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E-Rate Central News for the Week
April 11, 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 45 for FY 2015 will be released on Thursday, April 14th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015 is $3.21 billion.

Wave 79 for FY 2014 will be released on Wednesday, April 13th. 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

New FRN Bulk Upload Templates:

USAC’s Special Edition News Brief of April 5, 2016, announced the long-awaited availability of bulk upload templates for FRN line items and recipients of service. There are separate and distinct templates for each of the following five service types:

  • Category One - Voice Services
  • Category One - Data Transmission and/or Internet Access
  • Category Two - Internal Connections
  • Category Two - Managed Internal Broadband Services (MIBS)
  • Category Two - Basic Maintenance of Internal Connections

The following three points should be noted:

  1. Templates are to be used on a line-by-line FRN basis. A user must first create a specific FRN before uploading a completed template (see illustrations below).
  2. Use of the templates is optional. As discussed in the following section, FRNs may still be entered manually. Indeed, unless a particular FRN requires numerous line items and/or recipients of service, manual entry may be easier.
  3. Early experience with the templates indicates that users will need to enter data carefully, often re-ordering line items if data is corrected. Trial and error is a common experience. We recommend early reading of USAC’s quick tips and detailed instructions. Some instructions, such as the following, may have to be read more than once:

    EPC Bulk Upload

Copies of the templates can be downloaded from either:

  • USAC’s FY 2016 Filing Window Headquarters page under the heading “Related Templates” or
  • EPC at the FRN level within a draft Form 471.

For the latter, click on the “Bulk Upload” button.

EPC Bulk Upload Button

Next, click on the “Download template” link.

EPC Download template

 

Review of Manual FRN Entry Process:

As indicated above, all line item and recipients of service data can still be entered manually, often more easily than using the templates. The basic navigation process is not always intuitive, so an illustrated review is appropriate. Here are the four basic steps for creating an FRN:

Step 1: Once you get to the  stage, click on the button, and answer all the FRN questions.
Step 2: The tricky part comes after answering the last FRN question. At that point you get a list of FRNs such as:

Underneath this list are three buttons.

Although it’s tempting, do not click the big green button. You are not ready for a new FRN yet. What the list shows, in this example on the 2nd and 3rd lines, are completed FRNs. Each completed FRN shows at least 1 line item and a dollar amount in the FRN Calculation column.

The incomplete FRN you are working on is always listed first in the list, showing zero line items and no dollar amount.

Step 3: To add a required line item(s), which is not intuitive, you must first click on the button-less FRN hyperlink on the first line.

Only then do you get an obvious line item button.

Step 4: After answering all the questions for that line item, the system will display that FRN’s line item(s) as shown below. At that point, if there are more line items to add, you can again click the green “Add New FRN Line Item” and repeat Step 3. Otherwise, click the gray “Continue” button in the bottom right-hand corner. This will take you back to the updated list of FRNs shown in Step 2, to either add a new FRN or complete the Form 471 draft.

New ESA Entity Type Guidance:

USAC’s Special Edition News Brief of April 9, 2016, announced that it had established a new entity type — “ESA School District with No Schools” — to reflect the unique characteristics of this type of ESA and the way such an entity can be handled within EPC.

Last year, a non-school ESA filing an application for its own services was advised to create a large Block 4 listing all the schools for the districts in its service region. The ESA’s discount rate was based on the total enrollment and eligibility of those districts’ students.

Within the new EPC structure, however, this approach is problematic. With EPC’s strict parent-child requirement, it would mean that a school (i.e., a “child”) would be associated with two separate “parents,” the ESA and their own district. USAC’s new “ESA School District with No Schools” type retains the same discount rate calculation without listing the regional district schools. Essentially, it makes the ESA a large school reporting the total enrollment and eligibility of its districts’ students.

Note the following:

  1. Multi-site non-school ESAs will report their main site as their “school,” and list their other sites as NIFs. Because none of their sites are schools in the normal sense of the word, none of the sites are eligible for Category 2 funding.
  2. ESAs qualifying for this new entity type should contact CSB to update their EPC profiles and, if necessary, to remove any links to the ESA’s districts.
  3. ESAs with schools are not affected by this change. They will continue to be treated as “School Districts,” listing their own schools and NIFs.
  4. Additional guidance may be required as this new entity type is implemented within EPC.

