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E-Rate Central News for the Week
October 24, 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.

Important: October 28th Invoice Deadline

Applicants in danger of missing the October 28th invoice deadline for FY 2015 recurring service discount reimbursements must file an extension request by the same date (see discussion and references below).

Funding Status – FY 2015 and FY 2016

FY 2016:

Wave 17 for FY 2016, released last Monday, totaled $81.3 million.   Cumulative national funding through Wave 17 is $775 million. Wave 18 is scheduled for release today, October 24th.

FY 2015:

USAC will release Wave 67 for FY 2015 on Thursday, October 27th. Cumulative funding through Wave 66 is $3.31 billion.

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

New FRN Invoice Deadline Extension Tool:

As discussed below, October 28th is both the deadline for filing FY 2015 recurring service invoices and/or the deadline for filing Invoice Deadline Extension Requests (“IDERs”). Until recently, the preferred method for filing an IDER, for one or multiple FRNs, was via the Submit a Question feature on the USAC website. One problem with this approach has been that all the requests were handled manually, delaying approval.

Last Friday, USAC incorporated an IDER tool within the online BEAR system providing almost instant (in most cases) IDER approvals on an FRN-by-FRN basis. Once signed in to the BEAR system, which does require a PIN, the new tool is accessed within the “Deadline Extension” tab.

Online BEAR System

Enter and “Find” the FRN desired, confirm the resulting display of FRN information, then request an extension using the “Submit” button (red arrow). The extension approval, together with the new deadline date, is quickly displayed (green arrow).

USAC Invoice Deadline Extension Request

Although you should print the approved display page out for your records, the system also quickly generates a confirming email.

Invoice Deadline Extension Request Confirming Email

Please note the following:

  1. To make sure you receive the confirming email, include no-reply@solixinc.com in your email whitelist.
  2. The new deadline is actually 122 days after October 28th, because the 120-day extension (February 25) falls on a Saturday.
  3. Requests for FRN extensions must be done one at a time. For multiple FRNs, the process needs to be repeated for each.
  4. Requests may be denied if, for example, funds for the FRN have been fully disbursed or another extension has already been granted.
  5. If you had previously submitted a list of FRNs to be extended, but they are not yet approved, you are free to request them using the new tool. The earlier bulk requests will then be denied as duplicative.

This is a great addition to USAC’s tools, delivered just before a critical deadline.

E-Rate Updates and Reminders

Upcoming 2016 E-Rate Deadlines:

October 28 The invoice deadline for recurring service charges for FY 2015 is this Friday. Applicants planning to file for BEAR reimbursements need (1) an active PIN, and (2) an approved Form 498. Completion of either of these two steps can easily take two or more weeks. Additionally, before BEARs can be filed, applicants must make sure that the service providers associated with each BEAR have themselves filed their Service Provider Annual Certifications (Form 473s) for FY 2015.

If BEARs cannot be filed by the October 28th deadline, applicants must file IDERs on or before this date. Late IDERs, regardless of reason, are now being routinely denied by the FCC.

For details, please see our newsletter of September 12th, the Schools and Libraries News Brief of October 14, 2016, and the discussion above of USAC’s new IDER tool.

October 31 The Form 486 deadline for FY 2016 funding committed in Waves 1–2 is next Monday. 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 commitments 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   The 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 our newsletter of September 26th).

T-Mobile’s “Homework Gap” Settlement:

The FCC reached a settlement agreement with T-Mobile last week addressing “inadequate disclosures of ‘unlimited’ data plan restrictions.”  The most interesting aspect of the settlement is a requirement for T-Mobile to provide free student devices and low cost Internet wireless support for up to 80,000 students beginning next fall. A specific goal of the “Investment in Youth Program,” as set forth in the Order (DA 16-1125), is to “bridge the homework gap.”

Student provisions:

  1. Devices (e.g., tablets) and wireless Internet services to the students (and their families) will be free.
    1. The actual devices are intended to be valued in a range of $80–200 (as selected by the school).
    2. The wireless service must include 2 GB of data per month at the highest speed offered by the local T-Mobile network (followed by reduced speed for the remainder of the monthly cycle).
    3. The students receiving free devices and services will apparently be selected by the participating schools.
  2. The Internet service must be filtered to “comply” with CIPA. (Note: Because the Internet will be provided by T-Mobile, not through the school, it is not immediately clear how CIPA compliance will be determined — and by whom.)

