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Funding Commitment Decision Letters

Introduction:

Funding Commitment Decisions Letters ("FCDLs") are sent to each applicant that has submitted a valid Form 471. The letters notify the applicant of the funding decisions that have been made with regard to each individual Funding Request Number ("FRN") or item.

For most applicants, FCDLs summarize the E-rate funds that have been committed and set aside for discounts that had been requested on eligible services. The FCDL lists a separate decision for each request made in the associated Form 471. In some unfortunate cases, a letter indicates rejections of requested discounts on services deemed ineligible or on lower priority services for which program funding is not available.

All decisions that are listed in a FCDL need to be carefully and quickly reviewed in preparation of taking one or more of the following actions:

  • File a FCC Form 486. In most cases, and when possible, a Form 486 should be filed shortly after receiving a FCDL (see Form 486 Preparation Tips).
  • Correct apparent errors (such as an incorrect supplier identification) in funding decisions and/or in the underlying Form 471
  • Appeal an SLD funding decision
  • File a FCC Form 500 to change a start or contract expiration date, or to cancel or reduce a FRN (see Form 500 Preparation Tips).

Inquiries, corrections and appeals must be made in writing to the SLD within 60 days of the date of issuance of the FCD letter.

[Note: Appeals denied by the SLD can be appealed again to the FCC]

Review Items in FCDLs:

Important Warning: The most serious problem found by E-Rate Central in its review of FCDLs is that a decision was not included for every single request on the associated Form 471. Whether the requested item was funded or denied, there should be a one-to-one correspondence between the applicant's requested items and the SLD decisions. If there is a mismatch, there is an error.

This table illustrates the key information included in a FCDL (covering a single decision for a funded discount):

Funding Request Number: ########## .

Funding Status: Funded .

SPIN: 1430##### .

Service Provider Name: Acme Telephone .

Services Ordered: Telecommunications Services .

Earliest Possible Effective Date of Discount: 07/01/2013 .

Contract Expiration Date: 06/30/2014 .

Site Identifier: #######.

Billing Account Number: ### ###-####.

Pre-discount Amount: $ 2,000 .

Discount Percentage Approved by SLD: 40% .

Funding Commitment Decision: $ 800.00 - 471 Approved as submitted.

Almost every line of this decision is important; most need to be carefully compared with the related line item data on the original Form 471.

Based on E-Rate Central's experience with FCD reviews, here are a few key points:

  • The Funding Request Number ("FRN") is a unique identifier assigned by the SLD to each requested line item on a Form 471. Henceforth, all references to this funding item - by applicants, vendors, or the SLD - should be by FRN
  • If the Funding Status is not shown as "Funded," the applicant should understand why. Often, for internal connections, it will be because total E-rate program funding has been exhausted and the applicant has a low discount rate. The decision should include brief language substantiating the lack of funding. Questions or appeals to an SLD funding decision must be made in writing
  • The SPIN (Service Provider Identification Number) is critical for funded items because the applicant will be getting its discount from that vendor. Discrepancies in SPINs can occur because the applicant listed the wrong number on the Form 471, because digits were transposed by the SLD during data entry, or because the vendor has changed its SPIN (see below)
  • The services ordered should be correctly categorized as telecommunications, Internet access, or internal connections. The category is particularly important with regard to discount rate selection and contract extensions
  • The Effective Date of Discount should be no earlier than the start of the program year (07/01/yyyy)
  • The Contract Expiration Date should be as initially listed on the Form 471
  • The Estimated Total Annual Pre-discount Cost should reflect that which is initially listed on the Form 471 unless changed by the SLD during the Problem Resolution or Program Integrity Assurance phases of the review process (and hopefully discussed with the applicant)
  • Discount Percentage Approved by the SLD should be the aggregate rate for all shared services, and the individual rate for all site-specific service
  • The Funding Commitment Decision amount should equal the pre-discounted amount times the discount percentage. It is the maximum of discount that an applicant can expect to receive via reimbursement and/or ongoing discounts