E-Rate Central News for the Week
April 22, 2013
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 Web site.
The FY 2013 Form 471 application filing window closed March 14, 2013. USAC's preliminary estimate of FY 2013 demand should be released later this month.
Wave 40 for FY 2012 will be released on Tuesday, April 23, 2013, for $22.6 million. Priority 2 funding is being provided at 90%, and is being denied at 89% and below. Cumulative funding for FY 2012 will be $2.12 billion.
Wave 89 for FY 2011 will be released on Wednesday, April 24, 2013, for $6.9 million. Priority 2 requests are being funded at 88% and above, and denied at 87% and below. Cumulative funding for FY 2011 will be $2.56 billion.
E-Rate Updates and Reminders
FCC Director of Digital Learning:
Departing FCC Chairman Julius Genachowski appointed Michael Steffen as the Director of Digital Learning. This is a new position charged with leading "the FCC's work within the agency and across government, public, and private partners to modernize broadband infrastructure in U.S. schools and libraries and expand access to the opportunities of digital technologies for America's teachers, students, and parents." In one sense, this appointment may be seen as an effort to extend Chairman Genachowski's education legacy at the FCC beyond his retirement.
The actual date of Chairman Genachowski's retirement is still being projected as being in the "coming weeks." A report in last week's Washington Post indicates that Mr. Genachowski will join the Aspen Institute and that the new frontrunner for the Chairmanship is Tom Wheeler. Mr. Wheeler is a venture capitalist who worked with President Obama on telecom policy issues during the 2008 campaign and transition.
FCC Appeal Decisions Watch:
The FCC released one decision last week (DA 13-238) granting requests for review or petitions for reconsideration for 27 applicants and denying those for five others for late-filed FY 2011 and FY 2012 applications, certifications, or Item 21 attachments. The approvals were based on applications that the FCC found: (a) had actually been filed within the window; (b) were filed within 14 days of the close of the window (an extended deadline that the FCC has historically provided upon appeal); or (c) were filed later under "special circumstances" justifying a waiver.
Schools and Libraries News Brief Dated April 19 – Certification/Attachment Deadlines
Consistent with past practices, and as discussed in the SLD News Brief for April 19, 2013, USAC will issue two sets of letters this week extending the deadlines for submitting missing FY 2013 Form 471 certifications and Item 21 attachments.
Approximately 930 Notification of FCC Form 471 With No Certification letters will be sent to applicants who filed their applications online, on or before the March 14th window deadline, but who have not yet filed their signed certifications. These applicants will have until May 15th to complete and submit these certifications (either online or on paper). Applications not certified by this time will be considered out-of-window and will be denied.
Approximately 3,980 Item 21 Attachment Urgent Reminder Letters will be sent to those applicants who have not yet filed their Item 21 attachments for one or more FRNs on their FY 2013 applications. These applicants will also have until May 15th to submit their attachments.
This year's reminder letters are less numerous than last. For FY 2012, USAC had sent roughly 990 certification reminders and almost 7,600 attachment reminders. We suspect that the drop in attachment reminders is a function of both heightened application awareness of the deadline and improvements in the SLD's ability to match online Form 471s with separately filed Item 21 attachments.
Our recommendation for any applicant receiving one or both of these reminders, who believes that the certification or attachments have already been submitted, is as follows:
- For a reportedly missing Form 471 certification, contact the SLD's Client Service Bureau (888-203-8100) or Submit a Question online to confirm that the certification is still deemed missing. Document and retain all responses. If the applicant submitted more than one application, make sure that the documentation references the specific application in question. Simply submitting a duplicate certification is an option, but may ultimately require the applicant to file a separate request to cancel the duplicate.
- If any Item 21 attachments filed online are reported missing, the applicant should go back online to make sure that the process was completed. Note that online attachments are not considered to have been filed until the applicant clicks the Submit button on the last Item 21 attachment page.
- For separately filed, but reportedly missing, Item 21 attachments, the applicant should again confirm that the attachments are still missing by calling or electronically contacting the SLD. E-mail confirmations from the SLD indicating that the attachments have been received have historically not included Form 471 and/or FRN identification numbers and are, therefore, of doubtful value for documentation purposes. There appears to be no downside in resubmitting, and carefully documenting, reportedly missing Item 21 attachments.