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February 23, 2015

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.

Wave 42 for FY 2014 will be released on Wednesday, February 25th. Funding for FY 2014 is available for Priority 1 services only. Priority 2 funding is being denied at all discount levels. Cumulative funding for FY 2014 is $2.13 billion.

Wave 82 for FY 2013 will be released Monday, February 23rd. Funding for FY 2013 is available for Priority 1 services only. Priority 2 funding is being denied at all discount levels. Cumulative funding for FY 2013 is $2.13 billion.

USAC has begun sending out Form 471 Receipt Acknowledgment Letters (“RALs”) for applications that have been submitted and certified for FY 2015. Although this year’s Form 471 is dramatically different from the previous version, this year’s RAL is strikingly similar.*  It shows only the most basic information on each FRN (see sample FY 2015 RAL).

The primary purpose of the RAL is to allow applicants to review the discount rate and funding requests contained in their filed applications, and to make certain allowable corrections of Ministerial & Clerical Errors (“M&C” errors).

Simple corrections to the basic FRN information shown can be made on the RAL itself by making changes to the information on the applicable FRN page(s), and returning the corrected RAL to USAC by e-mail, fax, or mail (see instructions in the M&C errors link above).

Unfortunately, the Form 471 application for FY 2015 is much more complicated, particularly with respect to Item 21 details. This information does not appear on the RAL (nor does it appear in USAC’s Data Retrieval Tool (“DRT”). According to the RAL instructions (unchanged from previous years), “to request a correction to a field that does not appear in the attached Report, print a copy of your FCC Form 471 and clearly note your requested correction.”  The RAL can then be returned to USAC together with corrected application section(s).

The biggest problem with the RAL correction process this year is that it is no longer possible to view in detail, much less print out, many important sections of a completed Form 471. As a result, applicants may have trouble even determining that there is an error that needs to be corrected.

As an example, suppose that a school district files an FRN for Internet used by six schools and its administrative building, but mistakenly forgets to include its middle school in the list of managed entities when completing the associated Item 21. The “Display” copy of the completed Form 471 doesn’t show the entity list for an Item 21, so how is the applicant to recognize that a mistake was made?

There are several possible answers to this question, all requiring additional actions by the applicant before or after the application has been submitted. Before submission, the applicant has two opportunities to collect application details that will not appear on the “Display” version of a completed application. The applicant can either take screen shots of the various steps along the way during the online application process, or can use the “Review Application” function available just prior to submitting the application. If the “Review Application” function is used, it is important to fully expand all sections and subsections (which can only be displayed one at a time) of the application before printing out copies. To get the entity list for a specific FRN, for example, the applicant needs to:

  1. Expand “Funding Requests.”
  2. Click on the appropriate Item 21 button.
  3. Click on the little “+’ symbol at the left-hand side of the Item 21 data line.

Note that service providers are also sent RALs showing only the same basic information for the specific FRNs associated with their SPINs. The service providers will not have access to the optional pre-submission information discussed above unless it is provided by their customer.

After the application has been submitted, there appears to be only one way for applicants (and service providers) to get additional application data not found in the “Display” version of a completed Form 471 (or DRT). A new Download Form 471 Information tool is available to generate additional FY 2015 application data. Although apparently designed to collect aggregate data, it can be used to pull data on specific applications, albeit requiring a certain amount of data manipulation. The tool works on a state-by-state basis creating the following seven spreadsheets with filed application data for each state:

  1. Basic Information and Certifications
  2. Billing Account Numbers
  3. Connectivity Questions
  4. Discount Calculations
  5. Funding Request Key Information
  6. Item 21 Entity Cost Allocations
  7. Item 21 Services and Costs

Entity lists, for example, are included in the “Item 21 Entity Cost Allocations” file. The entity data, however, is provided by FRN and there are no data fields in this file for either application number or billed entity number. The applicable funding request numbers can be obtained from the RAL. Another easy source for obtaining the FRNs for a given application is to use the Funding Quick Search tool available in the upper left-hand count of each State Information page on the E-Rate Central website, drilling down to the DRT-based FY 2015 data.

