News of the Week

Wave 26 for FY 2017 was released Wednesday, November 22nd, for a total of $59.8 million. Funding for New York was $1.47 million for 17 applicants.Cumulative national funding through Wave 26 is $1.84 billion, including $73.5 million for New York. Wave 27 is scheduled to be released on Friday, December 1st. 

Form 486 Approval Update:

Form 486s passing a series of automated data validations are approved upon certification. Form 486s not passing these validation benchmarks are flagged for manual review. USAC only began processing its large backlog of Form 486s in late October. That process is ongoing. Applicants awaiting Form 486 approvals are most likely to receive inquiries in the following areas:

1. Pre-July Service Start Dates. Technically, an E-rate “service” cannot start before the funding year begins on July 1st. Fortunately — or unfortunately as far as E-rate forms are concerned — E-rate rules allow vendors to ship equipment and to begin installation work beforehand (January 1 for special construction of Category 1, and April 1 for Category 2). The purpose of allowing this early work is to permit the underlying services — the real “services” in the E-rate vernacular — to be available at the start of the funding year. For E-rate form purposes, dates before July 1 can be entered in a Service Start Date (“SSD”) field, but they are treated as errors. Form 486 approvals will require resetting the SSDs to July 1 or later.
2. “Early” filings. Generally, a Form 486 for any specific FRN should not be filed until the associated service has started. One exception is made so that applicants funded before the funding year begins can file early Form 486s to give their vendors time to setup discounted billing as of July. The very first certification in the Form 486 deals with this exception. It asks early-filing applicants — and only early-filing applicants — to certify that their services will begin by at least July 31st. Other applicants — indeed, most applicants — filing regular Form 486s should not check this certification. If the early-filing box is incorrectly checked, applicants will be asked to authorize unchecking the box.
   
   Note: While work can commence prior to July 1st of the Funding Year, USAC is not authorized to make payments until the start of the funding year on July 1st.
3. Incorrect CIPA certifications. The Form 486 contains several confusing, often intertwined, certifications regarding compliance with the Children’s Internet Protection Act (“CIPA”) that depend upon the services being funded and the applicants’ E-rate histories. Guidance on CIPA certifications comprise the majority of the Form 486 Instructions. USAC reviewers should be able to step most applicants through the certification correction process.

Form 498 Validation Upload:

Form 498s, used to collect applicant bank account information for direct deposits of BEAR reimbursements, need to be manually validated before approval. The most common validation approach used by USAC is to ask for a copy of a voided check to confirm bank account and bank routing numbers. Applicants who have filed and certified Form 498s, but who are awaiting bank validation, can speed the process by submitting their voided check information upfront rather than awaiting a USAC request. The proper procedure for submitting unrequested verification information was covered in USAC’s Schools and Libraries News Brief of October 6, 2017. It can be done electronically via USAC’s Upload Documents facility or via fax. In either case, applicants should include the billed entity name and number, the Form 498 ID of the certified form, and all contact information.

FY 2018 Filing Window:

The Form 471 Filing Window for FY 2018 has not yet been announced. For planning purposes, a workable assumption is that the Filing Window will open in mid-January and close in late-March.

As an important first step, USAC announced that it has completed the updates on applicant profiles based on PIA review of FY 2017 applications. Applicants can now review and update their entity profiles in EPC. This is the beginning of what in the past has been known as the “Administrative Window.”  Once USAC begins accepting FY 2018 applications, entity profiles will be locked for the duration of the Filing Window.

Upcoming 2017 E-Rate Dates:

Awaiting Formal Guidance on Form 470 Internet Options:

Status: Pending.

As discussed in our newsletter of November 6th, USAC guidance on the proper Form 470 menu options to use when applying for fiber-based Internet services continues to evolve, albeit without any published updates. For now, our best advice is as follows:

• Always include the “Leased Lit Fiber” option, whether or not transport is required.
• Use either the “Internet Access & Transport Bundled” or the “Internet Access: ISP Service Only” option, as appropriate (the only two options that actually mention “Internet”).
• Use the “Narrative” section to fully describe what you really want. Better yet, upload a detailed RFP.

USAC Fall E-Rate Training:

USAC’s annual fall training sessions were held this year in Charlotte, Minneapolis, Portland, and Washington DC. Presentation slides for the most recent training are available online. Other useful instructional videos and webinar recordings may be found in USAC’s Online Learning Library.

USAC did not issue a Schools and Libraries Program News Brief on Friday, November 24th, due to the Thanksgiving holiday.