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January 15, 2018

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

FY 2018:

The FY 2018 Form 471 Application Window opened Thursday morning, January 11, 2018.  The Window will close Thursday, March 22, 2018 at 11:59 p.m. EDT.

FY 2017:

Wave 34 for FY 2017 was released Saturday, January 13th, for a total of $46.8 million.  Funding for New York was $602 thousand for 4 applicants.  Cumulative national funding through Wave 34 is $2.08 billion, including $86.6 million for New York.  Wave 35 is expected to be released Friday, January 19th.

Updating Locked Entity Profile Data:

As discussed in our newsletter of January 8th, USAC locked all school entity profile data as of the opening of the FY 2018 Application Window last Thursday.  The entity lockdown will remain in place for the duration of the window.  This means that school and school district discount rates will be based on student NSLP data currently reflected in EPC.  Applicants seeking to update entity profiles during the window will encounter the following message:

Entity Progile Locked

Once a Form 471 application has been completed and certified, RAL changes of application and/or entity data can be requested through EPC using the following page.

RAL Changes

Bulk Upload Templates for FRN Data:

As noted in last week’s USAC News Brief (referenced below), applicants creating detailed FRNs can upload Excel data using pre-formatted templates available for the different Category 1 and Category 2 services.  Applicants largely replicating funding requests created from previous year templates need to make sure that current template versions are used for FY 2018 — most importantly, the v18.0 version of the Category 2 template for Internal Connections.  Links to the most current versions of these templates can be found in Step 3 of USAC’s Form 471 guidance.  See:

Bulk Upload Templates for FRN Data

Copy FRN Warning on New Sites:

Early experience with EPC’s Form 471 for FY 2018 indicates that use of the “Copy FRN” function must be used with caution if an applicant has added a new site to its entity profile, either as a new addition for FY 2018 (before entity profiles were locked) or as a PIA addition for FY 2017.  New sites will not carry over into the recipient of service listings generated when previous year FRNs are copied, but may be added to the FRNs manually.

New E-Rate Central Website:

E-Rate Central is excited to launch its new website featuring a streamlined interface to provide easier access to our most popular tools.  Links to our State Information page and Funding History Search tools are now available on our home page.  Now it’s easier than ever to review an applicant’s or service provider’s complete E-rate funding history since the inception of the program simply by entering your Billed Entity Number or SPIN.  An example is shown below.  Additional detail may be accessed by drilling down through the hot links to individual funding years, and thence to specific funding requests (“FRNs”).

E-Rate Central's Funding History Tool

Upcoming 2018 E-Rate Dates:

January 16 FY 2017 Form 486 deadline for funding committed in Wave 16.  Upcoming Form 486 deadlines include:

Wave 17         01/22/2018
Wave 18         01/29/2018
Wave 19         02/05/2018
Wave 20         02/09/2018

Applicants missing these (or earlier) deadlines should watch carefully for “Form 486 Urgent Reminder Letters” in EPC.  The Reminders will afford applicants with 15-day extensions to submit their Form 486s without penalty.

January 29 Invoice deadline for FY 2016 non-recurring services (or for requesting an Invoice Deadline Extension Request).
February 22 Technically, the last day to file a Form 470 for use with a Form 471 application for FY 2018.  Whenever possible, Form 470s should be filed well before this date.  If a Form 470 is filed on this date, the 28-day posting requirement is not over until March 22nd.  On that day, an applicant using that last day Form 470 would have to select vendors, sign contracts, and complete the Form 471, all on the last day of the Application Window — never a good filing strategy!
March 22 FY 2018 Form 471 Application Window closes at 11:59 p.m. EDT.

FCC Commissioner Carr Nominated for Full Term:

FCC Commissioner Brendan Carr, appointed last summer to fill the final year of Thomas Wheeler’s term, was nominated for a new five-year term by President Trump.  Senate confirmation of Mr. Carr’s appointment is expected.