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. While USAC, the FCC, and various users or user groups are discussing a deadline extension, please start work on your Form 471(s) and the related — and necessary — EPC profile requirements as soon as possible. The learning curve for new users is steep.

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 email address on the blog’s home page (under the USAC logo), and confirming the resulting email.

Post No.    Title

  1.       Evaluate Your Bids! And Sign a Contract
  2.       Starting an FCC Form 471 and Background About Funding Requests
  3.       Enter Basic Information: Plus, Pick Category 1 or 2
  4.       Review Entity and Discount Information: Most Info Auto-Populates from Your Profile

E-Rate Central Funding History Tool Updated for FY 2016:

The “Funding Quick Search” tool, found in the upper left-hand portion of each State Information page on E-Rate Central’s website has been updated to include funding request data for applications filed for FY 2016. Users may find that this tool provides easier access to Form 471 data by BEN or by SPIN than the multi-tab Excel state file generated in USAC’s current “View/Download FCC Form 471 for FY2016” search tool.

USAC 2015 Annual Report:

USAC released its 2015 Annual Report last week. The Report provides a wealth of financial and other statistical data on the entire Universal Service Fund. Areas of particular E-rate interest include:

p. 15 Summary of the three goals of E-rate modernization
  1. Ensure affordable access to high-speed broadband
  2. Maximize cost-effectiveness to make the funds go further
  3. Simplify E-rate Program processes

As may come as no surprise to those struggling with the new EPC system, the Report focuses on the “end-state” benefits and characterizes the “roll-out” as an “iterative process”

p. 19  Statistics on application funding, invoice payments, and appeals
p. 34 Pricing and contract terms for Solix and Appian
p. 41 Funding breakdown for FY 2015 by application type

p. 49 State-by-state funding for FY 2015, calendar 2015, and historic 1998-2015 totals

Form 486 Deadlines for April:

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 deadlines (adjusted for weekends and holidays) for April for approved FY 2015 applications are:
                                          Wave 28                04/11/2016
                                          Wave 29                04/15/2016
                                          Wave 30                04/22/2016

Schools and Libraries News Brief Dated April 8 – Category 2 Budgets

The S&L News Brief of April 8, 2016, discusses Category 2 budgets for FY 2016 in a Q&A format. The questions covered are:

  •  How do C2 budgets work?  Short answer: 5-year budget limits are determined on a per student basis for individual schools and on a per square footage basis for individual libraries. See individual answers to:
    • How do you calculate the C2 budget for a school?
    • How do you calculate the C2 budget for a library?
    • Are C2 budgets pre-discount or post-discount?  Short answer: Pre-discount.
  • How do I determine my available C2 budget for FY 2016?  Short answer: EPC will calculate the budget requested for each entity, but the applicant must account separately for any funding committed for FY 2015. (Hint: Use USAC’s Category 2 Budget Lookup Tool.)  Also see answers to:
    • Can I apply for C2 funding for FY 2016 if I didn’t apply (or applied but was not funded) for FY 2015?  Short answer: “Yes.”
    • What if my FY 2015 C2 funding request is still pending a decision from USAC?  Short answer: The FY 2015 and FY 2016 requests must be coordinated in PIA.
    • Does E-rate Priority 2 funding received prior to FY 2015 count against the five-year budget for C2 purchases?  Short answer: “No.”
  • I need to spend more than my C2 budget to upgrade my network. If I spend more than my C2 budget, will that affect my E-rate request?  Short answer: “No.”
  • What happens if my plans change and I can't use all of the C2 funding committed in a year?  Can I reduce or cancel funding that USAC has already approved for the current funding year to "free up" money in its budget for the next funding year's requests?  Short answer: “Yes.”
  • When I complete the FCC Form 471, how do I indicate which products or services should be counted against which budgets?  Short answer: Costs may be assigned or allocated during the FRN creation process (as described earlier in our newsletter).
  • Can school districts and library systems shift funds or average costs among their schools and libraries?  Short answer: “No.”
  • If a school or library receives C2 items that were purchased with E-rate support from another school or library that is closing, would that have any effect on the school’s five-year C2 budget?  Short answer: “No.”
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.