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E-Rate Central News for the Week
June 6, 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 FY 2016 filing deadline for school and school district applications was Thursday, May 26th. The first funding wave for FY 2016 should be released in mid-June. USAC’s latest News Brief, referenced below, summarizes the Funding Commitment Decision Letter (“FCDL”) process for FY 2016.

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

The summer PIA deferment period, whereby application reviews are put on hold if the application contacts are not available, began last Friday. PIA for those applications will resume Monday, September 12th.

FY 2015:

Wave 53 for FY 2015 will be released on Thursday, June 9th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015 is $3.29 billion.

Updates on USAC’s E-Rate Productivity Center

Profile Changes Temporarily Disabled:

Immediately after the close of the FY 2016 application window for schools and school districts, USAC disabled the entity profile section for those types of EPC accounts. This was done on a temporary basis, through July 23rd, to stabilize school entity data until after the close of the extended library and consortium application window on July 21st.

To see this, click on the “Manage Organization” button.

x

The result is:

x

Although the direct path to school and district entity profiles is temporarily blocked, there are ways to add or update entity data as necessary. The easiest, though perhaps not the fastest, approach is to ask USAC to update the entity data by filing a Customer Service Request within EPC.

Alternatively, applicants who filed Form 471s for FY 2016, can use the RAL correction process to update entity data in their applications. (Note: It is not yet clear if such updates will flow through the applicants’ entity profiles, or will simply update their applications.)  To update application entity data within EPC:

  1. Select “FCC Forms,” then choose “FCC Form 471.”

    x
  2. Click on the application number to display the basic Form 471 information. Select “Related Actions,” then choose:
    x
  3. To edit a specific entity, sequentially select “Entity,” “Related Entities,” the entity in question, and then “Edit.”
    xx

Summer Deferral of PIA Inquiries:

The S&L News Brief of May 27, 2016 notes that USAC will put application reviews on hold during the summer contact period if the contacts on those applications are not available. The summer deferral period began the Friday before Memorial Day and will end the Friday after Labor Day. Application contacts receiving PIA inquires will now see an option within EPC to exercise the summer deferral period.

PIA inquiries are initiated with emails to the application contacts entitled “E-Rate Application Information Request. ”  Each email includes a hyperlink “Click here to respond to inquiries” directly (after login) to the “Pending Inquiries” section of the applicant’s EPC account. As shown below, there is now a new “Apply Summer or Winter…” button in the upper right-hand corner. (Note: “Winter” refers to a shorter deferral period in effect during the late December holiday season.)

 

The applicant now has three choices: (a) respond to the inquiry within the initial 15 days; (b) request a 7-day extension; or (c), request an extension until the end of the summer period. At this stage of the year, the latter choice provides the greatest flexibility. The downside of this option is that approval of the application is also deferred — although the applicant can reinitiate the application review at any time by answering the outstanding inquiries.

E-Rate Updates and Reminders

FCC Releases Draft ESL for FY 2017:

The FCC released, and is seeking comment on, the draft Eligible Services List (“ESL”) for FY 2017. The Public Notice (DA 16-615) contains a summary of the changes and the proposed ESL itself. The proposed ESL changes are primarily clarifications of the new fiber rules. One lingering question that appears to be resolved is the treatment of special construction charges for fiber installed between two buildings on the same campus. Fiber which crosses a public right-of-way has always been considered Category 1, but the C1 vs. C2 status of fiber within a campus has been hazy. The draft ESL addresses this issue by indicating that fiber between two separate schools (as defined by the state) on a campus falls under Category 1, whereas fiber between two buildings of the same school (e.g. a main school and its annex) is to be treated as Category 2 (and thus subject to that school’s C2 budget limitation). In a phrase: “One school, Category Two; two schools, Category One.”

Comments on the proposed ESL are due July 5th; reply comments are due July 20th.

FCC Decision Watch — More IDER Denials:

The FCC issued its latest monthly set of “streamlined,” precedent-based decisions in Public Notice DA 16-600.

Apparently undeterred by the broad and negative reaction to its April denial of over 120 requests for FY 2014 invoice deadline extensions (“IDERs’) — see “Uproar over the FCC’s IDER Decision” in our newsletter of May 23rd — the FCC denied another 65 IDERs. Were it not tone-deaf, the FCC might have at least deferred a decision on these IDERs until it had fully considered the major Petition for Reconsideration and Rulemaking filed by the State E-Rate Coordinators’ Alliance (“SECA”) in response to the first set of denials.

In addition to the IDERs denials, last week’s decision:

  1. Granted:
    1. Two requests for review of one applicant’s appeal concerning compliance with state and local procurement laws.
    2. One request for review finding that the carrier chosen was an “Eligible Telecommunications Provider.”
    3. One request for review granting additional time to respond to USAC’s request for information.
    4. One request for waiver of the Form 471 window for a late-filed application due to actions beyond the applicant’s control.
    5. Five requests for reviews and/or waivers approving Form 471 (or other) corrections as a result of ministerial and/or clerical errors.
    6. One request for waiver concerning a mischaracterization of telecommunications services.
  2. Partially granted:
    1. One request for USAC review of cost allocation for ineligible components.
  3. Dismissed or denied:
    1. Three petitions for reconsideration deemed failing to “identify any material error, omission, or reason warranting reconsideration.”
    2. One request for waiver of the deadline to file an operational SPIN change.
    3. One request for review seeking support for services not covered by the applicant’s Form 470.
    4. One request for review or waiver seeking the extension of a service delivery deadline.
    5. Five requests for reviews or waivers not filed within the 60-day appeal window.
    6. One request for review or waiver of the competitive bidding 28-day rule (missed by more than three days).

Form 486 Deadlines for June:

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 June (adjusted for weekends and holidays) for approved FY 2015 applications are:

                                          Wave 36                06/10/2016
                                          Wave 37                06/21/2016
                                          Wave 38                06/27/2016

Schools and Libraries News Brief Dated June 3 – FCDLs and Form 498s

The S&L News Brief of June 3, 2016 notes that Funding Commitment Decision Letters (“FCDLs”) for FY 2016 will be released electronically through EPC, not through the mail as has been the case in previous years. As indicated above, we expect that the first weekly wave of FCDLs for FY 2016 will be released in mid-June. The actual date of Wave 1 may depend on USAC’s final development and testing of a new EPC-based version of the Form 486. USAC is also working on a set of commitment search tools publicly-available outside of the EPC system.

USAC also announced an outreach effort to confirm the required Form 498 banking information to permit the direct payment of BEAR reimbursements effective July 1st. The Form 498 has been available within applicant EPC portals since last December, but earlier submissions had not been subjected to approval. The outreach process will require applicants, who have already completed their Form 498s within EPC, to provide “a canceled check, bank statement, or other verification” to confirm the accuracy of the bank account and routing information.

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.