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August 24, 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 (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 14 for FY 2015 will be released on Friday, August 28th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015, as of Wave 13, is $1.28 billion.

Wave 64 for FY 2014 will be released on Wednesday, August 26th. 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 $2.27 billion.

This article is the fifth in a series of updates on USAC’s 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, EPC must be used by all applicants seeking to file Form 470s for FY 2016. It is important, therefore, for applicants (and their consultants, if applicable) to get their EPC accounts established as early as possible in the FY 2016 application cycle.

The EPC system is still under development. There are changes — and/or new things we’re learning — weekly. This week’s update is as follows:

  1. Early users, who established their EPC accounts in June, have begun receiving email notices warning them that their initial passwords will be expiring within 7 days and will have to be reset. An annoying, but apparently inherent, characteristic of the new system is that individual passwords must be changed every 60 days. Those not involved with E-rate on a day-to-day basis, who are registered as users primarily for informational purposes and/or who are likely to access the system only occasionally to certify forms, may find that they have to reset their passwords almost every time they log in.

    Passwords must be eight characters or more in length, including at least one upper and lower case letter, a number, and a special character. The system may limit the reuse of passwords. Our suggestion is to develop a password format beginning with the required character types and ending with a numeric suffix (perhaps a 4-digit date) that can be changed each time. One unintended consequence of the 60-day reset requirement but not a best practice — is that many EPC users may start taping their current passwords to their monitors.
  2. We suspect that roughly 75% of all applicants have yet to establish their EPC accounts — a situation that will hopefully begin to change for the better when schools are back in session. Last week, as a part of an outreach program, USAC sent emails to a number of E-rate consultants seeking assistance in identifying and contacting prospective account administrators for clients who did not provide valid email addresses.
  3. One of the nice features of the new EPC system is that it can automatically generate email reminders for users. Applicants who filed Form 470s for FY 2016 earlier in July, for example, have begun receiving notices that the Allowable Contract Dates (“ACDs”) for those forms have been reached. The notices:
    1. Indicate that the applicants may now close their competitive bidding processes (unless otherwise required by state and/or local procurement rules).
    2. Indicate that the next steps are to evaluate the bids received, select the winning providers, and enter into legal binding agreements or sign contracts.
    3. Provide direct links to the applicable Form 470s.
    The direct links to specific Form 470s are particularly useful because one of the worst features of the EPC system (in its current stage of development) is the difficulty of finding specific Form 470s from the general list of filings. As listed in EPC, Form 470s are identified only by the nicknames given by the applicants and by the USAC-assigned Form 470 numbers. To see more useful information, such as applicant name or types of services requested, it is necessary to click on each Form 470 individually. The ACD notifications sent to the applicants are particularly nice because the Form 470s, as displayed in EPC, show only the filing dates, but do not calculate the later 28-day ACDs.

    Form 470s for FY 2016 can be accessed outside of the EPC portal, but the process is a bit cumbersome. Individual Form 470s can be viewed via the View an FCC Form 470 (FY2016) tool, again in a list without any easily identifiable designations. Bulk downloads of Form 470 data are also available using the Download 470 Information (FY2016) tool. This produces four ZIP files containing an assortment of Form 470 data, but there are several problems, namely:
    • To view the data in any usable format, it is necessary to convert the files from pipe-delimited format into field separated Excel format, then merge the four files.
    • The list of Form 470s available is only reasonably current.
    • Not all important Form 470 data is included. Of particular importance to potential bidders, for example, the data files show neither the Form 470 filing dates nor the ACDs.
    Currently, there are less than 70 Form 470s filed for FY 2016, so the problem is manageable, but the situation will become increasingly problematic as the year goes on.

FCC Planned IT System Outage:

The FCC announced (DA 15-940) that it will be performing Information Technology upgrades and improvements early in September which will shut down most of the Commission’s resources normally available through its website. The website itself will remain operational, but with “reduced content and limited search capabilities.”  The most important impact for certain E-rate filers will be that statutory filing deadlines, such as appeal windows, otherwise scheduled during the shutdown period will be extended by the same number of days.

The S&L News Brief of August 21, 2015, is the fourth in a series of News Briefs discussing the basic process of filing a Form 470 for FY 2016. Part 1 discussed setting up an EPC account and beginning a Form 470. Part 2 and Part 3 covered requesting Category 1 and Category 2 services, respectively.

Last Friday’s News Brief discusses the option of specifying a separate technical contact and/or identifying any state or local procurement requirements.

The critical point to note is that a Form 470 for FY 2016 can be filed only through USAC’s new E-Productivity Center (“EPC”). To do so, an applicant must have an established EPC portal account.