Given the lack of detailed application data included in the RALs and in the “Display” versions of completed FY 2015 applications, it will be interesting to see what data is made available to PIA for application review and how the PIA reviewers will interact with the applicants.

FY 2015 Form 471 Application Window:

The FCC Form 471 application filing window for FY 2015 opened on Wednesday, January 14, 2015. It will close at 11:59 pm EDT on Thursday, March 26, 2015. Based on last Friday’s count, the number of FY 2014 applications filed to date is roughly 35% below the comparable FY 2014 filings at this time last year.

Since a Form 470 must be posted on the USAC website for at least 28 days, the last possible date to file a FY 2015 Form 470 is this Thursday, February 26th. Please remember that filing a Form 470 this late is a last resort. It would mean that vendors would have to be selected, contracts signed, and a Form 471 filed all on March 26th.

Tracking Category 2 Budgets

Category 2 budgets are limited to maximum pre-discount amounts per student for schools and per square foot for libraries over a five year period. This means that it will become increasingly important for applicants to track Category 2 funding requests and commitments by their individual schools or libraries across multiple applications and funding years. At some point, we expect USAC to develop a Category 2 tracking tool much like its 2-in-5 Tool for Internal Connections that is available for previous funding years. In the meantime, we encourage applicants seeking Category 2 funding for multiple entities to begin tracking their own school or library budget totals.

The easiest time to capture this data is just prior to the submission of an online Form 471. Once all FRNs are completed, you can use the “View Category Two Requests & Budgets by Entity” button in the upper right-hand corner of the webpage to generate a total Category 2 budget table. The table can be printed out, or the data can be cut and pasted into a separate spreadsheet. Two critical points should be noted:

  1. The Category 2 totals displayed reflect funding requests for that application only. If the applicant is applying for Category 2 funding in more than one application, data must be collected from each application as it is being prepared.
  2. Once the application is submitted, the Category 2 summary table is no longer available. The table does not appear in the “Display” view for a completed application. Nor, as discussed above, does the “Display” view show the entities associated with each Item 21. Pulling Category 2 budget data from a completed application can best be accomplished if the FRNs were originally filed on an entity-by-entity basis — in which case we recommend including the entity name or number in the FRN designator.

USAC released two S&L News Briefs last week. As outlined below, both briefs deal with aspects of the Form 471 application process.

The Special Edition News Brief of February 19, 2015, provides definitions and helpful hints for understanding and selecting the various types and characteristics of services required to complete Category 1 funding requests.

Additional information on these subjects was made available last week by EducationSuperHighway (“ESH”) in a series of FAQs on the E-rate Form 471. Separately, ESH urged applicants to pay special attention to the following three issues:

  1. Select the correct Purpose (in most cases "Internet" and "Transport" are itemized separately)
    In most cases, districts should itemize the costs for Internet connections separate from Transport connections. Only in situations where the provider offers a bundled service of both Internet connection and Transport circuits should the district select "Transport and Internet." As a reminder, Transport services (also known as WAN) are connections between buildings in a district, whereas Internet is the connection from the district to the Internet.
  2. Select the correct Type of Service (in most cases it is "Digital Transmission Services")
    For Category 1 broadband, in most cases, districts will select "Digital Transmission Services" and specify the type of connection the district is procuring for that service. "IA Only (no circuit)" should NOT be selected generically for Internet Access service. It is a unique situation where a district is paying for Internet access at the provider's point of presence separately from the physical connection to their building FROM that provider's point of presence (note that "no circuit" is the operative term).
  3. Select the correct response for WAN ("Yes" for Transport connections only)
    WAN or Wide Area Network is a service that provides the connections between buildings in a district. Districts should select "Yes" for WAN if they have a Transport connection.

The regular S&L News Brief of February 20, 2015, discusses the bid evaluation process, covering the following topics:

  • Closing your competitive bidding process
  • Disqualification reasons
  • Constructing an evaluation
  • Requesting tariffed/month-to-month services and contracted services
  • Services that do not require a Form 470 (see also the article on The FCC Exemption Traps in our newsletter of February 2, 2015)
  • Retaining documentation

*  The only real difference is the absence of the “Block 4 Entity or Worksheet No.” that is no longer needed now that the same application discount rate applies to all funding requests.