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E-Rate Central News for the Week
July 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

FY 2016:

USAC released Wave 4, totaling $23.6 million, on Friday, July 15th. Cumulative national funding through Wave 4 is $78 million.

The extended Form 471 application filing window for libraries and consortia closes this Thursday, July 21st, at 11:59 p.m. EDT.

FY 2015:

No wave for FY 2015 is scheduled this week. Cumulative funding is $3.31 billion.

Updates on USAC’s E-Rate Productivity Center and Legacy System

Tracking RAL Corrections:

Prior to FY 2016, applicants could make or request changes to their filed applications by physically marking up their paper Receipt Acknowledgement Letters (“RALs”) and submitting the corrected RALs to USAC. For FY 2016, RAL Corrections must be made online through EPC.

To make a RAL Correction, navigate to the Form 471 application, then select “Submit Modification Request (RAL)” under “Related Actions.”

Submit Modification Request (RAL)

An important part of the RAL Correction process is to recognize that applicant “corrections” are, in reality, requests to update an application. Corrections are not applied to an application until USAC’s system, or in some cases a PIA reviewer, approves the changes. Some corrections, such as a change in applicant contact information, are virtually automatic. Other corrections, particularly those regarding FRN changes, need to be more carefully reviewed by PIA. Often, in such cases, the changes must be deemed to have resulted from a “Ministerial or Clerical” error.

Once a RAL Correction has been made, its status may be tracked by selecting “My Submitted Modification Requests (RAL)” under the “Reports” tab.

My Submitted Modification Requests (RAL)

This generates a rather detailed list of RAL Corrections.

Detailed List of RAL Corrections

The detail may be hard to read in this example, but please note the following:

  1. This particular list is the result of two relatively simple corrections (identified by the left-hand “RAL Request ID” column) made to a single FRN for cellular services. What creates this much detail is that each field change is reported on a separate row.
  2. Columns #2 and #4, blanked out in this example, show the Form 471 application number and FRN numbers (sometimes with a three-digit addendum to indicate the FRN line number).
  3. The next to last column indicates the status of the RAL Correction. In this case, the individual changes are marked only as “Submitted” (except for one inexplicitly labeled “Inactive”). Once reviewed and approved by USAC, the status should change to “Approved.”
  4. The last column, showing “View,” provides hot links to any documents uploaded during the RAL Correction process. If no documents were provided, the “View” link is inoperative (except to sometimes change the row order).

Problematic Library/Consortium Applications:

With the extended application filing window for libraries and consortia closing this coming Thursday, it’s time to consider what applicants should do if they are still facing problems with incorrect or missing EPC entities for associated school districts (or schools). Although USAC has been hard at work on corrections, entity data problems remain. From USAC’s viewpoint, this leaves the following two options:

  1. Extend the library/consortium window again (unlikely); or
  2. Encourage applicants to file with available information, and work to fix the remaining problems during application review.

As of last Friday, considered by many to be a drop dead date for entity corrections, USAC was going with Option #2 — getting the applications filed and fixing them later.

The most important step for any applicant using this option is to flag the application for special attention. USAC’s advice to consortium applicants still encountering entity problems is to:

  1. Drop any affected members from the consortium application.
  2. Include clear language in the “Narrative” section of any affected FRN stating, for example, “This FRN also include services for the following districts…,” which we’d suggest listing by name and BEN.
  3. Make sure that the amount of funding requested reflects all the entities that should be in each FRN. This may require over-allocating expenses to the more limited subset of entities included in the initial application.

In the same spirit, we offer the following procedural and “Narrative” suggestions:

  1. Consortia with large numbers of missing entities or with other complications may find it more useful to submit spreadsheets or other documentation. Because the Form 471 system does not support uploads of such files, one (or both) of the following approaches can be used:
    1. Pre-submission:  Create a Customer Service Case (which does permit file uploads) and reference the Case number in the associated FRN “Narrative(s).”
    2. Post-submission:  Initiate a RAL Correction (which also supports file uploads) immediately after submitting the Form 471, including a description of the necessary changes and documentation provided in the textbox.
  2. Libraries have a different problem. Since each library’s discount is determined by the entity data of its local school district, eliminating the district from the application is not an option. A feasible alternative for a library would be to reference the closest district for which entity data is available, and clearly flag the switch in the “Narrative.”