School and/or school district provisions:

  1. School participation is limited to those with a student population of 40% or greater enrolled in the free and reduced lunch program (and where T-Mobile has 4G LTE coverage over at least 80% of the school’s geographic enrollment zone).
  2. Participating schools must commit to train relevant teachers and administrators in how best to utilize the devices and the wireless service. T-Mobile must provide “reasonable and appropriate training and technical assistance to the schools free of charge.”
  3. Although monthly service is free to the students, the cost to the schools (presumably not E‑rate eligible) is set at $10/student/month. Upon request, schools may qualify for a waiver of the monthly service charges.

FCC Decision Watch:

The FCC granted appeals for 69 applicants whose funding had been reduced as the result of late-filed Form 486s. The appeals, filed as early as mid-2013, covered FY 2009 through FY 2015.

To review:  The normal deadline for filing a Form 486 is 120 days from the later of (a) the start of service (typically July 1st), or (b) the funding commitment date. If a Form 486 is filed late, USAC will reset the service start date to one calculated as 120 days before the actual filing date, and will adjust any recurring service funding commitment amount accordingly, even to zero.

The good news for applicants affected by last week’s Order (DA 16-1205) is that their funding will be restored. The bad news for everyone is that the FCC took this opportunity revisit its approach to granting relief for late Form 486s going forward, specifically for appeals filed with either USAC or the FCC after January 30, 2017.

Thereafter, the FCC ruled that “…absent extraordinary circumstances, we will only grant appeals of USAC decisions denying or reducing funding for late-filed FCC Forms 486 where petitioners have 1) sought an extension of the FCC Form 486 deadline no more than 120 days after the last day to receive the E-rate supported service at issue, and 2) demonstrated good cause justifying the late submission of the FCC Forms 486.”

The FCC based its decision to tighten the appeal deadline on the need to make unused funds available to other applicants. This is the same rationale it used to restrict grants of IDERs after the initial invoice deadline.

In actuality, tying the Form 486 appeal deadline to 120 days after the last date to receive service (the end of the funding year for recurring services) is stricter than the IDER deadline because invoice deadlines, in the case of late FCDLs, may be later than that. Under the new rule, late-funded applicants will have to be particularly careful not to miss their Form 486 deadlines. Note also the FCC’s use of the phrase “absent extraordinary circumstances,” the same language the FCC is now applying to late-filed IDERs. We have seen no recent examples of circumstances that the FCC has considered “extraordinary.”

Last week’s order is but another step in the FCC’s move to tighten E-rate deadlines — another cautionary lesson for E-rate applicants.

USAC Fall Training Schedule:

The locations and dates for USAC’s remaining regional trainings are listed below. For registration information, see Trainings & Outreach.

San Juan, PR Thursday, October 27, 2016
Minneapolis, MN Tuesday, November 1, 2016 (waiting list only)
St. Louis, MO Thursday, November 10, 2016 (waiting list only)
Seattle, WA Wednesday, November 16, 2016 (waiting list only)
Los Angeles, CA       Friday, November 18, 2016 (waiting list only)

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

USAC News Brief Dated October 21 – FY 2015 Invoices and IDERS

USAC’s Schools and Libraries News Brief of October 21, 2016, reminds applicants about the October 28th invoice deadline for FY 2015 recurring service discounts. It announces the new Invoice Deadline Extension Request (“IDER”) Tool, discussed above, and provides the following pre-BEAR filing tips for applicants:

  1. Verify that your service provider has filed a Form 473 (“SPAC”) for FY 2015 online.
  2. Verify that USAC has approved your Form 498 if you intend to file BEARs.
  3. Request a Personal Identification Number (“PIN”) if you do not have one.

USAC also sent a separate invoice reminder Notice last Friday to a broad email list of applicants and service providers regarding the October 28th invoice 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.