E-Rate Central News for the Week
December 2, 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 SLD announced that the FY 2014 application window will open Thursday, January 9, 2014, at noon EST, and will close on Wednesday, March 26, 2014 at 11:59 p.m. EDT. We assume that this window period anticipates the approval and online implementation of the revised Form 471 (see article below).
Wave 29 for FY 2013 will be released on Friday, December 6, 2013, for $47.8 million. Funding is currently being provided for Priority 1 services only. Cumulative funding for FY 2013 will be $1.48 billion.
Wave 70 for FY 2012 will be released on Monday, December 2, 2013, for $1.05 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 105 for FY 2011 will also be released on Monday, December 2, 2013, for $453 thousand. Priority 2 funding is being provided at 88%, and is being denied at 87% and below. Cumulative funding for FY 2011 is $2.65 billion.
Additionally, USAC is cleaning up a limited number of older pending applications this week (and last), issuing funding totaling over $84 million for funding years 2007–2010. Almost all of this funding is for one large urban school district.
Form 471 Data Issues for FY 2014
The revised version of the Form 471, which is expected to be approved in time for use during the FY 2014 application window, requires applicants to provide substantially more information on the type, number, and speeds of their broadband connections. The revised Form 471 will do away with the current Block 2 “Impact of Services Offered” table, which requested aggregate data on students served, classrooms connected, numbers of computers, and number of lines at various speeds. Instead, the new Form 471 will require the completion of a more detailed data circuit table for each FRN involving broadband Telecommunications and/or Internet Access services (including cellular data). A copy of the new data table (Item 24) is included as an attachment to this newsletter.
Applicants, particularly those tending to file their Form 471s on the last day or two of the application window, are encouraged to review the new data collection requirements earlier. Accurate completion of the table for each FRN may require applicants to obtain line speed data from their carriers and to conduct classroom coverage surveys. The collection of coverage data for consortium applications, in particular, may require time-consuming member surveys.
The revision of the Form 471 was part of a broader series of form revisions begun earlier this year involving all applicant E-rate forms. The FCC first released proposed revisions to both the Form 470 and the Form 471 for public comment (DA 13-1590) on July 17th. As a result of these comments, several changes were made to the proposed revisions and were discussed during the SLD’s fall training sessions.
In what will likely be the final stage of the revision process, the proposed revision of the Form 471 was submitted to OMB for approval. OMB, in turn, released the new Draft Form 471 for final public comment (2013-24951). Comments were due last week on November 25th.
Normally, the OMB public comment period for these types of forms is a non-event. But this year, comments on the proposed Form 471 were filed by the State E-Rate Coordinators’ Alliance (SECA”). In large part, SECA’s comments were driven by the apparent unavailability of an accompanying draft of the Form 471 Instructions, and by a number of unanswered questions on completing the new data table raised by the E-rate applicant community. SECA’s comments raised the following questions:
- Do state network and/or other consortium applicants have to complete 24.a and 25.b, or just 24.c?
- If the answer to question 1 is yes, then for state network consortium applicants, if the state network provides connectivity that is a wired/landline circuit but the building into which the circuit is delivered has wireless Internet access, should 24.b.1 only be answered or should 24.b.2 also be answered?
- For state network consortium applicants that provide last mile connectivity, must the consortium lead request the percentage of wired and wireless classrooms that each consortium member has in order to report this information?
- In Item 24.c, how is last mile connectivity defined? For example, if there is a regional wide area network where the connection goes to the District's head-end, does that constitute a last mile to the school? Or is this a literal question asking if the connection goes to individual school buildings? Does this answer change if the District's head-end is a school building?
- For FRNs that contain charges for mobile Internet access such as air card service, how should the percentage of classrooms with wireless broadband connectivity be computed?
In filing these comments, SECA stressed “that in no way do we want the review and approval of these forms to be delayed,” and that it was important that the Form 471 be approved in time for USAC to make the required changes to its online system prior to the opening of the FY 2014 application window on January 9th. SECA indicated that its only interest was in seeking “clarifications to the instructions associated with Items 24.a, 24.b, and 24.c.”
Additionally, expressing concern that it may already be too late to educate applicants on the new data collection process, SECA suggested that completion of the Item 24 data table “be made optional in the first year of the rollout of the new form for E-rate FY 2014 applications.”
The questions being raised on the new broadband data collection requirements only serve to highlight our recommendation that applicants not wait until the waning days of the FY 2014 application window to review the revised Form 471.
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 1-11 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 12 12/04/2013
Wave 13 12/12/2013
Wave 14 12/19/2013
Wave 15 12/26/2013
Applicants missing these deadlines will receive Form 486 Urgent Reminder Letters giving them an additional 20 days to file. The initial batch of warning letters was mailed two weeks ago carrying a final deadline of December 11th.
SLD News Brief:
No SLD News Brief was published last Friday for the Thanksgiving week.
Revised Form 471 Data Collection Table
To be completed for every broadband Telecommunications or Internet Access funding request (“FRN”).