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E-Rate Central News for the Week
October 2, 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 18 for FY 2017 was released Friday, September 29th, for a total of $68.0 million. Cumulative national funding through Wave 18 is $1.37 billion. Wave 19 is scheduled to be released on Friday, October 6th.

FY 2016:

No funding wave for FY 2016 was released last week. The cumulative national funding through Wave 63 is $2.90 billion. Wave 64 is scheduled to be released on Tuesday, October 3rd.

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

EPC’s New Look

USAC issued a Special Edition News Brief on September 30, 2017, summarizing updates it has made in the EPC user interface. The changes include:

  1. Minor style updates to colors, shapes, and fonts.
  2. Navigational changes, specifically:
    1. Filters and menus for accessing additional or more detailed information are now provided at the top of the page rather than on the left-hand side of the screen. Having selected a particular type of Record, “Applicant Entities” for example, the top of the page now shows a search box plus a choice of drop-down filters.
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    2. The old trick of always being able to click the USAC logo to return to the Landing Page does not always work because the logo is no longer on every page. When it’s not, the new trick is to first click on one of the main menu tabs (in the top blue bar), which will bring up a page with a logo, then click on the logo (i.e., two clicks rather than one).
    3. Users who have added photos to their profiles will now see circular pictures of themselves in the upper right-hand corner of their screens (users without photos will see only silhouette circles). The vain among us may want to replace their photos with ones conducive to being cropped into a circular view so as to show their entire heads.
  3. The password screen retains the same functionality, but includes brief instructional text.

Additional information on these changes will be available next week on the About EPC page and in a short video to be posted on the USAC website.

Editorial Note:  Cosmetic changes to EPC are fine, but we would have much preferred the system development time to have been spent on much needed improvements in form processing functionality.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Dates:

October 2? Saturday, September 30th, was the service delivery deadline for the receipt of non-recurring services (i.e., installation or other one-time charges) for FY 2016. As of Friday, both USAC’s News Brief (see below) and CSB advised that the Form 500 deadline to request a service delivery deadline for another year, was also September 30th. The rule, however, is that a submission deadline falling on a weekend or holiday shifts to the next business day. This would make the deadline for requesting a service delivery extension to be today, Monday, October 2nd — hopefully a date that USAC will take into account when processing extension requests.
October 4 Form 486 deadline for FY 2016 funding committed in Wave 49. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (often July 1st), whichever is later. Upcoming Form 486 deadlines for funding commitments received in later waves include:

Wave 50         10/09/2017
Wave 51         10/18/2017
Wave 52         10/30/2017

Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” in the “Notifications” section of EPC. The Reminders will afford applicants with 15-day extensions to submit their Form 486s without penalty.

October 23 Initial comments due on the FCC’s inquiry on revisions to Category 2 budgets (see below). Reply comments are due November 7th.
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.)  Requests to extend this deadline, if needed, will be automatically granted by USAC if filed on or before this date.
October 30 First Form 486 deadline for FY 2017 FRNs approved in Waves 1–5.

FCC Decision Watch:

The FCC issued another set of “streamlined,” precedent-based decisions (DA 17-928) 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 Petitions for Reconsideration having failed to provide any arguments not already fully considered by the FCC.
  2. Granted:
    1. One Request for Review on the eligibility of user licenses for interconnected VoIP systems.
    2. Four Requests for Review or Waiver granting the applicants additional time to respond to USAC requests for information.
    3. Four Requests for Review or Waiver for applications involving ministerial and/or clerical errors.
    4. One Request for Review involving late-filed BEAR(s) pending USAC actions on Form 498s, PINs, or other requests.
    5. Four Requests for Waiver of the 60-day appeal filing deadline for appeals submitted “only a few days late.”
    6. One Request for Review, partially granted, involving the eligibility of certain project management services.
  3. Denied:
    1. One Request for Waiver and/or Review on an improper CIPA certification.
    2. One Request for Review finding that study centers in residential dormitories are not eligible for support. Note: The FCC did make certain residential facilities eligible in its Sixth Report and Order (FCC 10-175) in 2010, but this appeal dealt with FY 2007.
    3. Five Requests for Waiver for invoice deadline extensions.
    4. Three Requests for Waiver for late-filed Form 471 applications filed more than two weeks late.
    5. Two Requests for Waiver or Review for late-filed Form 486s.
    6. One Request for Waiver for a late-filed appeal.

USAC Fall E-Rate Training:

USAC’s annual fall training is being provided on a more limited basis than in previous years. Although monthly webinars are planned, on-site training is available only in the following locations (including registration links):

October 10 Washington DC area (Chevy Chase MD)
October 24 Charlotte, NC
November 2   Minneapolis, MN
TBD West Coast (likely San Diego, CA)

 USAC News Brief Dated September 29 – Service Delivery and Invoice Deadline Extensions

USAC’s Schools and Libraries News Brief of September 29, 2017, notes (with one day’s notice) the basic September 30th deadline for the delivery and installation of FY 2016 non-recurring services As indicated, certain service delivery deadlines for FY 2016 are automatically extended one year based on late approvals on or after March 1, 2017, of FCDLs, appeals, SPIN changes, or service substitutions.

The News Brief also reviews the process for requesting invoice deadline extensions for FY 2016 recurring service FRNs as discussed in more detail in the previous week’s News Brief of September 22nd. The normal invoicing deadline for FY 2016 recurring services is Monday, October 30th.

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.