News of the Week

The FY 2015 application window will close this Thursday, April 16, 2015 at 11:59 p.m. EDT. The SLD’s Client Service Bureau will be open for extended hours until the deadline (see the S&L News Brief referenced below).

Wave 49 for FY 2014 will be released on Wednesday, April 15th. 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 $2.19 billion.

Warning:  The deadline for filing Form 471 applications for FY 2015, the next funding year, is Thursday, April 16, at 11:59 p.m. EDT. Applications completed after this deadline will be treated as being received outside the filing window and will not be funded (without a successful FCC waiver request).

For the inevitable applicants who are going to wait until Thursday to submit their Form 471s, we offer the following suggestions:

1. Historically, USAC’s online filing system has become overloaded during the last day or two. This is a new system this year, so more problems than usual would not be unexpected. If last-minute problems are experienced with the SLD’s online data entry system, it is important to document that the filing had been in process when the problems developed. In particular:
   1. We suggest periodic screen printouts — particularly of the screen that appears early in the filing process displaying the Form 471 number and security code. It is also important to call the SLD’s help line (888-203-8100) to report problems. The help line will remain open one-half hour past the 11:59 p.m. EDT deadline. If you call with a filing problem, make sure you retain the assigned Case Number.
   2. Before working on an online application, or if problems are encountered, review USAC’s Tips and Troubleshooting document. The following additional tips should be noted:
      1. The system limitation on Category 2 budgets for certain urban libraries noted in the above document has been corrected.
      2. Clearing your cache is particularly important if working on more than one application. The key combination for clearing the cache in most Windows browsers is “Ctrl” + “F5.”
      3. Use one of the recommended browsers. USAC’s official advice is to use Internet Explorer versions 9 or 10 or the most current version of Firefox or Chrome if you have a Windows operating system. If you are using a Mac, use the most current version of Safari.
      4. Use the “Review Application” feature before submitting your application. In some cases it is necessary to expand the four sections of the application in the review mode before the “Submit Application” button can be activated.
2. Remember that all Form 471s should be certified by the deadline. If the application is not certified online using a PIN, the certification must be printed out, signed and dated, and submitted by the deadline. If the application is submitted online and on time, but not certified, USAC has historically provided a reminder and a second chance to do so. If at all possible, please do not rely on this second chance as it will delay application review.

3. When mailing a Form 471 certification to the SLD, document the postmark date. If using an express mailing service (e.g., FedEx), the electronic pickup date in the tracking system serves as the “postmark.”  Make sure you know the time of the latest express mail pickup in your area.
   
   If using the U.S. Postal Service, similar advice applies. Use certified mail and make sure the certification is time-stamped before the 11:59 p.m. EDT deadline. Some post offices have earlier closing times than others. Check the USPS website to find the nearest offices and to check their business hours.
   
   Alternatively, a Form 471 certification may be faxed to the SLD at 888-276-8736. If a fax is used, make sure to print and retain a time- and date-stamped fax confirmation report showing the successful transmission of all three pages.

4. Any Form 470 referenced in a Form 471 must also be signed and certified to be valid. Applicants who filed a Form 470 online a month or two ago, but who did not electronically certify it online, should make sure that their paper certification pages have been submitted.
   
   The easiest way to confirm that a specific Form 470 has been certified is to use the Form 470 Search Posted feature on the SLD website. The first section of a posted Form 470 should show a Certification Received Date. If this field is blank, and you just mailed the certification, make sure that you can document the postmark date. If you mailed the certification a while ago, and the field is still blank, we suggest resubmitting it.

Late filers should also read the “Tips for Last-minute Filers” section of the S&L News Brief referenced below.

Petitions for Reconsideration:

The FCC issued a Public Notice last week announcing the filing of four petitions for reconsideration of certain aspects of the E-rate 2.0 rules. Oppositions to these petitions must be filed within 15 days of the date of public notice of the petitions in the Federal Register. Replies to oppositions must be filed within 10 days thereafter. The four petitions were filed on behalf of:

• AdTec, Inc. asking the FCC to reconsider (a) the elimination of data plans and air cards for mobile devices, and (b) the phase down of all local, long distance and cellular voice services.
• T-Mobile USA requesting the FCC to reconsider its guidance dealing with the cost-effectiveness and/or duplication of services for mobile broadband services.
• Cox Communications, Inc. urging the FCC to adopt additional safeguards on the expanded funding available for new fiber projects, whether leased or owned by applicants.
• WTA – Advocates for Rural Broadband et al. asking the FCC to reconsider the obligation of high-cost support recipients to bid on fixed broadband with yet-to-be-determined, national, reasonable comparability benchmark(s).

USAC Service Provider Training:

This year’s spring USAC E-rate training, designed primarily for service providers, will be held in Phoenix on Tuesday, June 2nd, and in Tampa on Tuesday, June 16th.

The S&L News Brief of April 10, 2015, provides a number of tips for filing a Form 471 application for FY 2015. It addresses the four major sections of the application, namely:

• Basic Information
• Discount Calculation
• Funding Requests
• Certifications & Signature