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E-Rate Central News for the Week
March 7, 2016

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 (516-801-7814), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central website.

Funding Status

Wave 40 for FY 2015 will be released on Friday, March 11th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015 is $3.06 billion.

Wave 78 for FY 2014 will be released on Tuesday, March 8th. Funding for FY 2014 is available for Priority 1 services only. Priority 2 funding has been denied at all discount levels. Cumulative funding for FY 2014 is $2.28 billion.

Updates on USAC’s E-Rate Productivity Center

Keyboard Tip for Pulldown Menus:

The computer mouse is a wonderful device invented by Douglas Engelbart in 1964. EPC users, however, can quickly become mouse-weary moving repetitively from one field to another and clicking on all the pulldowns to manually enter data into applicant profiles. This process becomes particularly annoying when the same fields have to be completed again and again for multiple entries (e.g., entity connectivity or contract data).

The trick to reducing mouse use is to rely more heavily on the keyboard using the “Tab” key to move from field to field, and avoiding the pulldown lists by typing 1-2 letters of the required entry choices. Here’s an example of a connectivity profile completed this way (using the mouse only twice:
         E-Rate Connectivity Profile

Steps to complete:

  1. Use the mouse to select the “Download Speed” field
  2. Type “1”
  3. Tab to the “Upload Speed” field
  4. Type “1”
  5. Tab to the “Download Speed Units” field
  6. Type “g” — for “Gbps”
  7. Tab to the “Upload Speed Units” field
  8. Type “g”
  9. Tab to the “prominent connection type” question field
  10. Type “f” — for “Fiber”
  11. Tab to the “biggest barriers” question field
  12. Type “n” — for “No barriers”
  13. Tab to the “quality” question field
  14. Type “c” — for “Completely”
  15. Use the mouse to click the “Save Changes” button

How cool is that? Only fifteen steps (two mouse clicks and thirteen key strokes) to complete one connectivity profile.

For the connectivity profile, the keyboarding approach saves using the mouse to navigate to six additional fields and having to use the mouse to select the proper pulldown response in five fields. While not a significant time savings for an applicant with only a few entities, it makes the process a lot easier for larger school districts and library systems.

Similar tab/character sequences work on other fields within EPC. The trick is to become familiar with the pulldown choices, noting the first letter. If the pulldown list has two or more choices beginning with the same letter, an additional keystroke or two may be required. In the connectivity profile, for example, the pulldown list for “connection type” includes both “Copper” and “Cable Modem,” in that order. Typing just “c” (capitalization doesn’t matter) brings up “Copper.”  To get to “Cable Modem,” type “ca” or type “c” twice (to get to the next “c” in the list).

Training Site Available for Practice:

USAC has developed an EPC Training Site to give users the opportunity to practice use of the EPC system to update applicant data and to create and file forms (including Form 471s) without actually affecting the real site. Users can log into the test site as if they were actual users with full rights for independent schools and libraries, school districts, library systems, and consortia.

Use of the training site requires users to first obtain usernames and passwords by completing request forms on the USAC site, and then to set up their training profiles.

Note that updates are continually being made to the EPC system. These changes should flow through to the training site, but typically with a 1-2 day lag.

Pre-Certification NSLP Modifications:

Submitting a Form 471 for FY 2016 is not an independent activity within EPC. Before even creating a Form 471, an applicant must make sure that other aspects of its EPC profile, or profiles of related entities, are complete. This includes:

  • Updated student enrollment and NSLP eligibility data for all underlying schools. Libraries, library systems, and consortia must rely upon the associated schools or school districts to complete their entity profiles.
  • Connectivity data must be provided for all school districts, library systems, and their related schools and libraries. (Consortia are exempt from providing connectivity data for their member entities.)
  • Contract data related to any FRNs must be provided in the contract profile section.

This does not mean, however, that this data must be finalized before an applicant can begin drafting a Form 471. As long as preliminary data is available, a Form 471 can be created. The trick is to hold off submitting a Form 471 until all the associated data is up-to-date. In particular:

  • In setting up EPC, USAC carried forward most school enrollment and eligibility from the  FY 2015 applications. If that discount rate data is complete (including the necessary urban/rural designations), albeit out-of-date, work on related Form 471 drafts can continue. Requested discount rate data is not locked in until the Form 471 is actually submitted.

