FCDL

Funding Commitment Decision Letters

Introduction:

Funding Commitment Decision Letters ("FCDLs") are provided to all applicants that have submitted a valid Form 471. Prior to FY 2016, FCDLs were mailed to the schools/libraries but, after the deployment of the E-rate Productivity Center (“EPC”) portal, physical letters were replaced with pdf and csv files. When an FCDL is generated, the EPC Account Administrator and users linked to the applicant’s account will receive email notification that a funding decision has been issued. The notification includes a copy of the FCDL and the csv file.These documents can also be generated in EPC.

For most applicants, FCDLs summarize the E-rate funds that have been committed and set aside for discounts that had been requested on eligible services. The FCDL lists a separate decision for each request made in the associated Form 471. In some unfortunate cases, a letter indicates rejections or removal of requested discounts on services deemed ineligible.

All decisions that are listed in a FCDL needs to be carefully and quickly reviewed in preparation of taking one or more of the following actions:

• File a FCC Form 486. In most cases, a Form 486 should be filed shortly after receiving a FCDL (see Form 486 Preparation Tips).
• Correct apparent errors (such as an incorrect supplier identification) in funding decisions and/or in the underlying Form 471.  Alternatively:
  • Appeal an SLD funding decision
  • File a FCC Form 500 to change a start or contract expiration date, or to cancel or reduce a FRN (see Form 500 Preparation Tips).

Inquiries, corrections and appeals must be made in writing to the SLD within 60 days of the date of issuance of the funding commitment decision and are to be submitted through the portal as well.

[Note: Appeals denied by the SLD can be appealed again to the FCC]

Review Items in FCDLs:

Important Warning: The most serious problem found by E-Rate Central in its review of FCDLs is that a decision was not included for every single request on the associated Form 471. Whether the requested item was funded or denied, there should be a one-to-one correspondence between the applicant's requested items and the SLD decisions. If there is a mismatch, there is an error.

This table illustrates the key information included in a FCDL (covering a single decision for a funded discount):

Almost every line of this decision is important and needs to be carefully compared with the related line item data on the original Form 471.

Based on E-Rate Central's experience with FCD reviews, here are a few key points:

• The Funding Request Number ("FRN") is a unique identifier assigned by the SLD to each requested line item on a Form 471. Henceforth, all references to this funding item - by applicants, vendors, or the SLD - should be by FRN
• If the Funding Status is not shown as "Funded," the applicant should understand why. Often, for internal connections, it will be because the SLD has deemed a portion of the equipment to be ineligible for E-rate support. This is often the case with firewalls.
• The SPIN (Service Provider Identification Number) is critical for funded items because the applicant could be getting its discount from that vendor. Discrepancies in SPINs can occur because the applicant listed the wrong number on the Form 471 or because the vendor has changed its SPIN (see below).
• The services ordered should be correctly categorized as  Internet Access, Internal Connections, Managed Internal Broadband Services and Basic Maintenance of Internal Connections. The category is particularly important with regard to discount rates and service delivery deadlines. Voice Services have been phased down by 20% each year since FY 2015. The service end date for recurring charges is June 30 while internal connections and other one-time purchases can be made up until September 30 after the funding year closes.
• The Service Start Date also varies. USAC will now allow the purchase of Internal Connection before the start of the program funding year, but no earlier than April 1. Please note that all other E-rate program rules still apply and the Form 471 must be submitted before the equipment is purchased. All recurring charges begin July 1 of the funding year.
• The Contract Expiration Date should be as initially listed on the Form 471.
• The Estimated Total Annual Pre-discount Cost should reflect the amount which is listed on the Form 471 unless changed by the SLD during the Problem Resolution or Program Integrity Assurance phases of the review process (and hopefully discussed with the applicant).
• The Committed Amount should equal the Total Eligible Recurring Charges Amount multiplied by the discount percentage. The Committed Amount is the maximum amount of money that an applicant can expect to receive via reimbursement and/or ongoing discounts.