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July 27, 2015


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 (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 10 for FY 2015 will be released on Friday, July 31st. Funding for FY 2015 is available for both Category 1 and Category 2 at all discount levels. Cumulative funding for FY 2015 as of Wave 9 is $834 million.

Wave 62 for FY 2014 will be released on Wednesday, July 29th. Funding for FY 2014 is available for Priority 1 services only. Priority 2 funding has been denied at all discount levels. Cumulative funding for FY 2014 is $2.26 billion.

USAC has completed the initial roll-out of its new online E-rate portal system, the “E-rate Productivity Center” or “EPC” (pronounced “Epic”). The EPC portal will ultimately be used for all electronic E-rate news, contacts, and filings. Most immediately, the EPC must now be used by all applicants seeking to file Form 470s for FY 2016. It is important, therefore, for applicants (and their consultants if they use one) to get their EPC accounts established as early as possible in the FY 2016 application cycle.

This article is the third in a series of updates on EPC. The system itself is still under development. As such, the system exhibits a number of bugs and quirks that are being addressed by USAC on an ongoing basis:

  1. The list of applicant entities shown when an EPC account is established may not coincide with the Block 4 entity list from the applicant’s FY 2015 application(s). This is a particular problem for a larger applicant because there is no easy way to download the EPC entity list for comparison with a current entity list. We have noticed that the EPC list may under-report the actual number of entities by 10% or more, including missing non-instructional facilities (“NIFs”). Adding or deleting entities within the EPC portal can only be done by the account Administrator. Alternatively, requests to add entities can be submitted to USAC, individually or in spreadsheet format, using the portal’s Customer Service Request function.
  2. Heavy users of the EPC portal are occasionally running into a message reading: “You cannot log in because you have reached the maximum allowed number of concurrent sessions.”  This apparently occurs when users are going in and out of EPC by simply closing their browsers (which does not actually end the sessions). This is normally a temporary problem because each session does time-out for lack of activity, but it is one that can be avoided entirely by formally logging out. To log out, click on your name in the upper right-hand corner of the screen and select “Sign Out.”
  3. When working on a new Form 470 within the EPC portal, it is important to choose the correct “Save” option if multiple users are assigned to the EPC account. There are two choices: “Save and Share” or “Save and Continue.”  The “Save and Share” option creates a “Task” for everyone in your organization who has partial or full rights in the EPC portal. This permits those users to view and/or modify the draft Form 470. The “Save and Continue” option, on the other hand, limits continued work on the draft Form 470 to that one specific user. If any user views and/or modifies a shared draft Form 470, but does not “Save and Share” it before exiting, the form is no longer shared. It is neither listed nor viewable as a “Task” for the other users.
  4. Once a Form 470 is submitted, there are a number of display issues. In particular:
    1. To see a completed Form 470, select “FCC Form 470” under the EPC “Records” tab. This brings up a list of all Form 470s filed for FY 2016. This list is virtually useless because it shows only the form’s “Nickname” and Form 470 number, not the applicant name and/or BEN. There is a search function, but the search is limited to the form’s name and/or number, again not the applicant’s name or BEN.
    2. Note that the two large letters or numbers displayed to the left each Form 470 are meaningless. They are simply the first two characters in the form’s “Nickname.”
    3. To narrow the list to Form 470s of interest to a specific applicant or consultant, click on the “Yes” (even though it’s not highlighted to look like a hot link) on the left side of the screen under the heading “Filed by my Organization(s)?”.
    4. Another way to reference an applicant’s completed Form 470 is to start on the applicant’s “Organization Details” page (reached by searching the “Applicant Entities” list under the “Records” tab. Next, click on “FCC Form 470” on the left side of the screen. The default setting on the next page shows “FCC Form 470 Details” for FY 2016.
    5. Just for fun, change the “View” to “FCC Form 470 Trend Over Time” and check out the FY 2015 to FY 2016 trend. This may someday be useful, but the EPC system does not currently include any Form 470 data for FY 2015 or earlier. As a result, the resulting graph for an applicant who has filed one Form 470 for FY 2016 looks as follows:
      E-rate FCC Form 470 trend over time
    6. The information displayed in a completed Form 470 includes the dates on which the form was created, certified, and last modified. It does not, however, display the critical Allowable Contract Date (“ACD”). Because the 28-day waiting period is so important, the Form 470 should show the earliest date at which an applicant can close the bidding, select a vendor, and sign a contract. Please be careful when calculating the ACD. Here are two tips:
      1. Open an Excel sheet, and enter the Form 470 submission date in Cell A1. In Cell B1, use the formula “=A1+28” to calculate the ACD. Using today as the submission date in A1, for example, the ACD will be shown in B1:
          A B
        1 7/27/15 8/24/15
      2. On a calendar, count off four weeks. The 28-day ACD will always fall on the same day of the week as when the Form 470 was submitted. As above, for example, July 27th and August 24th are both Mondays.
    7. The other source of Form 470 data for FY 2016, available outside EPC, is similarly lacking. As discussed in the S&L News Brief of July 17, 2015, USAC added two additional Search Tools to its SLD website providing the capability to View an [individual] FCC Form 470 or Download 470 [aggregate] Information for FY 2016. The list of individual Form 470s shows only the 8-digit form number (and associated RFP links), not the applicant name and BEN. Again, the ACD date is not shown and must be calculated from the “Certified Timestamp” date shown on the final page of each PDF. The list itself is apparently not being updated daily, so service providers relying on this data source may miss a week or so of the minimum procurement cycle. As discussed in our newsletter of July 20, 2015, the Form 470 download tool for FY 2016 is cumbersome (and doesn’t include even the certification date from which to calculate the ACD).

