BEARs and Unfiled SPACs:
Applicants working to file BEAR reimbursement invoices for FY 2017 services, particularly those associated with smaller service providers not doing much E-rate work, should check to make sure that their service providers have filed their Service Provider Annual Certifications (Form 473s or “SPACs”) for FY 2017. Although BEAR payments are now paid directly to applicants — without the need for formal supplier acknowledgment as was required before July 1, 2016 — USAC will not approve BEARs for payment unless the associated vendors have SPACs on file for the funding year(s) in which services are delivered.
Applicants expecting discounted services for FY 2018 — based on the Service Provider Invoice (“SPI”) process — may also want to check that their suppliers have current FY 2018 SPACs on file. Appropriately, last Friday’s USAC News Brief (referenced below) reminds service providers to file their SPACs for the current year.
As of last week, we counted over 740 service providers without FY 2017 SPACs. This represented about 16% of the active E-rate vendors responsible for about 1% of the total committed funding.
The easiest way to check whether or not a supplier has a current SPAC on file — short of trying to file a BEAR and having it rejected — is to check USAC’s SPIN Search Tool. The last column in the search results table indicates the supplier’s SPAC history. As an example, the display for AT&T, which has been active in E-rate since the program’s start, shows that it has already filed SPACs for FY 2017 and FY 2018. SPAC status on an FRN-by-FRN basis is also shown in USAC’s FRN Status Tool.
If your service provider has not yet filed its SPAC, the best first step is to call the E-rate contact listed in the same SPIN search result. If this effort is unproductive, USAC’s suggestion — made in response to a question on last week’s E-rate Program 101 webinar— is to file a customer service request via EPC and ask USAC to reach out to the service provider.
Correcting Form 498 and FCCRN Errors, cont.:
Last week’s newsletter discussed the occasional need for applicants to fix incorrect bank routing or account numbers in their existing Form 498s, typically because of missing leading zeros or transposed digits. Until such errors are fixed, the U.S. Treasury cannot process BEAR payments. Once the errors are fixed, applicants should receive the following confirmation (note the useful helpline numbers):
