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E-Rate Central News for the Week
April 17, 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 42 for FY 2016 was released last Thursday, April 13th for a total of $8.4 million. Cumulative national funding through Wave 42 is $2.43 billion. Wave 43 is scheduled to be released on Thursday, April 20th.

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

Special Construction Inquisition

On April 14th, ironically Good Friday, USAC issued a series of disturbing questions to over 100 applicants seeking special construction for lit, dark, or self-provisioned fiber. This request went to both requests still in PIA review AND funded fiber projects, with the latter being more disconcerting. USAC’s cover letter gives applicants two weeks to respond to the six-page set of questions most of which the application will not be able to answer without significant support from the service provider.  

The timing of this notice could not be worse. USAC waiting until after the Form 470 deadline to issue these questions places recipients of this letter (and other applicants with open bids) in a very precarious position.   Applicants now must hope that the USAC and/or the FCC like their responses or they may need to wait until FY 2018 to try again.    

The focus of USAC’s inquiry revolves around excess strands installed as part of lit, dark, and self-provisioned fiber projects.    Applicants who have strands that are not being lit for their use immediately, are less scrutinized if they have cost-allocated the unlit “excess strands” however to date neither the FCC nor USAC has identified the preferred cost-allocation methodology.   From a practical perspective the cost to “dig” is the same regardless of whether two strands are installed or 24 strands.   That said, we suspect FCC may expect a cost-allocation based on a pro rata basis of the entire construction costs. As we learn more about the specific results stemming from these templates we will let you know in future newsletters.

RCDLs and Other EPC Updates:

Our newsletter of April 10th discussed the first release of the Revised Funding Commitment Decision Letters (“RFCDLs”) for FY 2016. As a reminder, the RFCDL provides notifications to both applicants and service providers of USAC decisions on appeals, service substitutions, and SPIN changes (both corrective and operational). Early this week, we expect RFCDLs to appear in the FRN Status Tool or “FST”. The “Appeal Wave Number” and “Revised FCDL Date” fields will now populate as well as any modifications to the “FRN Status”, “Service Provider Name, “SPIN”, and dollar changes to any fields beginning with “Cmtd” which is short for “Committed”.  

It does not appear that any fields have been added to provide a RFCDL comment. In the past, RFCDLs would only be issued if there was a change in the funding decision, a change in the committed dollar amounts, or updates to the service provider.   Administrative Decision Letters (ADLs) would be issued for cancelled or dismissed requests and denial decisions that were upheld from the original determination. The ADL decision was never published in the Data Retrieval Tool (DRT) and its elimination poses a new challenge now that all decisions are being issued as an RFCDL.  

Specifically, without an explanation of the RFCDL decision there is no easy way for, if any, a third-party can determine the USAC’s RFCDL decision. The “Commitment Status” field which shows whether an FRN has been “Funded”, “Denied”, or “Cancelled”, lacks history tracking unlike other fields which display an “Original” and “Current” view. Fields that do have historical tracking display only the most current change. This results in RFCDL updates which over-write fields that previously contained pre-commitment PIA changes. Only those applicants and service providers who receive the RFCDL directly from USAC will be able to easily determine the outcome and changes as described in our newsletter of April 10th.

Form 471 Print Preview Bug – Missing Students:

We have identified another bug in the EPC system. When viewing the “Print Preview” version of the Form 471, the student counts of schools may erroneously indicate “0” despite the “Discount Rate” section populating correct data.

E-rate Discount Rate Calculation

While the 471 will let you certify the application it is a best practice to carefully review your 471 to ensure all of your information is displaying and accurate. In particular, the following certification may give applicants consternation if they realize that their student counts are displaying zeroes.

x

We are happy to report there is a fix despite the fix requiring the Customer Service Bureau’s (CSB) intervention. For those entities that display a zero, the root cause is blank entries in the “Total Number of Part-Time Students” and “Peak Number of Part-Time Students” fields.

x 

The solution is to enter the correct values into these fields. In this case there are no part-time students.

x

Updating enrollment information is normally a fix that an EPC user could make on their own but due to USAC’s entity profile lockdown, users are unable to make these updates and require CSB intervention. The missing student count bug affects any type of application even though Category One applications do not utilize part-time student data to calculate. Once updated, the proper student counts will populate and you will be able to truthfully certify your 471.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Deadlines:

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.
April 20  Form 486 deadline for FY 2016 funding committed in Wave 26. 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 27          04/27/2017
Wave 28          05/04/2017
Wave 29          05/09/2017

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.

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 14 – Competitive Bidding Reminders

USAC’s Schools and Libraries News Brief of April 14, 2017, discusses competitive bidding reminders.

  • Wait the Full 28 days.
  • Upload your RFP and RFP documents to your FCC Form 470.
  • You may need to restart your 28-day clock.
    • If you certified your FCC Form 470 but you are only now issuing your RFP, you must certify a new FCC Form 470 and attach your RFP to the new form.
    • If the document you are now issuing results in a cardinal change to your original form and any attached documents, you must restart your 28-day clock.
    • If the document you are now issuing does not result in a cardinal change, you do not need to restart your 28-day clock.
  • Conduct an open and fair competitive bidding process.
  • Do not accept gifts from service providers.
  • Answer questions from potential bidders.
  • Follow your state and local competitive bidding rules.
  • Give the highest point value in your evaluation to price of the eligible products and services.
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.