Form 498 Status Verification:

After an applicant has completed a Form 498 in EPC, USAC will reach out for confirming documentation (a voided check or bank statement) to verify the bank account and bank routing information. This is information that has to be correct for electronic payment purposes. USAC has found enough problems in initial Form 498 filings to fully justify the need for this confirmation process.

From an applicant’s perspective, it is important to know when USAC has completed the verification process and approved the Form 498. Until a Form 498 is approved, an applicant cannot complete an online BEAR. Applicants, who have submitted their banking documentation, but who have not otherwise been advised of the approval status of their Form 498s, can request a status update from USAC by emailing: 498bankverification@usac.org.

Consultant/Applicant Roles in EPC:

EPC has been a mixed blessing for E-rate consultants. The system’s complexity, particularly in its first year of operation, has led more applicants to consider the use of consultants. For FY 2015, roughly 50% of applicants, accounting for almost 60% of the discount requests, used consultants. When final FY 2016 numbers are available, we expect both percentages to be higher.

The downside of EPC as currently structured is that certain critical E-rate tasks can be performed only by the Account Administrator (“AA”) who must be an applicant employee. A consultant cannot be an AA. To provide excellent E-rate support, consultants are continually being forced into a position of saying to a client:  “We can walk you through this step, but you need to log into EPC and do it yourself” — often followed by saying:  “By the way, you’ll probably have to reset your EPC password first.”  The entire EPC process is frustrating for consultants and applicants alike.

The new requirement for applicants to file Form 498s to support the direct electronic payment of BEAR reimbursements led to the following email from On-Tech Consulting to other consultants in the E-Rate Management Professionals Association (“E-MPA”). A slightly edited version is reprinted below (with permission) as a humorous indicator of shared frustrations.

x

To be a little more expansive, but not as funny, please note the following:

  1. Some amount of staff turnover is to be expected. With most applicants, personnel involved in E-rate have many additional duties. If they leave, E-rate may not be at the top of their job transition to-do lists. This can be particularly problematic if the individual leaving is the EPC Account Administrator. Only the AA can add a new person to the EPC account and/or reassign the AA role. If the AA leaves before doing that, replacing the AA on the account requires Client Service Bureau intervention and additional applicant documentation.
  2. Passwords have become a burden of everyday living. EPC passwords are a special case because:
    1. They are user-specific, supposedly not to be shared with anyone (a condition of the EPC Terms and Conditions).
    2. They must meet strict standards including upper and lower case letters, numbers, and special characters.
    3. They must be reset every 90 days.
    4. Re-establishing a lost password is a two-step process that must be completed within a ten minute window.
    In our experience, CSB representatives are unfailingly polite. But we can envision a slight tone of disapproval in a response to a request for a password assigned to someone else.
  3. It’s easy to get lost navigating within EPC. Unless a user is specifically set up as a “School or Library Official” or “General Financial Contact,” the user cannot even see a Form 498.
  4. All invoices, both BEARs and SPIs, are now paid electronically. The primary purpose of the Form 498 (and the pre-approval confirmation) is to provide bank account routing information to USAC.

E-Rate Updates and Reminders

Reply Comments Due on the Proposed ESL:

Reply comments on the draft Eligible Services List (“ESL”) for FY 2017 (DA 16-615) are due July 20th. Links to, and a brief summary of, the only two initial comments to the ESL were provided in our newsletter of July 11th.

Form 486 Deadlines for July:

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

                      Wave 42                07/22/2016
                      Wave 43                07/29/2016

Schools and Libraries News Brief Dated July 15 – Update on PIA Responses

The S&L News Brief of July 15, 2016, indicates that USAC has updated the PIA process to prevent applicants from submitting partial responses to PIA inquiries.  Previously, if an applicant submitted answers to only some questions, the EPC system prevented the applicant from returning to the inquiry section to answer the remaining questions.

There were two obvious approaches to fixing this problem. One was to update the system to permit applicants to respond to questions in stages; the other was to prevent applicants from responding at all until all questions in a particular inquiry were addressed. USAC, which would like to handle inquiries in their entirety, chose the latter.

Applicants will now receive a warning message if they try to submit incomplete responses. The News Brief makes it clear that applicants do not have to address all questions in one sitting, but can save their work at any stage in the process, and can return to the questions at a later time (albeit within the deadline for responses).

Last Friday’s News Brief also reviewed some very basic application tips for library and consortium applicants approaching the extended July 21st filing deadline.

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.