New PDF Versions of FCDL and RFCDL for FY 2018:
With the first wave of FY 2018 funding, USAC unveiled a new and much improved PDF version of the Funding Commitment Decision Letter (“FCDL”). A similar version of the Revised Funding Commitment Decision Letter (“RFCDL”) will be available to handle post-commitment decisions.
Previously, funding decisions as displayed in the EPC News feed consisted of boilerplate text, a funding summary, and a downloadable spreadsheet. The new PDF version is well-formatted and includes an introductory page showing the total application commitment.
Details of the initial funding decisions are shown on a subsequent page.
The RFCDL format will be similar, but with an additional detail column to show the type of request.
One important point to note concerning the new FCDL is that a notice and copy of the PDF will be emailed only to the person who certifiedthe associated Form 471 application. In many cases, the certifier is not the person most responsible for the day-to-day E-rate work. Although every authorized EPC user will have access to the new FCDL through the EPC News feed, key E-rate personnel may not be made aware of funding approval. Because appeal and Form 486 deadlines are determined by the FCDL date, delayed recognition of funding approval could be problematic.
This is not the first time that USAC has chosen to notify certifiers, not E-rate contacts, of important decisions — and it may not be the last. As a safeguard, applicants designating separate people for form certifications may want to establish message forwarding rules in their email systems to automatically send copies of emails from usac.org to the appropriate E-rate contacts.
Form 486 for FY 2018:
Coincident with the first funding wave, USAC updated EPC to permit the filing and certification of Form 486s for approved applications. Note that the general timing rule for filing Form 486s is that they should not be filed until services have started. However, there is an exception — and a special certification — for applications approved before the start of the funding year. The first certification permits applicants to file early Form 486s if services will begin on or after July 1st, but at least by July 31st. Early filing of Form 486s for approved applications is advantageous particularly for applicants seeking discounted bills on recurring services because it gives their vendors time to set up their invoicing systems in time to provide discounts on July’s bills.
In previous years, applicants filing early Form 486s had to be careful to not mistakenly enter Service Start Dates (“SSDs”) before July 1st of the upcoming funding year. Pre-July SSDs on Form 486s — allowed within EPC, but not under E-rate rules — would flag those Form 486s for review. Early SSDs were correctable errors, but required PIA review and typically delayed Form 486 approvals. For FY 2018, USAC has smartly modified EPC to only accept SSDs of July 1st or later.
In addition to enabling the Form 486 for FY 2018, and fixing the filing process to avoid SSD errors, USAC is already approving many submitted Form 486s and issuing approval notification letters such as the following:
