Form 500 Limitations:
The Form 500, as implemented within EPC, has several significant drawbacks. Most importantly, USAC indicated last week that FRN changes can currently be made only for FY 2016. This limitation is not immediately obvious. To the contrary, as we pointed out in our newsletter of January 2nd, there is an easy way to change the default “No” answer to the question “Is this FCC Form 500 being filed to request a change to an FRN filed for FY 2015 and prior?” All you have to do is check “Yes,” and upload a copy of the earlier paper version of the Form 500.
We suspect that the upload feature for the older Form 500 was designed into EPC as a stopgap measure until an EPC-specific solution could be developed for earlier funding years. Unfortunately, the problem now is that OMB approval of the old paper Form 500 expired at the end of 2016. Even though you can complete and upload an older Form 500, USAC cannot process it. No timeline has been provided to upgrade the EPC Form 500 system to handle pre-2016 changes.
The most immediate and serious consequence of this limitation will be felt by applicants trying to cancel or reduce FY 2015 commitments associated with Category 2 expenditures in order to free up their budgets for FY 2017. Hopefully, a solution to the pre-2016 limitation will be available before reviews begin for FY 2017 applications.
Canceling or reducing FY 2016 commitments can be requested via the EPC Form 500, although it is not clear if USAC can yet process those requests. It should also be noted that the process for requesting FRN reductions for multi-line items with multi-entity can be burdensome. Each entity allocation for each line item must be calculated and entered separately. Unlike the original Form 471 application, no template is available to complete this process offline and upload the changes in bulk into the EPC Form 500. There is also a problem, hopefully soon to be fixed, if there are more than 10 line items for a given FRN.
Form 500 filers should also recognize that there is no print preview capability prior to certification. This is a particular problem if the form certifier is not the form preparer and would like to review the Form 500 before certifying it. For all but the simplest changes, the form preparer should take progressive screen shots.
New EPC “Records” Grid Views:
As discussed in USAC’s most recent News Brief (referenced below), the Records feature of EPC has been enhanced to provide a “grid view” list of:
- Applicant Entities
- FCC Forms 470
- FCC Forms 471
- Users
Clicking on any of these record types brings up a formatted list of additional information which can be filtered by the categories shown on the left hand side of the screen. To get a full list of filters, click “More…” The grid can also be sorted in ascending or descending order by the column headings. The following example is a portion of the unfiltered grid for Applicant Entities (showing, for all E-rate Trivia fans, the lowest assigned entity numbers).
Separately, USAC indicated that it is close to updating its legacy Entity Search tool. Currently, the legacy database does not include any new entities issued beyond FY 2015. The updated tool will show all entities and will provide additional information.