News of the Week

Wave 32 for FY 2015 will be released this Thursday, January 14th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. As of Wave 31, cumulative funding for FY 2015 was $2.90 billion.

Common EPC Questions:

USAC issued a Special Edition News Brief on January 6th discussing the five most common EPC questions being asked of the Client Service Bureau (“CSB”). This is a useful review, with links to related instructional resources, for applicants new to the EPC portal. The five questions addressed are:

1. How do I create an organization in EPC?
2. How do I set up account administrator access in EPC?
3. How do I get a user account (or set up access for a consultant) in EPC?
4. How do I navigate through the FCC Form 470 in EPC?
5. How do I get the status of a form or request I have submitted?

Parent/Child Relationships:

USAC’s answer to Question #1 above noted that EPC organizations must be one of two types, either “parent” or “child.”  In particular:

• Parent organizations, such as school districts, library systems, and consortia, make decisions and file forms on behalf of their child organizations. They have their own accounts in EPC. This also includes independent schools and independent libraries.
• Child organizations, such as individual schools within a school district and individual libraries in a library system, are featured on the accounts of their parent organizations. They do not have their own accounts in EPC.

This is an important distinction. EPC is enforcing a much stricter and inflexible definition of parent and children relationships than has been the case in the past. One way to think of this, to continue the parent/child analogy, is that EPC does not recognize the difference between an independent adult child and a dependent minor child.

As an example, consider libraries. In the real world, there are two types of library systems, namely:

1. A library system with a series of dependent library branches (i.e., a parent and “minor” children); and
2. A library system, acting much like an educational service agency, providing overall guidance and support to independent libraries (i.e., a parent and “adult” children).

EPC doesn’t recognize the difference between an independent library and a dependent library branch. Each type is designated a “Library.”  This distinction did not seem to cause much of a filing problem in the past, but it is does for FY 2016. The second type of library system (as listed above) needs to be an EPC consortium if its related libraries are to remain independent applicants with their own EPC accounts and capable of filing their own Form 471s.

On the school side, similar distinctions may need to be made for diocese schools, charter school management groups, multi-Head Start organizations, etc. If the upper level organization controls the underlying schools, is truly the billed entity, and is to be the BEN filing the E-rate application(s) on behalf of all the schools (“minor” children), then that organization is deemed a “School District.”  If the upper level organization is simply providing overall guidance and support, perhaps including the establishment of contracts for use by the schools (“adult” children), it should be a “Consortium.”

The “Consortium” vs. “Library System” or the “Consortium” vs. “School District,” distinction is critical in EPC for FY 2016. Most importantly, at the moment, any entity wishing to file a Form 470 to be used by other BENs must be a “Consortium.”  Previously, any type of entity could list other BENs in a Form 470 Block 4 as additional Recipients of Service. Under EPC, unless the Form 470 filer is a Consortium, the Form 470 will show only the filer as the Recipient of Service.

Form 470 “RNL” Corrections:

Prior to FY 2016 and the introduction of the EPC portal, any applicant filing a Form 470 was sent a Form 470 Receipt Notification Letter (“RNL”). The Form 470 RNL served to confirm the posting of the Form 470, to note the Allowable Contract Date (“ACD”), to review contact information, and to indicate the basic categories of services requested. The Form 470 RNL also provided a vehicle for making limited corrections, primarily of contact information, on the posted form.

For FY 2016, Form 470 RNLs are no longer mailed to applicants (or even available as such online). Instead, applicants can view their Form 470s, and make limited corrections, directly through EPC. The basic process for viewing an applicant’s completed Form 470 is as follows:

1. There are two easy ways to access an applicant’s Form 470, namely:
   1. At the bottom of the user’s Landing Page, there is a list of all FY 2016 Form 470s (the default condition) started (“Incomplete”) or completed (“Certified”); or
   2. From the applicant’s basic profile page, click on “FCC Form 470” in the activities list in the upper left-hand corner, leading to a list of completed Form 470s (the default condition), including creation, certification, and modification dates.
2. For certified applications, click on the desired application hotlink to bring up a copy of that Form 470 as currently posted. “Currently,” in this case may be important because the original Form 470 may have been corrected (see 4.c below) and/or augmented with additional RFP documents.
3. Checking for RFP documents, if any, is a little tricky. On each line item of Services Requested, there is a hotlink labeled “View RFP Documents.”  At first glance, clicking on this link may appear to simply refresh the basic Form 470 display. But, if there are RFP documents, the new display now includes an added “Service Request RFP Documents” with hotlinks to those documents.
4. The upper left-hand corner of the Form 470 display provides access to three functions.
   
    
   1. “News” indicates any USAC-generated emails resulting from the posting of this Form 470. One will be USAC’s notice that the Form 470 was posted. In one sense, this is equivalent to the previous Form 470 RNL. Twenty eight days after the Form 470 is posted, another news item will indicate that the Allowable Contract Date has been reached.
   2. “Generated Documents” provides a link to the Form 470 as originally posted.
   3. “Related Actions” provides four options to update the Form 470.
      
      The first, third, and fourth options permit limited corrections to the Form 470, equivalent to the changes which could be made in earlier years through the Form 470 RNL process.
      
      The second option is an entirely new capability this year, directly related to the new requirement that RFP documents (when available) be uploaded into EPC coincident with the posting of the Form 470. This option permits the applicant to supplement the original RFP documents (e.g., with Q&As). Please note that RFP amendments must be minor in nature. “Cardinal” changes to services being bid require a new Form 470 and RFP.

BMIC Break/Fix Invoicing:

With the limited exception of certain ongoing maintenance services, such as Cisco Base, E-rate discounts on Basic Maintenance of Internal Connections (“BMIC”) are committed based on estimates of break/fix costs, and then invoiced and disbursed only upon actual expenses. Prior to FY 2015, when and if P2 funding was available, discounts were committed and paid on a per-school basis covering all eligible equipment listed for each school. BMIC applications for FY 2015, however, required the BMIC estimate for each school to be broken down by equipment type. This raised a concern that invoicing would be limited to line item commitment amounts. Fortunately, as we have learned, USAC recognizes that the line item amounts are simply components of the per-school estimates, and that invoicing will similarly be limited only by the total per-school FRN commitments. We understand that the FY 2016 EPC version of the Form 471 will revert more clearly to per-school BMIC estimates.

FCC Appoints New USAC Board Members:

FCC Chairman Tom Wheeler appointed six members to three-year terms on USAC’s Board of Directors (DA 16-18). As a representative of schools, the appointments included Dr. Michael Hernandez, previously of the Arkansas Department of Education and currently the Superintendent of Arkansas’ Hot Springs School District. From an E-rate perspective — depending on the results of the fall election — this may be a politically astute choice. Unfortunately, however, it deprives the USAC Board of detailed E-rate experience that has been so capably provided by Julie Tritt-Schell, the Pennsylvania State E-rate Coordinator.

Form 486 Deadlines for January:

The Form 486 deadline for certifying the start of service (and CIPA compliance, if applicable) is 120 days from the later of the FCDL approval date or the start of service date. The remaining January deadlines (adjusted to Monday when the 120-day deadline falls on a Saturday) for approved FY 2015 applications are:

Wave 16                01/12/2016
Wave 17                01/18/2016
Wave 18                01/25/2016
Wave 19                01/29/2016

The S&L News Brief of January 8, 2016, discusses EPC and, according to the title, “What You Should Be Doing Now.”  In actuality — because this may be the first in a series — this particular News Brief covers:

• Advantages of an EPC portal
• EPC accounts (see more detailed article above on parent-child relationships)
• How to get more guidance on EPC
• How to get more information on the FY 2016 Form 470