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September 16, 2019

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.

USAC released Wave 24 for FY 2019 on Thursday, September 12th.  Funding totaled $30.9 million.  Cumulative commitments through September 12th are $1.69 billion.

This week marks the beginning of USAC’s fall applicant training.  USAC will be conducting two 1½-day sessions in Washington, DC, with both sessions including beginner/general/advanced tracks.  USAC’s full applicant training series for 2019, including special tribal workshops, runs through November.  Links to the agenda and most of the slide presentations are shown below.


Applicant Training Agenda and Presentations

Half-Day Beginner Session

Full-Day General Sessions

Full-Day Beginner Track

Full-day Advanced Track

Those looking for new information in USAC’s training slides are likely to be disappointed.  The problem this fall is that USAC is awaiting several key decisions from the FCC regarding FY 2020, most importantly the:

  • Future status of Category 2 budgets;
  • Continued eligibility of managed internal broadband services, caching, and basic maintenance of internal connections; and
  • Permanent discontinuance of the requirement to amortize special construction charges of $500,000 or more.

Somewhat surprisingly, the current 2019 applicant slides do not discuss:

One encouraging slide does indicate that USAC may be ready to fully discuss the longstanding problem of how to best handle the transitional phase-in of Category 1 services throughout a funding year.  The following slide is scheduled to be discussed in the Full-day Advanced Track.  The guidance is consistent with the approach USAC has approved on a case-by-case basis, but that USAC has heretofore been reluctant to discuss more generally.

USAC How to Apply: Transitioning Services

Additional information from this week’s training sessions should be available in next Monday’s newsletter.

Upcoming E-Rate Dates:

September 16 –  
November 21
See USAC’s 2019 Training webpage for a schedule of all USAC 2019 fall applicant and tribal training sessions.
September 18 Deadline for submitting reply comments on the FCC’s draft Eligible Services List (“ESL”) for FY 2020 (DA 19-738).
September 23 Deadline for submitting comments to the USDA’s proposal to revise the categorical eligibility of families in the Supplemental Nutrition Assistance Program (“SNAP”) (FNS-2018-0037).    (See our newsletter of August 5th for E-rate implications.)
September 30 Last day to receive non-recurring services for FY 2018 and/or the deadline for requesting a one-year extension of the delivery and installation of such services.
October 28 Invoice deadline for FY 2018 recurring services.  Note:  For applicants and service providers unable to submit invoices by this date, October 28th is also the deadline for filing 120-day Invoice Deadline Extension Requests (“IDERs”).
October 28  Due date for nominations for six positions on the USAC Board of Directors (see DA 19-835) including the slot reserved for a library representative and one of the two slots reserved for school representatives.
October 29 The first Form 486 deadline for FY 2019, covering funding committed in Waves 1-10.  More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later.  Other upcoming Form 486 deadlines are:

Wave 11            11/04/2019
Wave 12            11/08/2019
Wave 13            11/15/2019

Note 1:  Applicants missing any Form 486 deadline should watch carefully for “Form 486 Urgent Reminder Letters” in their EPC News Feed.  These Reminder Letters afford applicants 15-day extensions to submit their Form 486s without penalty.

USF Quarterly Contribution Factor Reaches 25%:

Last Friday, the FCC released the Proposed Fourth Quarter 2019 Universal Service Contribution Factor indicated at an even 25.0%.  This is the first time that the USF quarterly contribution factor has reached the 25% threshold — a level likely to generate at least a modicum of political heat.

As shown in the following table, the contribution factor has been edging towards 25% for several years.

Proposed USF Contribution Factor by Calendar Year

It is important to note that the primary reason for the increasing contribution factor is not increased USF expenses.  The percentage increase is tied more directly to a decrease in interstate and international end-user telecommunications revenues, the contribution base, as long-distance toll rates continue to fall.  The contribution factor is the ratio of USF expenses (or revenue requirements) divided by the declining contribution base (or revenue base).  As exemplified in the tables below:

  • Over the past year, quarterly USF expenses rose just over 6%, but the contribution base fell almost 15%.  This drove up the contribution factor up by over 24%.
  • This past quarter, USF expenses fell slightly, but the contribution base continued its decline.

USF Quarterly Contribution Factor Changes

This is an untenable and unsustainable situation.  Ultimately, the future of E-rate and the other Universal Service Fund programs will depend on FCC — and possible Congressional — action to expand the contribution base.

 

USAC’s Schools and Libraries News Brief of September 13, 2019 reviews the following changes being made in EPC later this week:

  • New sender email address for USAC review questions — hint:  add the domain “portal.usac.org” to your safe senders list.
  • Fix for a problem experienced when uploading documents in response to certain PIA questions.
  • Automatic addition of county information to entity profiles.
  • New “Recent Information Change” notifications in News feeds, entity landing pages, and user emails.
  • Dashboard access to FCDL News posts.
  • Halt to notifications being sent to consultants removed from applicant or service provider profiles.
  • Improved state coordinator access to service substitution and SPIN Change requests and to Form 486s and Form 500s.