A consortium, library system, or library can begin working on its Form 471 before the associated school district(s) has updated its NSLP data for FY 2016. If the district(s) updates the data, the changes will supposedly flow through to any associated draft application(s).
Changes made after an associated application is filed may be updated in PIA and/or in a revised Funding Commitment Decision Letter.

  • Connectivity data for non-consortium applicants can — and should — be updated any time there are changes.
  • Contract data is not required for tariffed and month-to-month service FRNs. FRNs for contracted services must reference contract data previously entered in the applicant’s contract list, but contract data (and FRN links to that data) can be updated anytime during the Form 471 draft process. If an applicant has enough contract information to begin work on an associated FRN, but is awaiting final contract details, “dummy” contract information can be used on an interim basis.

Note: Several applicants have reported being told by CSB that all contracts must be uploaded into EPC. This is incorrect. Contract uploads are recommended by USAC as a way to speed PIA review, but are not currently required.

Current FRN Problem for Internet to a Hub Site:

Applicants applying for Internet into hub sites, then distributed over WANs to other sites (as is typically the case with school districts or library systems), are reporting a problem answering the following two questions.

FRN problem for Internet Hub Sites
Technically, the answer to both questions is “Yes.”  It is a direct connection to a single hub site, but it’s also a connection providing WAN access to other eligible sites.  Apparently, however, EPC expects answers of either “Yes” and “No,” or “No” and “Yes.”  This appears to be a bug in the system. Answering “Yes” to the second question leads to one line per entity in the Managed Recipients section of the FRN.

Currently, the only way around this problem is to answer “No” to both questions. As long as the Form 471 is in draft mode, this may be OK. But USAC would prefer applicants avoid the issue until the system can be fixed.

E-Rate Updates and Reminders

FY 2016 Application Window is Open:

The Form 471 application window for FY 2016 opened on February 3rd. The window is scheduled to close at 11:59 p.m. EDT on Friday, April 29, 2016. The entire application process for FY 2016 is being handled through USAC’s new EPC portal with its own learning curve. Please do not wait until later in the window to file Form 470s, update pre-471 EPC applicant profile information (entity, student, connectivity, and contract data), and begin the Form 471.

USAC EPC Webinars:

The last of USAC’s series of webinars on the EPC Form 471 filing process will be conducted this week, first on Tuesday and again on Thursday. Registration is available now on the Trainings & Outreach page of the USAC website. Earlier webinars have been recorded and are available in USAC’s Online Learning Library.

  • How to Understand and Complete the Certifications Section, and Complete FCC Form 471: March 8th and March 10th at 1:00 p.m. EST

File Along with Me Updates:

A USAC blog, “File Along with Me,” initiated in early February, provides additional information on the application process. Links to last week’s postings are provided below. You can subscribe to the blog by entering your e-mail address on the blog’s home page (under the USAC logo), and confirming the resulting email.

Post No.   Title

  1.         Decide on Services and Post for Bids
  2.         Starting Your FCC Form 470: Accurate Basic Info Is Essential
  3.         Finishing Up FCC Form 470: Leave Time To Certify!

FCC Decision Watch:

The FCC issued its latest monthly set of “streamlined,” precedent-based decisions in Public Notice DA 16-220, including:

