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E-Rate Central News for the Week
April 18, 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

USAC’s Special Edition News Brief of April 15, 2016, announced extensions of the FY 2016 Form 471 application window. For most applicants, the new filing deadline has been postponed by four weeks. It is now scheduled to close at 11:59 p.m. EDT on Thursday, May 26th. Libraries and consortia, whose applications depend on the completion of related school district entity data, and who, as a result, may not currently be able to even begin their Form 471s, are being given an additional eight weeks. The deadline for filing library and consortium applications is Thursday, July 21st. The Form 471 deadline extensions also extend the last possible dates for filing Form 470s for FY 2016 until April 28th for most applicants, and until June 23rd for libraries and consortia.

Wave 46 for FY 2015 will be released on Thursday, April 21st. 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.

Updates on USAC’s E-Rate Productivity Center

Two EPC “Improvements:”

USAC released a Special Edition News Brief of April 11, 2016, announcing changes to the EPC system to address two minor problems being encountered by certain applicants.

CEP Discount Rate Calculation Rounding:

Note: The following discussion applies only to schools participating in the Community Eligibility Provision (“CEP”) program — and more specifically to those CEP schools with a “identified student percentage” (“ISP”) in the range of 46–47%.

CEP schools, school groups, or school districts calculate their number of NSLP-eligible students and discount rate by:

  1. Using the direct certification process to determine the “identified student percentage” (“ISP”). This percentage is expressed to two decimal places. To be eligible for CEP, this percentage must be at least 40%.
  2. Multiplying the ISP by the Department of Agriculture-approved factor, currently 1.6x, to estimate the total percentage of NSLP-eligible students. This percentage must be at least 64% and is capped at 100%.
  3. Multiplying the NSLP-eligible percentage by total student enrollment, rounding up to the next highest integer to determine the number of NSLP-eligible students.
  4. Dividing the number of NSLP-eligible students by the total student enrollment, rounding that result to the nearest whole percentage point.
  5. Using the resulting percentage to determine the entity’s E-rate discount rate. For CEP schools, the E-rate discount rate will be either 80%, 85% (Category 2 only), or 90%.

The problem within EPC has been in step #1. EPC has been rounding the initial ISP down to the lower whole percentage point. Depending upon the size of the school, this rounding could affect the eligible student calculation by a few students. This error is a problem only if the initial CEP percentage is in the 46–47% range. Where it falls within this range could mean the difference between qualifying for an 80% discount or the higher 85–90% discount. The following is an example of this borderline problem. In this example, rounding down the CEP percentage, as EPC had been doing, results in a 10% lower discount rate.

Step Description Without CPE
Rounding
With CPE
   Rounding Down
1 Directly Certified CEP (ISP) % 46.72% 46%
2 NSLP-Eligible % 74.75% 73.60%
3 NSLP-Eligible Students* 150 147
4 NSLP-Eligible Students % 75% 74%
5 Discount Rate (Category 1) 90% 80%
* Total enrollment = 200

Single Circuit Allocations for Multi-School Sites:

Note: The following discussion applies only to schools sharing a common site, but begins with a description of a seemingly related EPC problem that has not yet been fixed. The News Brief is somewhat confusing on this point. It refers to the need for an applicant choosing Data Transmission and/or Internet Access directly to one entity to allocate the connection to all the entities sharing that service.

The most common problem — and one not addressed in this News Brief — is for Internet Access via a single circuit to one location, but shared via a WAN to other entities.

In this case, when you get to the FRN section below, you would think that you would check “Yes” to the direct connection question, check “No” to the WAN question, then use the “Multiple buildings” pulldown to indicate that the Internet is being shared.

EPC Connection Information for new FRN Line Item

Responding this way creates an awkward EPC problem. If later in the FRN creation process you indicate that multiple sites are sharing the service, the system default assigns one circuit per site, not one circuit to the group.

A quick reading of the News Brief might suggest that the solution to this problem is to assign a fractional (actually a decimal) value to each site (e.g., 0.2 circuits per site for Internet shared over a 5-school WAN). As discussed below, this was not the intent of the News Brief.

The best way we have found to solve the EPC shared internet allocation problem is select the “One building/site listed” response, and subsequently select the one site directly connected to the Internet provider. In other words, although the Internet is shared, the “Connection used by” is only the gateway site.

