Upcoming E-Rate Dates:
September 16 –
November 21 |
See USAC’s 2019 Training webpage for a schedule of all USAC 2019 fall applicant and tribal training sessions. |
| September 18 |
Deadline for submitting reply comments on the FCC’s draft Eligible Services List (“ESL”) for FY 2020 (DA 19-738). |
| September 23 |
Deadline for submitting comments to the USDA’s proposal to revise the categorical eligibility of families in the Supplemental Nutrition Assistance Program (“SNAP”) (FNS-2018-0037). (See our newsletter of August 5th for E-rate implications.) |
| September 30 |
Last day to receive non-recurring services for FY 2018 and/or the deadline for requesting a one-year extension of the delivery and installation of such services. |
| October 28 |
Invoice deadline for FY 2018 recurring services. Note: For applicants and service providers unable to submit invoices by this date, October 28th is also the deadline for filing 120-day Invoice Deadline Extension Requests (“IDERs”). |
| October 28 |
Due date for nominations for six positions on the USAC Board of Directors (see DA 19-835) including the slot reserved for a library representative and one of the two slots reserved for school representatives. |
| October 29 |
The first Form 486 deadline for FY 2019, covering funding committed in Waves 1-10. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (typically July 1st), whichever is later. Other upcoming Form 486 deadlines are:
Wave 11 11/04/2019
Wave 12 11/08/2019
Wave 13 11/15/2019
Note 1: Applicants missing any Form 486 deadline should watch carefully for “Form 486 Urgent Reminder Letters” in their EPC News Feed. These Reminder Letters afford applicants 15-day extensions to submit their Form 486s without penalty.
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USF Quarterly Contribution Factor Reaches 25%:
Last Friday, the FCC released the Proposed Fourth Quarter 2019 Universal Service Contribution Factor indicated at an even 25.0%. This is the first time that the USF quarterly contribution factor has reached the 25% threshold — a level likely to generate at least a modicum of political heat.
As shown in the following table, the contribution factor has been edging towards 25% for several years.
It is important to note that the primary reason for the increasing contribution factor is not increased USF expenses. The percentage increase is tied more directly to a decrease in interstate and international end-user telecommunications revenues, the contribution base, as long-distance toll rates continue to fall. The contribution factor is the ratio of USF expenses (or revenue requirements) divided by the declining contribution base (or revenue base). As exemplified in the tables below:
- Over the past year, quarterly USF expenses rose just over 6%, but the contribution base fell almost 15%. This drove up the contribution factor up by over 24%.
- This past quarter, USF expenses fell slightly, but the contribution base continued its decline.
This is an untenable and unsustainable situation. Ultimately, the future of E-rate and the other Universal Service Fund programs will depend on FCC — and possible Congressional — action to expand the contribution base.