E-Rate Central News for the Week
November 18, 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 2014 application window is not scheduled to open until at least January 8, 2014, and to close “commensurate with past practice.” If, in fact, the window does open on January 8th, we would expect the window to close on or about March 18th (USAC has indicated that it hopes to announce the exact dates later this week). One critical timing issue for opening the window may be the approval and the online implementation of the revised Form 471. The release of the new Form 471 currently hinges on OMB approval, public comments for which are due November 25th.
Wave 27 for FY 2013 will be released on Wednesday, November 20, 2013, for $41.7 million. Funding is currently being provided for Priority 1 services only. Cumulative funding for FY 2013 will be $1.37 billion.
Wave 69 for FY 2012 will be released on Thursday, November 21, 2013, for $1.1 million. Priority 2 funding is being provided at 90%, and is being denied at 89% and below. Cumulative funding for FY 2012 will be $2.81 billion.
Wave 104 for FY 2011 will be released on Tuesday, November 19, 2013, for $19.8 million. Priority 2 funding is being provided at 88% and above, and is being denied at 87% and below. Cumulative funding for FY 2011 is $2.65 billion.
E-Rate Updates and Reminders
Form 486 Deadlines:
Typically, a Form 486 must be filed no later than 120 days from FCDL issuance or the start of service. Assuming services started July 1, 2013, the deadlines for early FY 2013 funding waves 1-9 have already passed (although USAC will be giving a grace period to late filers). The upcoming Form 486 deadlines for the remainder of the year are:
Wave 10 11/20/2013
Wave 11 11/27/2013
Wave 12 12/04/2013
Wave 13 12/12/2013
Wave 14 12/19/2013
Wave 15 12/26/2013
Periodically, USAC will send out Form 486 Urgent Reminder Letters to applicants it believes may have missed their Form 486 filing deadlines. These warning letters provide an additional 20-day period (from the date of the letters) to file the missing Form 486s. The first batch of reminder letters covering the early FY 2013 waves was issued last week.
Determining Mobile Broadband Speeds:
As drafted, the revised Form 471 to be used for FY 2014 includes a new Item 24 table which must be completed for every Block 5 funding request involving broadband or other connectivity services. For cellular data service the table requires both number of “lines” (i.e., users or devices) and “Download speed per line in Mbps.” Because cellular download speeds are not typically advertised and may vary by carrier and/or geographic area, questions are already arising regarding the requested information. When asked for guidance, USAC has suggested applicants ask their carriers.
Last week, the FCC announced a free speed test app for measuring mobile broadband performance, including download speeds, which should provide adequate user data for the FY 2014 application. Initially the app is available only for Android devices, but an iPhone version is expected to be ready by late January. A short slide presentation covering the new app is also available from the FCC.
Schools and Libraries News Brief Dated November 15 – Technology Planning
The SLD News Brief for November 15, 2013, reviews the requirement for approved technology plans. As of FY 2011, approved technology plans are required only for applicants applying for Priority 2 equipment and services. The News Brief discusses the following five points:
- The technology plan must be created before the Form 470 is filed.
- The technology plan must cover all 12 months of the funding year.
- The technology plan must contain all of the required elements.
- Goals and strategies
- Professional development
- Assessment of products and services needed
- Ongoing evaluation process
- The technology plan must be approved by a USAC-certified Technology Plan Approver.
- The technology plan should not cover more than three years.
Timing is a critical element of the technology plan process. This is not an issue for any applicant having a currently approved technology plan covering all of the upcoming FY 2014 year (and covering all of the Priority 2 services needed for FY 2014). But other Priority 2 applicants must pay particular attention to the creation and approval dates of their new or revised plans. Those plans must be created (i.e., at least drafted) before their Form 470s are filed for FY 2014; and those plans must be formally approved before services are received in FY 2014 (typically, at least for maintenance services, July 1, 2014). Documentation of a plan’s creation can be as simple as a dated e-mail with the attached draft; documentation of a plan’s approval requires a plan approval letter from the appropriate Technology Plan Approver (“TPA”).
Additional information on technology plan requirements, and suggestions for developing the four required plan components, can be found in E-Rate Central’s Tech Plan Primer.