week.

E-Rate Updates and Reminders

October/November Deadlines Deferred:

As a result of the devastation in the northeast wrought by Hurricane Sandy, the SLD has extended the FY 2011 recurring service invoice deadline, previously set to expire on Monday, October 29, 2012 to January 28, 2013.  The January 28th date corresponds to the regular invoice deadline for FY 2011 non-recurring services.

The SLD's announcement also noted that Form 486 deadlines occurring prior to January 28th, including the normal Form 486 deadlines for FY 2012 waves 1-12, would also be extended until January 28th.

Additionally, we have been assured by the SLD that additional time will be given for PIA responses due from schools and libraries closed due to storm-related difficulties.  To be safe, affected applicants should check with their PIA representatives if PIA inquiries are outstanding.

Schools and Libraries News Brief Dated November 2 – SPIN Change Reminders

The SLD News Brief for November 2, 2012, highlights the difference between "Corrective" and "Operational" SPIN changes.  The distinction depends upon whether an applicant is actually changing service providers.  If the service provider is not being changed, a SPIN may be "corrected" to: (a) fix a data entry error; (b) account for a merger or acquisition; or (c) properly align a funding request with another of a service provider's multiple SPINs.  If, on the other hand, an applicant is actually changing service providers, then an "operational" change is required.

The difference between the two types of SPIN changes is important because the procedural requirements are significantly different.  Corrective SPIN Changes are easy and generally approved by the SLD with little question.  As of FY 2011, however, two additional strict requirements have been implemented for the approval of Operational SPIN Changes.  In particular:

  • The applicant must have a legitimate reason to change service providers, such as breach of contract or the service provider is unable to perform; and
  • The newly selected service provider must have received the next highest point value in the original bid evaluation, assuming there was more than one bidder.

Last week's News Brief discusses these new requirements in more depth and indicates the documentation necessary to support a change request.

The News Brief also clarifies that the new Operational SPIN Change requirements do not apply in a situation when an applicant is transitioning from one service provider to another over a funding year boundary and there is a delay before the new service provider can start providing service.  In this case, the applicant can request that the Funding Request Number (FRN) for the new funding year be split in order to continue service with the original service provider until the new service provider is able to provide service.