The fractional allocation fix discussed in this News Brief is designed to address a less common problem of any circuit terminating in a single physical location shared by multiple schools. Most commonly, we see this situation arise in either of the two following situations:

  1. A small school district housing what its state considers to be 2-3 schools in the same building (e.g., an elementary, middle, and high school); or
  2. An urban school district that has split a large building into 2 or more individually-defined schools.

The solution — hopefully to be available this week — is to allocate a portion of the one circuit to each school, making sure that the total adds up to one. In the News Brief example, therefore, the allocation for a 3-school building would be 0.33, 0.33, and 0.34.

Forthcoming EPC Updates:

USAC’s Special Edition News Brief extending the filing window also pointed to a list of EPC upgrades that are expected to be implemented within the next few weeks to:

  • Ensure that certain data that is currently missing from the PDF application review will appear, including some fields for Tariff and Month-to-Month FRNs and for certain portions of fiber FRNs.
  • Ensure that users have the ability to bulk upload student counts for larger data sets. (Applicants, particularly those with a large number of entities, have continued to report problems with the bulk entity upload process.)
  • Allow consortia applicants to have the ability to “select all” recipients of service on a funding request line item. (Currently, entities receiving service must be checked individually.)
  • Remove the erroneous error message that appears on the interest rate field for FRNs with special construction costs.
  • Display Billed Entity Numbers and FRN Line Item numbers rather than the internal tracking numbers on error messages for certain consortium applications. (EPC uses its own 6-digit internal entity numbers, beginning with a “3,” often creating undecipherable error messages for applicants.)
  • Remove the requirement to allocate Internet Access by individual recipients of service. (One temporary workaround for this problem is discussed above.)
  • Allow FRN Line item uploads using Excel 2013. (The recently released template for uploading FRN line item and recipient of service data currently requires the use of Excel 2010. A temporary workaround to support Excel 2013 is now being tested.)
  • Allow the FRN line item upload template to accommodate partial line allocations. (The use of fractional — more precisely “decimal” — line allocations is one of the “improvements” discussed above.)
  • Prevent the Entity upload template from rounding CEP percentages. (The rounding of CEP percentages within the EPC system itself has been fixed, as discussed above.)
  • Allow users to enter data in all fields of the Connectivity template. (USAC’s offer to help large users complete their connectivity profiles has been hindered by a formatting error in the USAC-provided template.)

E-Rate Updates and Reminders

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.       Add a Category One Funding Request: Plus, Continue or Copy an FRN
  2.       FRN Contract: Associate a Contract
  3.       FRN Contract: Tariffed and Month-to-Month Services
  4.       Add a Category One FRN Line Item: Product/Service Details, Function, and Type of Connection
  5.       Add a category One FRN Line Item: Bandwidth Speed and Connection Info

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

As noted in last week’s newsletter, 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.
E-Rate Central Funding History Quick Search

Upgraded versions of USAC’s more detailed multi-tab Form 471 Excel tables are also available. The most useful feature of E-Rate Central’s Enhanced Form 471 State Files of FY 2016 is the addition of applicant names and BENs in each tab.

Increased CEP Participation:

The Food Research and Action Center (“FRAC”) and the Center on Budget and Policy Priorities (“CBPP”) released an updated report “Community Eligibility Adoption Rises for the 2015-2016 School year, Increasing Access to School Meals.”  The report, providing state-by-state statistics, indicates that student enrollment in CEP schools is up 28% nationwide this year. This is good news, not only for the students, but in many cases for the E-rate discount rates of the participating schools.

FCC Approves Middletown’s CPN Waiver Request:

The FCC approved (DA 16-400) a request by the Enlarged City School District of Middletown (NY) for a limited waiver of the FCC’s Calling Party Number (“CPN”) identification rules. As discussed in our newsletter of March 7th, and several subsequent issues, strict CPN rules had been severely restricting Middletown’s ability to deal with a rash of threatening calls. The FCC’s Order was strictly limited to Middletown, but suggests that waivers by other schools facing threats would be similarly addressed on a one-by-one basis. Unfortunately, from our point of view, the FCC stated that “Based on the record before us we decline at this time to amend the existing CPN rules, as suggested by E-Rate [Central], to include an exemption for any school receiving threatening calls.”

Form 486 Deadlines for April and May:

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 for May and the remainder of April (adjusted for weekends and holidays) for approved FY 2015 applications are:
                                          Wave 30                04/22/2016
                                          Wave 31                05/06/2016
                                          Wave 32                05/13/2016
                                          Wave 33                05/23/2016
                                          Wave 34                05/27/2016

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.