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E-Rate Central News for the Week
August 29, 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 10 for FY 2016, totaling $58.4 million, on Friday, August 26th. Cumulative national funding through Wave 10 is $404 million.

Comparatively, funding for FY 2016 continues to lag well behind last year’s pace. Individual funding waves are currently running about half the size of last year’s waves. Cumulatively, through the end of August, the shortfall is about one billion dollars.

FY 2015:

USAC will release Wave 63 for FY 2015 on Friday, September 2nd. Cumulative funding through Wave 62 is $3.31 billion.

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

Form 498 Filing Update:

Effective July 1, 2016, all BEAR reimbursement payments are being made directly to applicants (rather than through the service providers). In order to accomplish these electronic payments, an applicant must have filed — and USAC must have approved — a Form 498. This is a two-step process.

  1. The applicant must file and certify a Form 498 online through EPC.
  2. Before approving a Form 498, USAC will request confirming bank account information, such as a blank voided check for that account. Depending upon applicant response time, the USAC approval process is currently taking two weeks or more.

The only applicants not required to file Form 498s are those relying solely on discounted vendor invoices. All others must eventually file Form 498s. Remembering that the invoice deadline for filing BEARs for recurring FY 2015 services is October 28th, applicants requiring Form 498s should have already begun the process.

Unfortunately, this does not seem to be the case. USAC released a Form 498 status report to State E-Rate Coordinators last week (to be used for outreach purposes) showing that only 22% of FY 2015 applicants nationwide currently have approved Form 498s on file. We suspect that percentage needs to be 80% or more — and soon.

If an applicant is not sure about the status of their Form 498 approval, we recommend the following:

  1. Begin the online BEAR filing process by completing the BEAR Invoice System Login.

    EPC Applicant Login
  2. Note that this login requires a PIN. If you don’t have a PIN, one can be requested from USAC’s Client Service Bureau (888-203-8100). Count on a lead time of at least two weeks. This estimated lead time underscores the importance of starting now if you have not already done so.
  3. Once logged in, go to “New BEAR Form,” as if to start a BEAR.

    EPC Add BEAR Invoice

    If a Form 498 has been approved for this Billed Entity Number (“BEN”), the Form 498 ID number will be displayed in that field. If the field is blank, more work — either by the applicant or USAC — is needed to get a Form 498 filed, certified, confirmed, and approved.

September’s FRN Status Tool:

USAC alerted several E-rate user groups last week that a new database of FY 2016 funding information would be available later in September. In its initial implementation, the new database — designated the “FRN Status Tool” — will mirror much of USAC’s current Data Retrieval Tool (“DRT”), the mainstay source of funding data for FY 2015 and earlier years. One key data field in the new tool will provide approval status of applicant Form 486s for FY 2016. Additional FRN Status Tool data fields (not available in the existing DRT) are expected to be added later in the year.

The Last of the Good Samaritans:

One potential problem faced by applicants, fortunately infrequently, is the inability to obtain BEAR reimbursements for a previously approved funding request when their service provider has subsequently gone out of business. Prior to July 1, 2016, when BEAR payments had to flow through service providers, the solution was to enlist the assistance of another service provider — a “Good Samaritan” — to act as the middleman for any BEAR reimbursements.

However, as of July 1st this year, all BEAR payments are made directly from USAC to the applicants. Since BEAR payments no longer flow through the service providers, there is no longer a need for Good Samaritans. This is good news — perhaps to all but religious scholars bemoaning the loss of a biblical reference in E-rate procedures.

The bad news is that an applicant, dealing with an out-of-business supplier, is still not home free. Current FCC rules on the direct payment of a BEAR still require the associated service provider to have filed a SPAC (Service Provider Annual Certification – Form 473) for that funding year. If the service provider hadn’t filed that SPAC before going out of business, it may be impossible to get them to do it now. Without the SPAC on file, USAC cannot process the BEAR payment. USAC’s current advice, in such a situation, is to file a waiver request with the FCC. Hopefully, the FCC will ultimately give USAC the authority to make a BEAR payment in this situation if USAC can confirm that the service provider is no longer in business.

E-Rate Updates and Reminders

File Along with Me:

A link to last week’s “File Along with Me” 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.       Starting Your E-rate Supported Services, and confirming that your services have started using Form 486.

USAC Fall Training Schedule:

USAC has posted the following locations and dates for its annual fall training series on its Trainings & Outreach site. Registration began last Friday. The Washington session is likely to be filled as of early this week.

      • Washington, DC Monday, September 26, 2016
Orlando, FL Thursday, October 6, 2016
Houston, TX Friday, October 14, 2016
Philadelphia, PA Tuesday, October 18, 2016
Minneapolis, MN Tuesday, November 1, 2016
St. Louis, MO Thursday, November 10, 2016
Seattle, WA Wednesday, November 16, 2016
Los Angeles, CA       Friday, November 18, 2016

Schools and Libraries News Brief Dated August 26 – Service Provider “.RSP” Files

The S&L News Brief of August 26, 2016, announced conference and hotel registration information for its fall training sessions (see above), and provided an update for service providers who have signed on for electronic notifications. Most importantly, USAC indicated that its file format for distributing Receipt Acknowledgment Letters (“RALs”) to service providers — the so-called “.RSP” files — has been modified to match the pre-FY 2016 legacy format. This should make FY 2016 RAL information more easily accessible for service providers’ existing IT systems. The News Brief includes service provider instructions to generate a complete set of FY 2016 .RSP files.

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.