Upcoming Dates:
| December 16 |
The Form 486 deadline for FY 2022 Wave 18. More generally, the Form 486 deadline is 120 days from the FCDL date or from the service start date (typically July 1st), whichever is later. Upcoming Form 486 deadlines are:
Wave 19 12/23/2022
Wave 20 12/30/2022 |
| January 9 |
ACP application window deadline (DA 22-1213) for the FCC’s outreach pilot programs for potential participation by schools, libraries, and others (see our newsletter of August 15th). See also the FCC and USAC announcements of the opening of the ACP application window last Monday. |
EPC Account Administrator Action Required:
In advance of a planned move of the standalone BEAR processing system into EPC in early January (see USAC’s E-Rate System Consolidation posting and our newsletter of November 14th), USAC emailed an advisory notice to EPC Account Administrators last week urging them to validate, and update as necessary, the users and their current access levels in their EPC accounts.
USAC has indicated that it plans to transition current BEAR permission levels into EPC, but this is clearly a step that EPC users — particularly EPC Account Administrators — will want to confirm. Once BEAR processing is moved into EPC, we expect the user permission section of EPC to look as follows:
To create and/or file a BEAR within EPC, a user will have to have either “Partial” (for draft-only rights) or “Full” (to certify) Form 472 rights. The Account Administrator is the only EPC user who can assign or modify user permissions.
Applicants likely to experience the most problems as BEAR processing is transitioned into EPC are those whose Account Administrator designations are out-of-date. USAC’s instructions for updating an Account Administrator are contained in its E-Rate Special Edition Newsletter of November 21st recommending the following two steps:
- Contact the E-Rate Customer Service Center at (888) 203-8100.
- Provide a reference letter of agency from the school/library district on the organization’s letterhead (or from the organization’s email domain) including the new EPC account administrator’s name, title, signature, and contact information.
State Conflicts with the FCC’s Proposed Bidding Portal:
The Iowa Department of Education is the latest state agency to weigh in on potential conflicts between the FCC’s proposed E-rate bidding portal (FCC 21-124) and the many state procurement laws and regulations. Although the initial and reply comment periods on the proposed portal closed last spring (see our newsletter of May 2nd), states continue to express concerns — and hopefully will continue to do so — with elements of the proposed plan that are in direct conflict with their state procurement requirements. Examples of earlier concerns include filings from state agencies in Arkansas, California, Illinois, Kentucky, Nebraska, Pennsylvania, South Dakota, and Utah.
Iowa’s comments include a discussion of the conflict that would result on Iowa DOE E-rate bids for statewide services under the competitive bidding rules of the Iowa Department of Administration Services (“DAS”). The DAS rules require that Iowa’s “Targeted Small Businesses” (small woman and minority-owned business that have been registered with the State) be notified 48 hours prior to the posting of public bids. As currently applied to Iowa E-rate bids, this means that the RFP portion of a Form 470 must be posted on Iowa’s Targeted Small Business website two days before the Form 470 (with the RFP) is certified in EPC. As the Iowa DOE indicates in its comments, this early posting of a bid would be in direct conflict with the proposed portal requirement that no bidder can have advance knowledge of the project information.