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E-Rate Central News for the Week
July 3, 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 and FY 2017

FY 2017:

Wave 5 for FY 2017 was released Tuesday, June 27th, for a total of $23.4 million. Cumulative national funding through Wave 5 is $276 million. Wave 6 is scheduled to be released on Saturday, July 8th.

Applicants funded in Waves 1–5 should note that EPC has not yet been configured for the filing of Form 486s for FY 2017. Form 486 capability will be available shortly.

FY 2016:

Wave 52 for FY 2016 was released on Friday, June 30th, for a total of $40.4 million. Cumulative national funding through Wave 52 is $2.81 billion. Wave 53 is scheduled to be released on the 4th of July.

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

FY 2017 Funding Appeals:

USAC has indicated that the FY 2017 appeals module within EPC should be available shortly, presumably early this month. The fact that it has not been available does not affect the 60-day window for submitting appeals of FY 2017 funding decisions. For example, appeals of Funding Commitment Decision Letters (“FCDLs”) issued in Wave 1, issued May 26th, are still due by July 25th.

Although appeals can be submitted as a Customer Service case, USAC is encouraging applicants needing to appeal to wait for the implementation of the FY 2017 EPC appeals module. Filing within the EPC appeals module will assure easier access to the associated documentation in the future.

Late-Filed Special Construction Delivery Extension Requests:

The initial deadline for completing the construction and lighting of new fiber systems for FY 2016 was last Friday, June 30th. Applicants approved for special construction discounts last year, but who missed the construction deadline, could have filed for a one-year extension. But that extension request had to have been filed by last Friday.

FY 2016 applicants, who missed either Friday’s construction and/or extension request deadlines, should request extensions ASAP by filing Form 500s. Although the extension requests filed after June 30th will be late, and will most likely require an FCC waiver, there is FCC precedent for waiving deadlines missed by only a few days or weeks. In addition, there is a strong argument for asking the FCC to accept any extension requests filed by September 30th on the basis of misinformation reflected in the EPC version of the Form 500 (see our newsletter of June 5th).

Confirming Summer Deferral Requests:

Applicants understaffed during the summer have the option of handling PIA inquiries or putting the review of their applications on hold during the summer deferral period ending the first Friday (September 8) after Labor Day. To request a summer deferral in EPC after receiving a PIA inquiry, click on the “Apply Summer and Winter Deferral” button.

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EPC will ask you to “Confirm” the deferral, but we recommend that you also send a confirming email to the PIA reviewer. We’ve noticed that EPC’s summer deferral button doesn’t always work, but that reviewers have the ability to manually place an application in a deferred status mode.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Deadlines:

July 7 Form 486 deadline for FY 2016 funding committed in Wave 37. 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 deadlines:

Wave 38         07/14/2017
Wave 39         07/21/2017
Wave 40         07/28/2017

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.

The earliest Form 486 deadline for FY 2017 will be Monday, October 30th.

July 21 Last day to file public comments on the FCC’s Proposed Eligible Services List for FY 2018 (DA 17-602).
July 25 USAC’s only service provider training this year is in Dallas. See details and registration information in USAC’s Schools and Libraries News Brief of June 9, 2017.

FCC Decision Watch:

The FCC issued another set of “streamlined,” precedent-based decisions (DA 17-618) last week. In summary, the FCC:

  1. Dismissed:
    1. Three Requests for Review or Waiver deemed as moot because USAC had already taken the actions requested.
    2. Three Requests for Waiver for not complying with the FCC’s basic filing requirements.
    3. Eight Petitions for Reconsideration, seven of which again failed to comply with the FCC’s basic filing requirements.
  2. Granted:
    1. One Request for Waiver in which the FCC determined that the applicant would have selected the same vendor if it had excluded the cost of ineligible items in its bid analysis.
    2. One Request for Review involving a corrective SPIN change.
    3. One Request for Review based on reevaluation of eligible entities.
    4. Seventy-six Requests for Waiver of the FY 2017 application deadline for Form 471s filed within 14 days of the window close.
    5. Three Requests for Review (one only partially granted) for applications involving ministerial and/or clerical errors.
    6. Three Requests for Waiver involving late-filed BEARs pending service provider certification.
    7. One Request for Waiver of the appeal filing deadline missed by a “few days.”
  3. Denied:
    1. Eleven Requests for Waiver for invoice deadline extensions (including one filed more than 12 months late).
    2. Ten Requests for Waiver for late-filed Form 471 applications filed more than two weeks late.
    3. Eight late-filed Requests for Review or Waiver.

USAC News Brief Dated June 30 – Form 486 and Form 470 Tips and Reminders

USAC’s Schools and Libraries News Brief of June 30, 2017, provides a number of tips and reminders concerning Form 486s for FY 2017 and Form 470s for FY 2018.

Form 486 Tips:

  1. Do not check every box on the form — read the text next to each checkbox carefully.
  2. Choose only the FRNs that are ready for filing.
  3. Modify the service start date(s) as appropriate.
  4. Choose the correct CIPA certification based on your situation.
  5. Review your form carefully before you certify it.

Form 470 Reminders:

  1. The Form 470 must be filed online in EPC.
  2. Some information in your organization’s EPC profile must be completed before filing a Form 470.
  3. If you issue a Request for Proposal (“RFP”) and/or other RFP-like documents, they must be uploaded in EPC to the Form 470.
  4. The Form 470 will not be posted to the USAC website, beginning the 28-day posting requirement, until the form is certified online.
  5. Your receipt notification will appear in your EPC News feed shortly after you certify your form.
  6. Service providers will be able to view filed Form 470s through EPC or through the USAC website.
  7. Form 470s for past funding years are still available on the USAC website.
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.