  1. Granted:
    1. Two requests for review granting the applicants additional time to respond to USAC’s requests for information.
    2. One request for review granting an applicant the opportunity to provide USCA with supporting evidence of their rural designation.
    3. Two requests for reviews and/or waiver reversing USAC decisions reclassifying services as ineligible.
    4. Three requests for reviews and/or waiver approving Form 471 corrections of ministerial and/or clerical errors.
    5. One request for review and/or waiver giving an applicant a chance to reduce a funding request to a level supported by their necessary resources.
    6. One request for review (although it was actually a waiver), extending an applicant’s service implementation deadline following a late-filed service substitution request.
    7. One request for waiver of the 60-day USAC appeal deadline for a filing that “was only a few days late.”
    8. One request for review or waiver of the competitive bidding requirement to comply with state or local procurement rules requiring publication of an RFP in a newspaper of general circulation. In this case, the FCC found that the applicant had “published the RFP on its website and received sufficient bid responses, and there was no evidence of waste, fraud, and abuse.”
    9. One request for review and/or waiver of the requirement to make price the most important factor in the bid assessment process. In this case, the FCC found that the applicant had, in fact, “selected the lowest priced option.”
  2. Dismissed:
    1. Six requests for reviews that should have first been appealed to USAC.
    2. Four requests for reviews or waivers, dismissed without prejudice, which did not meet the basic requirements of the FCC rules. All four failed to cite the associated application numbers.
    3. Two requests for reviews or waivers, deemed moot, related to funding requests that had already been approved by USAC.
    4. Three petitions for reconsideration, including one late filed petition. Note that although the normal appeal window is 60 days, petitions for reconsideration must be filed within 30 days.
    5. Four requests for reviews or waivers for Form 470s filed lacking adequate specificity and/or without indicating that an RFP was available.
    6. One request for review or waiver related to ineligible services invoiced by a service provider. Because the applicant had not been involved in the review of invoices, the FCC held that recovery should proceed against the service provider. Note that any ultimate settlement between the service provider and the applicant regarding the repayment of discounts on ineligible services is beyond the purview of USAC and the FCC.
    7. Six requests for reviews or waivers regarding Form 471 corrections of ministerial and/or clerical errors.
    8. Ten requests for reviews or waivers not filed within the 60-day appeal window.
    9. One request for review of a violation of the 28-day bidding rule.

Form 486 Deadlines for March:

The Form 486 deadline for certifying the start of service (and CIPA compliance, if applicable) is 120 days from the later of the FCDL approval date or the start of service date. The remaining March deadlines (adjusted for weekends and holidays) for approved FY 2015 applications are:
                                          Wave 25                03/15/2016
                                          Wave 26                03/21/2016
                                          Wave 27                03/29/2016

School District CPN Waiver Request:

Note: This article is not related to E-rate, but does concern an FCC telecommunications matter on which schools and school districts may wish to comment. Comments are due next Wednesday, March 16th.

On February 18, 2016, the Enlarged City School District of Middletown (NY) filed a petition for a limited waiver of the FCC’s rules, which prohibit terminating carriers from passing the calling party number (CPN) to the called party where a privacy indicator has been triggered by the caller. Middletown asserts that the prohibition on transmission of the CPN hinders a rapid response by security personnel and local law enforcement to threatening calls made to the schools in its district.

Middletown reported that it had received twelve “active shooter and bomb threats” so far this year from callers. The calls, not easily tracked because of the CPN restrictions, triggered lock-down procedures at its schools.

Middletown’s limited waiver request includes a number of measures designed to protect the privacy rights of most callers, as is the intent of the CPN restriction, while enabling the district to identify a threatening caller to protect students, faculty, and staff. Middletown notes that a similar waiver was granted to the Liberty Public School District of Kansas City in 2013.

In requesting comments of this waiver request (DA 16-234), the FCC appears to be considering a modification of the CPN restrictions to more broadly address, with protections, the ability of other schools, school districts, and law enforcement agencies to deal with similar threatening calls. E-Rate Central encourages other educational agencies to support such changes.

Schools and Libraries News Brief Dated March 4 – Common EPC Questions, Part 3

The S&L News Brief of March 4, 2016, continues a series of EPC Q&As begun two weeks ago. The new questions are:

  1. How do I get a user account in EPC? Short answer: Call CSB.
  2. My account administrator created a user account for me, but my attempts to reset my password have been unsuccessful. What should I do? Short answer: Make sure that your email address is correct.
  3. I have my student counts but I am afraid to enter them in my profile because I won't be able to edit them after I have started my FCC Form 471. What should I do? Short answer: Entity information can be edited at any time.
  4. I am a library system. I get an error message in the discount calculation section of my FCC Form 471. What can I do? Short answer: Contact your public school district.
  5. I am a service provider. I printed a copy of the Service Provider Annual Certification (SPAC) Form 473 and submitted it for FY 2016. Why isn't it showing up on the SPIN Search Tool? Short answer: Temporarily, USAC cannot enter paper Form 473s.
  6. I do not understand the concept of an annex. How and why should I set up annexes in my school or library profile? Short answer: None — please read this section.
Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.