The following is a summary of the E-rate News for the Week July 31, 2000, prepared by E-Rate Central. Official SLD news appears in the "What’s New!" section of the SLD’s Web site. Additional and archived information appears in the Archive Section on this Web site.
PY3 funding status
Wave Seventeen of Funding Commitment Decisions Letters ("FCDLs") for program year three ("PY3") will be mailed on Friday, August 4. Funding awards announced in this Wave was $55 million, including $6.1 million for NYS applicants. The funding threshold for internal connection services remained at 83%.
Cumulatively, through Wave Seventeen, the SLD has awarded funding on almost 24,000 applications totaling about $1.41 billion in discounts (including $60 million for NYS applicants). We are expecting that major funding waves will continue into September, with a few smaller funding "ripples" thereafter.
Update on pending SPIN changes
As discussed in last week’s news, the FCC has agreed, pending reconsideration of its new "Copan" rules, to let the SLD process any SPIN change that would have been approved under the older and more restrictive rules. This will permit the SLD to begin reducing the backlog of SPIN changes that have now been delayed for several months.
This week, the SLD posted a detailed description of the old (but newly effective) SPIN change rules. The information reiterates the three acceptable conditions for changing service providers, the documentation necessary to support a change, and the instructions for filing a SPIN change.
SLD reminder on PY3 reimbursements and discount billing
The "What’s New" section of the SLD Web site also includes a brief reminder that an E-rate discount can be realized either by: (a) having the applicant file a BEAR form for the reimbursement of discounts previously billed in full; or (b) having the vendor discount the bill directly. In the latter case, the vendor is reimbursed after filing a Service Provider Invoice Form ("SPIF").
The key point to remember is that, for PY3 discounts and for any given funding request ("FRN"), the SLD will accept only one type of reimbursement form. In other words, combinations of BEARs and SPIFs will not be allowed on the same FRN. If the SLD first receives an applicant’s BEAR, it will reject any SPIFs from the vendor for the same FRN. Conversely, if the SLD first receives a vendor SPIF, it will then reject any subsequent applicant BEARs.
Because of this policy of mutual exclusivity, the SLD encourages applicants and service providers to work together to determine how discounts will be processed. For the moment, the SLD has no announced policy for dealing with situations under which an applicant and vendor cannot agree. We suspect that this situation will ultimately be addressed.
Resubmitted 486s and cancelled BEARs
We have recently run into several situations in which applicants, who had submitted BEARs for PY2, were advised by the SLD that there was no record of Form 486s having been filed. Since a Form 486 must be filed before a BEAR (or SPIF) can be processed, these applicants were advised to file or, if necessary, re-file their Form 486s. Having filed new Form 486s and waiting a few more months, however, the BEAR payments were still outstanding.
Upon further investigation, it was found that the SLD had cancelled the earlier BEARs. Apparently, the SLD’s policy is to hold a BEAR for a short period of time (if no Form 486 is on file), then to simply cancel the BEAR. Unfortunately, there is no mechanism for notifying an applicant that a BEAR has been cancelled.
Any applicant submitting BEARs, and then being notified of a missing Form 486, should check back with the SLD representative who requested the Form 486 to make sure that it was received and that all outstanding BEARs are being processed. If this assurance cannot be given, or several months pass without receiving BEAR approval notifications or checks, it may be necessary to resubmit the earlier BEARs.
Application window #2 for Low Power FM
The FCC’s plan to license low power (100 watts or less) FM stations for non-commercial "educational" use remains on schedule. Last week the FCC announced that the application filing period for the second group of states would be August 28-September 1. Last June, during the first filing period, the FCC received over 750 applications, largely from religious organizations. The FCC’s Chairman has expressed a hope that more schools will take advantage of the program in the future.
The filing period for the third group of states, which includes New York, is still tentatively scheduled for late November. A formal announcement this window period is expected in early October.
Information on the FCC’s LPFM program is available on the FCC Web site.