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E-Rate Central News for the Week
September 4, 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 2017 and FY 2016

FY 2017:

Wave 14 for FY 2017 was released Friday, September 1st, for a total of $83.8 million. Cumulative national funding through Wave 14 is $1.05 billion. Wave 15 is scheduled to be released on Friday, September 8th.

FY 2016:

Wave 61 for FY 2016 was released on Tuesday, August 29th. Cumulative national funding through Wave 61 remains $2.91 billion. A scheduled release date for Wave 62 has not been announced.

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

SPIN Change and Service Substitution Requests in EPC:

As noted in last week’s USAC News Brief, referenced below, requests for SPIN changes and service substitutions can now be filed through EPC for both FY 2016 and FY 2017. From the “Related Actions” menu on the applicant Landing Page, choose either of the following:

E-rate SPIN Change and Service Substitution Requests in EPC

Note that there are two types of SPIN changes, namely:

  • “Corrective” used to fix data entry errors, or company mergers or acquisitions, for situations in which the underlying service provider has not changed; or
  • “Operational” required — and subject to more stringent restrictions — when a new service provider has actually changed.

A service substitution requires product/service description(s) and cost(s) down to the FRN line item level equivalent to the detail provided in the initial application so as to show the new “To” service as compared with the original “From” service (automatically generated within EPC). The service substitution process also permits applicants to provide an “Optional Narrative” text and to upload “Optional Supporting Documentation.”

SPIN changes and service substitutions recognized before their associated FY 2017 applications have been approved can be handled more easily by submitting RAL corrections and/or by working with PIA reviewers.

Consortium Form 479 for FY 2018:

USAC has confirmed that the Form 479, used by consortia to certify the CIPA status of their members, will remain a paper form for FY 2018. It is neither required in nor available through EPC. Consortium applicants collecting member LOAs for FY 2018 may want to collect Form 479s at the same time. Please remember that paper Form 479s are not submitted to USAC, but are to be retained by the consortia.

A “type-in” version of the Form 479 is available on the E-Rate Central website.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Deadlines:

Sept. 7 Form 486 deadline for FY 2016 funding committed in Wave 46. 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 47         09/19/2017
Wave 48         10/02/2017

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.

Sept. 19 Reply comment deadline for the FCC’s NPRM, FCC 17-76, on the release of caller ID information in response to threatening calls to schools and other community-based organizations (see our newsletter of August 28th).
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.
October 10 USAC’s first annual fall applicant training session in Washington DC. Additional training sessions are planned in Charlotte, Minneapolis, and San Diego (dates not yet announced).
October 30 Invoicing deadline for FY 2016 recurring services. (Note: The normal October 28th deadline falls on a Saturday pushing this year’s actual deadline to the following Monday.)

FCC Decision Watch:

The FCC issued another set of “streamlined,” precedent-based decisions (DA 17-796) last week. Applicants facing similar problems as addressed in these decisions may garner useful information by carefully reading the additional FCC explanations found in the footnotes. The original appeals and waiver requests can be found online in the FCC’s Search for Filings.

In summary, last week’s FCC decisions:

  1. Dismissed:
    1. Three Requests for Review or Waiver deemed moot because USAC had already granted the request or because invoice records demonstrated that the applicants had been fully compensated for the requested funding.
    2. Five Petitions for Reconsideration (or equivalent) deemed untimely or having failed to provide any arguments not already fully considered by the FCC.
  2. Granted:
    1. Two Requests for Review or Waiver granting the applicants additional time to respond to USAC requests for information.
    2. Nine Requests for Waiver of the FY 2017 application deadline for Form 471s filed within 14 days of the window close.
    3. Two Requests for Waiver for applications involving ministerial and/or clerical errors.
    4. One Request for Waiver involving late-filed BEAR(s) pending USAC actions on Form 498s, PINs, or other requests.
  3. Denied:
    1. One Request for Review (filed in 2007) dealing with improper service provider involvement in the Form 470 competitive bidding process. In part, the FCC decision apparently relied on USAC’s findings that the Form 470 was filed from the service provider’s IP address and that the description of services required displayed “striking similarities” with other Form 470s of clients of the same service provider.
    2. Six Requests for Waiver for invoice deadline extensions.
    3. Twenty-four Requests for Waiver for late-filed Form 471 applications filed more than two weeks late.
    4. One Request for Waiver involving a late-filed appeal by a service provider arguing that, although it had been involved in a client’s invoice review, it had not been notified by USAC that the invoice had been denied until after the 60-day appeal window had expired. This decision illustrates the importance of vendor-applicant coordination on application or invoice denials.

USAC News Brief Dated September 1 – Three EPC Updates

USAC’s Schools and Libraries News Brief of September 1, 2017, summarizes three recent changes to the EPC system, including:

  • The revised drop-down Category 1 service menu in the Form 470 (see also our newsletter of August 28th)
  • SPIN changes (see discussion above)
  • Service substitutions (see discussion above)
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.