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E-Rate Central News for the Week
October 16, 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 20 for FY 2017 was released Thursday, October 12th, for a total of $57.0 million. Cumulative national funding through Wave 20 is $1.49 billion. Wave 21 is scheduled to be released on Friday, October 20th.

FY 2016:

Wave 65 for FY 2016 was released Tuesday, October 10th for a total of $1.06 million. The cumulative national funding through Wave 65 is $2.88 billion. Wave 66 is scheduled to be released on Tuesday, October 17th.

Update on Bundled Internet Access and Transport

USAC’s guidance on Form 470 requests for bundled Internet access and transport services was changed last week during the first of USAC’s fall training workshops in Washington, DC, — apparently at the direction of the FCC. The change was not included in any of the training slides, but became apparent during a Q&A session. It is not yet reflected in any written USAC material.

Here is the current Form 470 guidance on bundled Internet service requests as we now understand it:

  • If you are seeking Internet access service, and the Internet service provider (“ISP”) will be providing a non-fiber connection (e.g., DSL) to deliver that Internet service, the only Form 470 drop-down menu option required is “Internet Access and Transport Bundled.”
  • If, however, the ISP will be providing a fiber connection to deliver Internet access (as is often required for higher-speeds), two Form 470 drop-down options must be selected — “Internet Access and Transport Bundled” and “Leased Lit Fiber.”
  • If you don’t care what type of connection is provided, but wish to merely specify a minimum Internet speed (or speed range), you should also use both the “Internet Access and Transport Bundled” and “Leased Lit Fiber” options. Without including the “Leased Lit Fiber” option, any subsequent request for a bundled fiber-based Internet service will apparently be denied.

Prior to this change, USAC’s Form 470 guidance for bundled, fiber-based, Internet access service required applicants to include three drop-down options — “Internet Access and Transport Bundled,” “Leased Lit Fiber,” and “Internet Access: ISP Service Only.”  This unintuitive guidance, of which many applicants were unaware, traces back to the August 26th introduction of new Category 1 drop-down options in EPC’s Form 470 — ironically characterized as “simplified” (see USAC’s Special Edition News Brief of August 22nd ). The updated guidance, reducing the number of required drop-down options from three to two, will still be a source of confusion. Absent official USAC guidance reducing the required dropdown from three to two, we encourage applicants to continue to use the three-option approach.

Hopefully, USAC will provide written clarification shortly and will proactively reach out to any applicants having filed incomplete Form 470s for bundled Internet services since August 26th. Applicants having filed Form 470s prior to August 26th should not be affected by the new — and changing — guidance.

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

EPC Updates and Corrections:

USAC’s News Brief of October 13th, referenced below, summarizes some minor changes made to EPC last week affecting the Form 470, Form 486, Form 500, and entity profiles.

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Dates:

October 18 Form 486 deadline for FY 2016 funding committed in Wave 51. 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 52         10/30/2017
Wave 53         11/01/2017
Wave 54         11/08/2017
Wave 55         11/15/2017

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 (DA 17-921) on revisions to Category 2 budgets. Reply comments are due November 7th.

Note:  At least two educational associations issued warnings last week suggesting that this Public Notice might be the FCC’s first step towards cutting or eliminating funding for Category 2. We see no indication of such adverse action, hoping instead to see the FCC’s recommitment and improvements to the Category 2 funding program. We encourage interested parties to submit comments for such action.

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.

NSLP and the McKinney-Vento Act:

This has been a terrible year for hurricanes with Harvey, Irma, and Maria battering Texas, Florida, Puerto Rico, and the Virgin Islands. Some of the families impacted in these areas, many with school aged children, are relocating into other U.S. states. E-rate coordinators in states likely to receive families such as these should recognize that students who are temporarily displaced due to such disasters are usually covered by the federal McKinney-Vento Homeless Education Assistance Act detailing the educational rights of students in temporary housing. Those rights permit these students to enroll immediately in the school districts where they are temporarily living. An important element of the McKinney-Vento Act, from an E-rate perspective, is that these students may become automatically eligible for free school meals and could, in some cases, increase a district’s discount rate.

USAC Fall E-Rate Training:

USAC’s annual fall training began last week outside Washington, DC. Presentation slides from this training are available online. Additional USAC workshops will be held the following locations:

October 24 Charlotte, NC
November 2   Minneapolis, MN
November 14 Portland, OR

USAC News Brief Dated October 13 – Form 486 Reminders

USAC’s Schools and Libraries News Brief of October 13, 2017, reviews the basic process for filing a Form 486, including:

  • Starting the Form 486 in EPC.
  • Selecting the FRNs.
  • Specifying the service start dates for each FRN.
  • Not checking the early filing box (applicable only if filing before August 1st).
  • Recognizing that the CIPA waiver option is very specific and does not apply to most applicants.
  • Completing the regular program and CIPA certifications.
  • Previewing the Form 486.
  • Certifying the Form 486.
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.