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E-Rate Central News for the Week
July 31, 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 9 for FY 2017 was released Friday, July 28th, for a total of $77.7 million. Cumulative national funding through Wave 9 is $616 million. Wave 10 is scheduled to be released on Friday, August 4th.

FY 2016:

Wave 56 for FY 2016 was released on Tuesday, July 25th, for a total of $2.78 million.  Cumulative national funding through Wave 56 is $2.82 billion. Wave 57 is scheduled to be released on Tuesday, August 1st.

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

Avoiding Form 486 Certification Errors:

It is always a good idea to read E-rate certifications before blindly checking all the boxes and certifying a form. On many E-rate forms, all or most of the certifications apply and must be checked prior to filing.*  For a Form 486, on the other hand, the majority of the certifications do not apply to a given applicant. To the contrary, the certifications are tailored to applicant-specific situations — unfortunately not well defined in the online EPC system.**

From a processing standpoint, USAC apparently recognizes that the certifications may be confusing and it does not automatically reject or deny Form 486s with wrong or inconsistent checkmarks. However, USAC does flag these Form 486s for review. Currently, there is a significant backlog of Form 486s under review, and neither applicants nor service providers can submit FY 2017 invoices until the associated Form 486s are approved by USAC. Therefore, it pays — quite literally — to get Form 486 certifications right from the beginning.

A list of possible Form 486 certifications (with our numbering in red) is provided below, followed by explanations of each.

Form 486 certifications

Certifications #1 and #2 — the first to appear during EPC’s Form 486 certification stage — generally do not apply. In particular:

  1. Based on its wording, certification #1 is particularly tempting to check, but its applicability is limited. Normally, a Form 486 cannot be filed until the services covered by the FRN(s) have already started, i.e., no earlier than July 1st. Certification #1 is to be used only by applicants who have been funded before the funding year begins, who want to file their Form 486s early, and who can assure USAC that the services will start sometime during the first month. Anyone filing a Form 486 on or after July 1st should not check this certification.
  2. Certification #2 should be used only in very special circumstances — ones we have never experienced — in which state or local procurement rules conflict with CIPA regulations.

Certifications #3, #4, and #5 are most commonly the only certifications used by CIPA-compliant applicants receiving Internet and/or any Category 2 services. Most importantly, they attest to the facts that:

  1. The certifier is authorized to file the Form 486.
  2. Related documentation, including all procurement material will be retained for at least 10 years after the service is delivered.
  3. The applicant is CIPA compliant.

Applicants applying for E-rate for the first time may be granted a one-year waiver of CIPA requirements as long as they are “undertaking” actions to become compliant. Three certifications address such a waiver, namely:

  1. Certification #6 is used by individual applicants to indicate they are currently undertaking actions to become CIPA compliant and will be in compliance next year.
  1. Certification #10 is used by consortium applicants to indicate that one or more of their members are not yet CIPA compliant.
  2. Alternatively, certification #11 indicates that no consortium members are seeking CIPA waivers.

CIPA compliance is not required if an applicant is applying for discounts on telecommunications services only. This exception applies even if the telecommunications services are used to provide Internet access services if, and only if, the applicant does not apply for E-rate discounts on the Internet service itself. Two certifications deal with the telecommunications-only situation, namely:

  1. Certification #7 is used by individual applicants applying only for telecommunications discounts.
  2. Certification #8 is used by consortium applicants applying only for telecommunications discounts.

Before a consortium applicant can certify a Form 486, it must first collect Form 479s from each of its members. Essentially, a Form 479 requires each member to certify CIPA compliance to its consortium leader so that, in turn, the leader can certify compliance in a Form 486 on behalf of all its members. A Form 479 is an unusual E-rate form in that it is filed — on paper, not online — with the consortium leader, not with USAC. As a result:

  1. Certification #9 is used by consortium applicants to confirm that they have collected completed Form 479s from all their members. It is obviously important for consortia to retain copies of all Form 479s received in the event of future audits.

Important note: Applicants whose EPC accounts are accessed for forms preparation and submission by different users must recognize that anyone preparing a form can check the proper certifications. But, once that form is sent to another person for certification, those checkmarks are deleted. The final form certifier must complete the certifications anew.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Deadlines:

August 7 Form 486 deadline for FY 2016 funding committed in Wave 41. 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 42        08/11/2017
Wave 43        08/18/2017
Wave 44        08/25/2017

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.

August 7 Last day to file reply comments on the FCC’s Proposed Eligible Services List for FY 2018 (DA 17-602).
Sept. 30 Service delivery deadline for the receipt of non-recurring services (i.e., installation or other one-time charges) for FY 2016. Requests to extend the service delivery deadline, if needed, must be made on or before this date.

USAC News Brief Dated July 28 – Corrections

USAC’s Schools and Libraries News Brief of July 28, 2017, notes several corrections regarding invoice deadlines that were discussed in the previous week’s News Brief. A revised version of the June 21st News Brief has been posted. However, the revised version still references a FY 2016 recurring service invoicing deadline of October 28, 2017, that is not technically correct. October 28th this year is a Saturday, thus extending the actual deadline to Monday, October 30th.

Last Friday’s News Brief also notes that the presentation slides for USAC’s July 25th service provider training in Dallas will be posted to the USAC website later this week.

 

*   Hint: Be careful to answer “No” to the two service provider funding questions on a Form 471.

**   Form 486 Instructions are available on the USAC website under the Reference section, not under the Forms section.

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.