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E-Rate Central News for the Week
September 26, 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 indicated its intent to standardize the release of FY 2016 waves on Mondays, as it did last week, in order to take advantage of lower system demand over the weekend to facilitate pre-wave processing. Wave 14 is scheduled for release today, September 26th.

Last Monday’s Wave 13 for FY 2016 totaled $59.2 million. Cumulative national funding through Wave 13 is $580 million.

Petitions Seeking Support for Off-Campus Internet Access

The FCC issued a Public Notice (DA 16-1051) seeking comment on two petitions requesting rule changes, clarifications, or waivers to permit limited off-campus use of E-rate supported Internet access. The goal of both petitions is to help close what Commissioner Jessica Rosenworcel has coined the “homework gap” — the inability of students, particularly those from low-income families, to access increasingly necessary broadband Internet services outside of their schools.

The two petitions address off-campus use from slightly different perspectives.

  • The Boulder Valley SD ("BVSD") petition focuses on an E-rate cost allocation issue. BVSD proposes to extend E-rate supported Internet access, available at some of its schools, to students living in nearby affordable housing complexes. The expense of these new connections would be borne by the housing authority (or other entities). After-hours use of the district’s Internet service would take advantage of the otherwise underutilized network with no additional cost to the school or E-rate fund. Currently, use of E-rate funded Internet services by local communities is permitted only on campus and after school hours. Any off-campus use, however, is required to be cost-allocated out of the applicant’s E-rate funding, effectively increasing the district’s non-discounted share. The BVSD petition asks the FCC to waive the cost allocation provision in these situations. BVSD notes that a similar, although clearly more targeted, waiver was granted to rural Alaskan communities (FCC 01-350) fifteen years ago.
  • The Microsoft petition proposes the use of a new TV White Spaces (“TVWS”) technology to extend E-rate funded broadband Internet services to eligible students in two rural Virginia counties. Microsoft and its partners plan to fund the TVWS equipment so, again, there would be no extra E-rate funding required. Microsoft’s petition is somewhat broader than BVSD’s petition because it requests clarification and/or waiver of the FCC’s educational purpose restriction to cover this extended off-campus usage. The practical effect of which, if granted, would be to also avoid the necessity of cost-allocation. As an alternative, should the requested clarification not be granted, Microsoft asks that the FCC grant a limited waiver of its rules to proceed with the project as a pilot.

The FCC’s request for comment recognizes “the importance of broadband connections off-campus for students and library patrons,” pointing, as an example, to its 2011 pilot Learning-On-The-Go program (which supported off-premise wireless learning devices). We believe that at least a few of the FCC Commissioners, led by Jessica Rosenworcel, are actively seeking a solution to the “homework gap” problem and will support the requested waivers/clarifications.  Their challenge, as we see it, is to do so without opening the E-rate floodgates implicit in a broader definition of “educational purpose.”  Comments — due November 3rd — will play an important part in this process.

In a related development last week, Senator Tom Udall (D-NM) announced an initiative to encourage the FCC to provide E-rate support for Wi-Fi on school buses. Jessica Rosenworcel has reportedly agreed to work with Senator Udall on this effort, and had mentioned the idea in a presentation earlier this month. (See discussion in our newsletter of September 12th.)

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

Recent EPC and Related System Problems:

For the past two weeks, in particular, EPC users — including PIA reviewers — have encountered “intermittent delays and outages.”  USAC has been posting updates on these problems in the Latest News section of its website and in a Special Edition News Brief of September 22nd. USAC indicated that it has identified, and has been or will be fixing, some of the root causes of the system degradation. However, “certain functions…are particularly resource intensive” (i.e., dependent on system loading). As a result, USAC is encouraging service providers to download funding wave data as they become available, not retroactively in bulk. Further, as indicated above, USAC will now be processing system-intensive funding waves on Sundays (ready for Monday’s early morning release) rather than during normal business hours.

EPC system issues also appear to be affecting related systems outside of EPC including USAC’s new FY 2016 FRN Status Tool (“FST”). (See our newsletter of September 19th.)  Wave 13, which would normally have been available in the FST on Tuesday, was not posted until Saturday (but was available in the Search Commitments tool). We have also noticed that funding data currently included in the FST does not appear to include new FRNs generated during PIA. In particular, note the following:

  1. Traditionally, FRN splits are the most common reason that new FRNs are created during (or after) PIA review.
  2. Within EPC, changes in service types (e.g., from IC to BMIC) apparently require cancelling the original FRN(s) and creating new FRN(s) citing the correct service type. Pre-EPC, this could be done by simply updating the original FRNs.

Ongoing system issues are a reminder that EPC is a work in progress. Although a new system is planned as of FY 2018 (or FY 2019), constant USAC attention is required to keep EPC running as smoothly as possible.

E-Rate Updates and Reminders

Upcoming 2016 E-Rate Deadlines:

September 30 Service delivery deadline for the receipt of non-recurring services (i.e., installation or other one-time charges) for FY 2015. Requests to extend the service delivery deadline, if required, must be made on or before this date. (See our newsletter of September 19th.)
October 21 FCC deadline to submit nominations for six directors on the USAC Board. (See DA 16-1018 or our newsletter of September 19th.
October 28 Invoicing deadline for recurring service charges for FY 2015. Applicants planning to file for BEAR reimbursements need an active PIN and must have filed (subject to approval) a Form 498. Completion of either of the preceding steps can easily take two or more weeks. (See our newsletter of August 29th.)  Invoice deadline extension requests (“IDERs”) must be made — and are recommended to be made — on or before this date. (See our newsletter of September 12th.)
October 31 Form 486 deadline for FY 2016 funding committed in Waves 1–2. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (often July 1st), whichever is later. This means that Form 486 deadlines for funding received in later waves will follow at roughly one week intervals, including the following November deadlines:

Wave 3        11/07/2016
Wave 4        11/14/2016
Wave 5        11/21/2016
Wave 6        11/28/2016

November 3 FCC deadline for submitting comments on the Boulder Valley and Microsoft petitions regarding off-campus use of existing E-rate supported connectivity. (See DA 16-1051 and article above.)

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.        Invoice USAC for Reimbursement and Learn About the New Invoicing Process

USAC Fall Training Schedule:

USAC’s annual fall applicant training begins today with a session in Washington, DC. The locations and dates for USAC’s other regional trainings are listed below. For registration information, see Trainings & Outreach.

Buena Vista, 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 (waiting list only)

Slides for the DC training have been posted on the USAC website.

USAC News Brief Dated September 23 – Invoice and Service Delivery Deadlines

USAC’s Schools and Libraries News Brief of September 23, 2016, provides additional information regarding the invoice and service delivery deadlines described above.


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.