Applicants who have not received an email invitation to establish an EPC account must formally contact USAC by email or fax. USAC has provided the following information and instructions on EPC account formation for applicants, service providers, and consultants:

USAC created accounts for account administrators in EPC based on information from recently certified program forms. The account administrator for an account must have a non-generic email address in our system and be:

  • For an applicant, the authorized person on an FCC Form 471 for FY2015 (independent school, independent library, school district, library system, consortium, or statewide applicant).
  • For a service provider, the Schools and Libraries contact on the most recently updated FCC Form 498
  • For a consultant, the main contact for the consultant organization.

We sent each account administrator an invitation email from “” with the subject line "USAC EPC Account Creation."

If the authorized person for an applicant entity did not receive an invitation email, you can submit a written request to create a new user account and assign account administrator rights.

Please note: We can create an AA account for an employee of the organization who has authorization to certify program forms and conduct other business on behalf of the organization; i.e. an authorized signer but not a contact person.

Please send the request via email to or via fax to 888-276-8736.

The request must be made on entity letterhead and contain the signature of the authorized person who is to be the account administrator, and it must be accompanied by a copy of your Letter of Agency.

The request must include:

  1. Billed entity number
  2. Account administrator’s name
  3. Account administrator's job title
  4. Address
  5. Phone number
  6. Email address: Since the EPC user account will act as your signature, we require that the e-mail address contain the authorized person’s name; i.e. it cannot be generic such as

USAC’s Data “Clean Up” Effort:

A Special Edition News Brief of July 21, 2015, announced that USAC will soon begin an effort to verify Category 1 data on FY 2015 Form 471s. The “clean up” is supposed to be conducted independent of the PIA process, but is likely to be related in some way to applications for which there are apparent discrepancies between the services as described and the bandwidth and/or prices of those services. Applicants who have already been funded may receive questions as well. Outreach will be by email and will request a response within five days.

AT&T, LCP, and FCA:

An interesting article appeared in ProPublica last week entitled “Judges Revive Claim that AT&T Overcharged Schools for Internet Service.”  The article discusses the recent developments involving E-rate’s Lowest Corresponding Price (“LCP”) rules and the applicability of the False Claims Act (“FCA”) to E-rate as funds. The specific claim referenced in the article’s title is one filed by Todd Heath, a Wisconsin telephone auditor, alleging LCP overcharging by AT&T and its subsidiaries. A good summary of the history of this case was provided over two years ago in another ProPublica article discussed in our newsletter of May 7, 2012. Interestingly, last July, an appeals court in San Francisco decided (on relatively narrow grounds) that E-rate funds were not “federal funds” and were not subject to FCA (see our newsletter of July 14, 2014). This appears to be at odds with this recent appeals court decision in the District of Columbia. Stay tuned.

USAC Fall Applicant Training:

As in recent years, USAC will hold eight regional one-day applicant training sessions this fall. Registration at this point is assured in only half the locations. The full training schedule with registration links is as follows:

Washington, DC October 2 – registration (including waiting list) is full
Tampa, FL October 8 – available only on a waiting list basis
Albuquerque, NM   October 13
Minneapolis, MN October 20 – registration limited
New Orleans, LA October 29 – available only on a waiting list basis
Los Angeles, CA November 5 – available only on a waiting list basis
Philadelphia, PA November 10 – registration limited
Portland, OR November 16

The S&L News Brief of July 24, 2015, reviews the strict relationship required within the EPC system for unique user names and email addresses on an account-by-account basis. It addresses the following questions:

  • Why do I use my email address as my username?  Brief answer: It’s a system requirement.
  • Can I have two different email addresses in EPC?  Brief answer: Yes, if needed for separate applicants.
  • What happens if I change my email address?  Brief answer: Register the new address; deactivate the old address.
  • What if I want to keep my existing email address but I am now working for a different organization?  Brief answer: A new address is needed for the new organization.
  • I am a consultant. Do I have to have a separate email address for each of my clients?  Brief answer: No.
  • Can I allow someone else to log in to my account using my email address and password?  Brief answer: No.
  • Can I use a generic email address to establish my account?  Brief answer: No (but the restriction is under review).