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E-Rate Central News for the Week
April 10, 2017

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

Wave 41 for FY 2016 was released last Friday, April 7th for a total of $31.5 million. An estimated 126 FCDLs were issued in this wave.  Cumulative national funding through Wave 41 is $2.42 billion. Wave 42 is scheduled to be released on Thursday, April 13th.

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

RCDLs and Other EPC Updates:

Our newsletter of April 3rd summarized the updates USAC had made to EPC over the previous weekend. Those updates have now been in place for a week.

The most significant development has been the first release of Revised Funding Commitment Decision Letters (“RFCDLs”) for FY 2016. The RFCDL provides notifications to both applicants and service providers of USAC decisions on appeals, service substitutions, and SPIN changes (both corrective and operational). In some cases, these requests have been outstanding for over six months. Although USAC had been processing these requests — and there is still a backlog — USAC’s approval (or denial) of the requests could not be conveyed until the RFCDL capability in EPC became operational.

A RFCDL notification starts with an email to the applicant contact person who made the request, directing them to an EPC News Feed such as shown below.

RFCDL Notification

Within EPC, there are several ways to view RFCDL-based decisions or the RFCDLs themselves. The first source of information is the applicant’s News Feed that, including the “RFCDL Supplement,” contains almost entirely boilerplate verbiage. Details on the decision — in this example for a corrective SPIN change between two Verizon subsidiaries — can be found in the linked Excel file.

x

A specific RFCDL decision, as well as a list and status of all other applicant post-commitment changes, can be found at the bottom of the applicant’s Landing Page.

x

For documentation purposes, a record of the original change request, plus a statement of the approval, can be found under EPC’s general “Records” tab. Select the type of request, then search for the request number. In this SPIN change example, the request number is 30202 (as indicated in the News Feed’s Excel file link shown above). To view the approval status, initially showing only the funding year, click on the “View Status (+)” link to show the expanded status.

x

Information on revised funding commitments will be sent to the associated service providers in the form of pipe-delimited CSV files with one RFCDL decision per row. Providers should note that any given RFCDL may contain more than one type of decision, but that there is a limit of only one comment field per RFCDL row. In the case of multiple decisions in the same RFCDL, the comment shown will be the most important one as defined by a hierarchy developed by USAC (with appeal decisions outranking SPIN changes and service substitutions, in that order).

Other EPC changes implemented last week include:

  1. New functionality on the processing of post-commitment requests whereby all PIA and applicant correspondence is sent via EPC and remains available for applicant review.
  2. Form 486 improvements:
    1. The technology plan certification has been removed on the applicant filing system.
    2. Various problems involving service provider notification of Form 486 approvals have been resolved.
  3. The status of applicant Form 500s has been corrected, eliminating an earlier “Wave Ready” error.
  4. Functionality has been restored permitting applicants to file Receipt Acknowledgment Letter (“RAL”) modifications to submitted FY 2017 Form 471 applications. This is particularly important for applicants seeking to update entity profiles (otherwise locked down during the application window). Additional detail on the restored RAL process is available in USAC’s News Brief of March 31st.

Form 470 ACD Corrections:

USAC has fixed a critical problem in its legacy Form 470 download and viewing tools. As noted in our newsletter of April 3rd, the Allowable Contract Date (“ACD”) was being calculated one day too early. The ACD, as shown in EPC, has been correct all along. Both tools are now showing the correct required 28-day Form 470 posting period.

Users seeking to view a specific Form 470 will find View an FCC Form 470 (FY2016-17) the easier of the two legacy tools. Note, however, that the required search form fields include a Form 470 “Posting Date” range that cannot exceed 30 days. Searches over a longer date range can be performed using the Download 470 Information (FY2016-17) tool.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Deadlines:

April 11 Form 486 deadline for FY 2016 funding committed in Wave 25. 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 April deadlines:

Wave 26                04/20/2017
Wave 27                04/27/2017

Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” (actually emails directing the applicants to EPC News Feed items). The Reminders will afford applicants with 15-day extensions from the date of the emails to submit their Form 486s without penalty.

April 13 Last day to file a Form 470 for FY 2017 meeting the required 28‑day waiting period prior to submitting a Form 471. To assist applicants unfortunately needing to file Form 470s over the last three days, USAC has extended the hours of operation of the Client Service Bureau (“CSB”) until 10:00 p.m. EDT.
April 19 End date for the special FCC 30-day waiver period on FY 2015 invoice deadlines (see USAC’s Schools and Libraries News Brief of March 31, 2017).  The new 30-day extension applies only to applicants missing the October 31, 2016, invoice deadline as the result of late approvals of Form 498s or the late distribution of BEAR PINs.
May 11 Last day of the Form 471 filing window for FY 2017. The window closes at 11:59 p.m. EDT.

USAC News Brief Dated April 7 – Category Two Budget Tool Available

USAC’s Schools and Libraries News Brief of April 7, 2017, discusses its new Category Two Budget Tool. The new tool provides budget information for both FY 2015 and FY 2016, previously unavailable in a single USAC tool. Unfortunately, it does not yet calculate the remaining Category 2 budgets for schools and libraries for FY 2017. Applicants seeking FY 2017 budget limits should calculate maximum budgets for each school and library, using the inflation-adjusted cap amounts for FY 2017 (see News Brief), and subtract the committed Category 2 funding for FY 2015 and FY 2016 as calculated in the new budget tool.

Additional information on USAC’s new Category 2 budget tool can be found in our newsletter of April 3rd.

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.