Executive Orders on Rural Broadband:

President Trump has signed two executive orders designed to help promote and develop rural broadband and Internet services.  The orders are not directly related to E-rate, and only tangentially involve the FCC, but may provide some assistance to rural schools and libraries seeking to buildout broadband facilities.

The first order, the “Presidential Memorandum for the Secretary of the Interior,” instructs the Secretary of the Interior to develop a plan “to support rural broadband development and adoption by increasing access to tower facilities and other infrastructure assets managed by the Department of the Interior.”  The second order, the “Presidential Executive Order on Streamlining and Expediting Requests to Locate Broadband Facilities in Rural America,” declares the government will continue to enforce rules governing access to wireless communication sites.

More broadly, as mentioned by the President, the orders are consistent with elements of the rural e-connectivity recommendations contained in last year’s Report to the President from the Task Force on Agriculture and Rural Prosperity.

FCC Lifeline Investigation Settlements:

In the closing days of 2017, the FCC announced the settlement of five Lifeline investigations.  As with the previous article, this is not directly E-rate related.  It does, however, indicate the FCC’s commitment to investigating instances of waste, fraud, and abuse.  More specifically, it illustrates the type settlements, both financial and procedural, imposed in resolving these investigations.  In all five settlements, the companies agreed to Consent Decrees that, in addition to requiring repaying the program for improper payments and making additional payments to the U.S. Treasury, implemented compliance plans to insure future adherence to program rules.”.  The key elements of the compliance agreements, which we have seen in comparable E-rate settlements, include:

  • Designation of a senior management Compliance Officer
  • Development of a Compliance Plan including:
    • Operating procedures to ensure compliance
    • A Compliance Manual
    • A Compliance Training Program
  • Requirement to report noncompliance
  • Periodic Compliance Reports

USAC’s Schools and Libraries News Brief of January 12, 2018, reports that its Category Two Budget Tool has been updated to show cumulative Category 2 funding and remaining budget amounts as of FY 2017.

The Tool shows data on an entity-by-entity basis.  The following example shows only one entity, but multiple entities can be displayed by inputting a string of entity numbers (separated by commas).  The initial display shows only the basic entity name and number.

Category Two Budget Tool

Hint:  If this screen or any of the following expanded view screens do not appear to display correctly, try clearing your browser’s cache (use the “Ctrl” + “Shift” + “Delete” key combination).

Summary budget data can be displayed by clicking the little “+” symbol to the left of the entity number.  Note that budget and funding amounts are all shown in pre­discount dollars.

x

Complete data on an application-by-application line item basis can be obtained by expanding the display a second time by clicking on the “+” symbol located left of the funding year.

Category 2 Budget Status

The new Budget Tool is a vast improvement over the previous version, that did not include FY 2017 data, but users need to be aware of a few quirks.  In the above example, for instance:

  1. The specific applications shown do not directly indicate the funding years.  To know this you need to understand USAC’s application numbering convention.  In this case, application # 1049963 is from FY 2015, before USAC began numbering applications beginning with the last two digits of the funding year.  Application # 1610566651, therefore, is for FY 2016.
  2. If no application is shown for a specific funding year — in this example, there is no application number beginning with “171” for FY 2017 — no category 2 funding was granted for that entity or for that entity’s district.
  3. If an application is listed under an entity, but no funding data is shown, the lack of data implies that one or more of the district’s other entities were funded.
  4. The Funding Year designation in the upper righthand corner has a dropdown menu for FY 2015–2017.  Changing the default year to either 2015 or 2016, does not change any of the funding data, but does change the funding year and budget amounts in the first data line of the display to reflect the lower per-student budget limits for that specific year.  We see little reason to use any year but FY 2017.

Last week’s USAC News Brief also discusses the following three topics:

  1. Bulk upload Form 471 FRN templates for FY 2018 (discussed above).
  2. Replacement of the previous “Apply for E-rate” web page with a new E-rate Productivity Center (EPC) page.  The new EPC page includes links to instructional guides and videos, plus the following, not so obvious, hot links:

E-rate Productivity Center (EPC) hot links

  1. New process for designating directly impacted applicants for hurricane relief.