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E-Rate Central News for the Week
October 30, 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 22 for FY 2017 was released Friday, October 27th, for a total of $52.1 million. Cumulative national funding through Wave 22 is $1.64 billion. Wave 23 is scheduled to be released on Friday, November 3rd.

FY 2016:

Wave 67 for FY 2016 was released Tuesday, October 24th, with no funding (one application was canceled and nine others were denied). Cumulative national funding through Wave 67 is $2.88 billion.

FY 2016 funding in recent waves has been small or non-existent. Pending unusual activity, we will no longer report on FY 2016 funding on a weekly basis.

Initial Comments on the FCC’s Category 2 Public Notice

Initial comments were submitted on the FCC’s Public Notice (DA 17-921) regarding the ongoing level, structure, and application processing of Category 2 (“C2”) funding. The current budgeting process was established in 2014 under a 5-year test period with plans to revisit the issue before FY 2019. This Notice is the first step in the process. FY 2019 would be the final funding year of the 5-year budget cycle for applicants who had begun Category 2 funding in FY 2015.

The submitted comments, many of them quite short, all encouraged the FCC to continue funding Category 2 equipment and services. In our view, there is little risk that the FCC is planning to discontinue such funding, but strong public support for the program is heartening.

In general, the more extensive comments focused on two recommendations to expand and simplify the Category 2 funding mechanism, namely:

  • Replace the individual school and library budgeting process with more flexible district-wide or system-wide budgets; and
  • Increase the budget amount per student or per square foot, particularly for small rural schools and libraries.

The following links to specific comments are worth reviewing:

ALA — Extend C2 another 5 years. System-wide funding. Additional IMLS locale code.

Aruba (HP) — Funding for technical assistance, network security, and management services.

CoSN, ESH, FFL — Administrative improvements:  District-wide funding. Increased per student budget.

E-MPA — District-wide funding and increased per-student budget.

ESC 12 — Examples of C2 costs not covered by $150/student.

Friday Institute (NC) — Good data. Non-linear funding. More Wi-Fi spectrum.

Pennsylvania DOE — District-wide funding and other simplifications.

SHLB Coalition — Inter-school flexibility. Streamline Form 500 reductions. Wi-Fi on buses. Square-foot budget for special needs schools. Preferred master contracts.

SECA — District-wide funding.

Reply comments on the Category 2 proceeding are due November 7th.

New FCC Rules for Tracking Threatening Calls

The FCC issued new rules (FCC 17-132) to give law enforcement agencies immediate access to Caller ID tracking information in situations involving threatening calls to schools and certain other organizations. As discussed in several previous newsletters, this is not an E-rate issue, but is another FCC regulatory matter that may be critical to schools nationwide. Until now, access to blocked Caller ID information required a school-specific FCC waiver. Delays in obtaining such waivers obviously impeded effective and timely responses to the threats.

A “threatening call” is defined as “any call that conveys an emergency involving danger of death or serious physical injury to any person requiring disclosure without delay of information relating to that emergency.”  According to studies referenced in the FCC’s order, bomb threats to schools have increased dramatically over the past 6-7 years. The threats themselves, even if ultimately proven false, can lead to highly disruptive school closures. E-Rate Central filed comments in support of this rulemaking earlier this year.

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

Automatic Deadline Extensions for FY 2016 Non-Recurring Services:

Last week, USAC began sending out emails notifying affected applicants that their Service Delivery Deadlines (“SDDs”) for FY 2016 non-recurring services have been automatically extended. The extensions apply to applicants who received original FCDLs or subsequent RFCDLs on or after March 1, 2017. RFCDLs include approvals of appeals, SPIN changes, or service substitutions. The emails — which fall into the “better late than never” category since the original SDD was last September 30th — were clearly identified as extension notices.

E-rate Automatic Deadline Extensions for FY 2016 Non-Recurring Services

The emails, which list the affected FRNs, indicate that USAC will continue to identify any other FRNs that meet the automatic extension criteria, but warn that notifications sent to applicants’ EPC News Feeds may not feature the extended deadlines. Deadlines, when extended, should be reflected in updates to the FRN Extension Table.

FY 2016 Invoice Deadlines and Form 486 Notification Letters:

USAC’s News Brief of October 27th (also referenced below) reminds applicants and service providers that the invoice deadline for FY 2016 recurring services, nominally this Monday, October 30th, may have been extended for any applicants receiving Form 486 Notification Letters after June 30, 2017.

Unfortunately, USAC notes, its system is currently unable to automatically calculate extended invoice deadlines on the affected FRNs, so they are updating the dates manually via weekly queries. As recalculated, the new deadlines should be 120 days following the date of an applicant’s Form 486 Notification Letter. Again, as in the previous article, deadlines, when extended, should be reflected in the FRN Extension Table.

Note that this Monday’s nominal invoice deadline is also the nominal deadline for filing Invoice Deadline Extension Requests (“IDERs”). It is not immediately clear how USAC’s system will process — or will not process — IDERs filed now on FRNs with manually extended invoice deadlines. When in doubt, we recommend calling USAC’s Client Service Bureau (“CSB”) at 888-203-8100, and retaining the case number and all followup email correspondence.

New Open Data Platform:

Last Friday, USAC launched a new “Open Data” platform providing API access to the expanding data generated by the four Universal Service Fund (“USF”) programs. The site is now currently available on a beta test basis with data for E-rate and two of the other USF programs. Information on other data sets, as well as more detailed USAC information on the use of the new platform, will be available soon. A portion of the home screen is shown below.

USAC Open Data Platform for E-rate

The E-rate data currently available, accessible by clicking the blue E-rate square, includes:

  • Competitive Form 470 bidding information
    • Basic data
    • Consortium data
    • Consultant data
    • Services requested
  • Form 471 funding request information
    • Basic data
    • Connectivity data
    • Discount calculation data
    • FRN line item data
    • FRN status information
    • Recipients of service data
  • Supplemental information (including annexes)

E-Rate Updates and Reminders

Upcoming 2017 E-Rate Dates:

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.)  Important note:  Requests to extend this deadline, if needed, will be automatically granted by USAC if filed on or before this Monday. Invoice Deadline Extension Requests (“IDERs”) can be filed for specific FRNs by logging into the Online BEAR System.
November 1 Form 486 deadline for FY 2016 funding committed in Wave 53. 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 FY 2016 Form 486 deadlines in November include:

Wave 54        11/08/2017
Wave 55        11/15/2017
Wave 56        11/22/2017
Wave 57        11/29/2017

November 7 Form 486 deadline for FY 2017 funding committed in Wave 6. Upcoming FY 2017 Form 486 deadlines in November include:

Wave 7                  11/13/2017
Wave 8                  11/20/2017
Wave 9                  11/27/2017

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

November 7   Reply comments due on the FCC’s inquiry (DA 17-921) on revisions to Category 2 budgets.

USAC Fall E-Rate Training:

USAC’s annual fall training sessions have been held in Washington, DC, and Charlotte, NC. Presentation slides for the trainings are available online. Additional USAC workshops will be held at the following locations:

November 2   Minneapolis, MN
November 14 Portland, OR

USAC News Brief Dated October 27 – Update on Hurricane Relief

USAC’s Schools and Libraries News Brief of October 27, 2017 provides additional and more detailed information on the relief provided to applicants affected by hurricanes Harvey, Irma, and Maria as discussed in its September 15th News Brief and the broader USF-related FCC Order DA 17-984. Additionally, FCC Chairman Pai released a statement last week indicating that he had circulated a proposed emergency order to the other Commissioners, not yet publicized, that would further assist schools and libraries recover from the hurricanes’ devastation.

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.