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E-Rate Central News for the Week
May 16, 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

FY 2016:

The revised filing deadline for FY 2016 applications is 11:59 p.m. EDT on Thursday, May 26th. PIA application review for FY 2016 is underway. The first funding wave for FY 2016 should be released in early June.

Libraries and consortia, whose applications depend on the completion of related school district data, have been granted an additional eight-week extension to July 21st. As a result of the latter Form 471 deadline extension, the last possible date for libraries and consortia to file Form 470s for FY 2016 is June 23rd.

To facilitate the application process, USAC’s Client Service Bureau is currently operating on extended hours, 8:00 a.m. – 8:00 p.m. EDT on weekdays and 12:00 p.m. – 4:00 p.m. on Saturdays.

FY 2015:

Wave 50 for FY 2015 will be released on Thursday, May 19th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015 is $3.26 billion.

Updates on USAC’s E-Rate Productivity Center

Finding PIA Inquiries

USAC initiated PIA inquiries last week.  For the first time, PIA inquiries and applicant responses will be processed through EPC. It’s already clear that this is going to involve a learning process for applicants, consultants, and PIA reviewers alike.

The basic PIA inquiry/response process is as described in USAC’s Special Edition News Brief on April 27th and in our newsletter of May 2nd. What caused significant confusion last week was the email alert, such as the following, sent to the applicant contacts.

From: [PIA Reviewer Name]@sl.universalservice.org
Sent:  Monday, May 09, 2016 10:35 AM
To:     [Applicant Contact Name and Email]
Subject: PIA Has Inquiries About Your FCC Form 471 Application

Dear [Applicant Contact Name]

My name is [PIA Reviewer Name] and I am a part of USAC’s Program Integrity Assurance (PIA) review team, currently reviewing your Funding Year (FY) 2016 FCC Form 471 application(s). PIA review is the process of checking FCC Form 471 applications for compliance with program rules and policies.

My review has generated further inquiries about your application, and we have sent the inquiry request to you. It is waiting for you in our new IT system, the E-Rate Productivity Center (EPC). Beginning FY2016, applicants must receive and answer all PIA inquiries using only one method—EPC. PIA will no longer email or fax FY2016 questions to you.

In order to access, respond to, or manage PIA inquiries (or any PIA notifications), you must:

  1. Log in to EPC.
  2. View the PIA notice in the News tab. The notification in the EPC News tab reads: From the FCC Form 471 Review Team.
    • Tip: To locate your inquiries more easily, enter "471 Review Team" in the News search function and hit the "Enter" key.
      When you click the blue bar at the bottom of the notification, you will be able to access your inquiries under the Review Inquiries menu item.
  3. From the “Review Inquiries” page, select one of the following:
    • Respond to inquiries
    • Request an extension
    • Submit a modification to your form ("RAL correction")

Note: USAC strongly recommends that you routinely monitor your News to make sure you do not miss any PIA inquiries.

Please refer to USAC’s News Brief for in-depth, specific guidance on how to:

  • Understand how you will be notified about PIA questions
  • Access your PIA questions
  • Respond to your PIA questions
  • Request an extension of time to answer PIA questions
  • Submit modifications to your FCC Form 471

Please feel free to contact me via EPC or call me if you need more information or have questions. I kindly ask that you answer the inquiries promptly, in order for your application review to continue. If you need additional time to prepare your responses, please let me know as soon as possible.

This example is one of the earlier alerts received. One improvement to the template, quickly added by individual reviewers, was to include some identifying information to the subject line to at least indicate a Form 471 number and/or applicant name. This was a particularly important addition for contacts (such as consultants) dealing with multiple applications.

What the email does not include, as had been the case in all years past, is an attachment indicating the questions being posed. To get the questions, the applicant contact is directed to an EPC “News” feed which, in turn, links to an EPC “Review Inquiries” page showing “Pending Inquiries” and providing an online mechanism to submit responses, request extensions, or make RAL corrections.

The first challenge facing an applicant is to find the specific “News” feed leading to the PIA question(s). The general “News” tab in EPC, even if customized to narrow the type of news reported, is choked with unrelated items. There is, however, a search function. Unfortunately, at least as of last Friday, the PIA email’s suggestion to search for “471 Review Team” wasn’t leading to any useful results. We’ve found that searching for “15-Day,” which is also referenced in the “News” inquiry subject line, works better.

Another approach to finding the appropriate “News” inquiry notice is to use the applicant-specific “News” function. As discussed in our May 2nd newsletter, there are two links to “News” from the applicant’s “Landing Page.”  The red arrow points to general “News;” the green arrow points to applicant-specific “News.”

USAC EPC News

Activation of Dummy SPIN:

USAC posted a notice last Thursday indicating that it has activated “143666666” as, what we call, the “dummy” or interim SPIN. USAC has traditionally activated this in the last few weeks of the application window. This is a temporary “Service Provider Identification Number” an applicant can use in funding requests if the applicant is new to E-rate and has not yet obtained its own SPIN. During PIA review, the applicant will be prodded to update the “dummy” SPIN with the vendor’s real SPIN, hopefully available by that time.

Note:  An interim SPIN is not to be used in cases where the applicant is unsure as to which service provider they are going to select, but wants to submit their Form 471. The selection and notification of the service provider must be executed prior to submitting the Form 471.

Safe Sender Lists for FCDLs:

A small notice in last week’s USAC News Brief (referenced below) indicates that when Funding Commitment Decision Letters (“FCDLs”) are issued this year, emails, rather than actual letters, will be sent to the applicants — no doubt referring the applicants to FCDL “News” items. To make sure applicant contacts receive these emails, USAC suggests adding “portal@usac.org” to their email systems’ “safe sender” lists.

More broadly, with USAC’s greater reliance on email notifications, we would suggest earmarking both “usac.org” and “sl.universalservice.org” (used by PIA) as safe domain names.

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.   A link to last week’s single posting is 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.       What's on Your RAL: FCC Form 471 Receipt Acknowledgement Letter

New Format for FY 2015 Application Display:

USAC’s Form 471 View – Funding Year 2015 display has been reformatted to provide a less cluttered view of larger applications. The initial views of both entities (used for discount rate calculations) and FRNs show only five at a time. An example of a consortium member list is provided below. Note that in the default mode, you can page through the lists five items at a time, but you can also reset the list display to show 10, 20, 50, or all listed items at a time. A similar display capability would be useful in EPC.

EPC Form471 View for FY 2015

Form 486 Deadlines for 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 the remainder of May (adjusted for weekends and holidays) for approved FY 2015 applications are:

                              Wave 33                05/23/2016
                              Wave 34                05/27/2016

Schools and Libraries News Brief Dated May 13 – Filing Actions for Schools and Districts

The S&L News Brief of May 13, 2016, discusses actions that schools and school districts should take “NOW.”  In point of fact, many of these actions are overdue. They include:

  1. Get an EPC account.
  2. Get an FCC Registration Number for your organization.
  3. Get an entity number for each entity in your organization.
  4. Get an account administrator.
  5. Check the applicant type for your organization.
  6. Update each entity profile in your organization with complete information.

Alternatively, if these steps are new to you, a more practical and satisfying approach at this late date might be to:

  1. Lean back;
  2. Put your feet up on your desk; and
  3. Wait for next year’s application cycle (hopefully with EPC 2.0).
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.