News of the Week

Wave 37 for FY 2015 will be released next Monday, February 22nd. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015 is $3.01 billion. This is the first time since FY 2010, and only the second time in the program’s history, in which cumulative funding reached the $3 billion mark.

Full-Time and Part-Time Students:

There is a conflict between the way part-time students are handled in EPC depending upon whether the system is using the student count to calculate discount rates or Category 2 budgets.

EPC’s “School Information” profile for each school includes the following four fields for student counts:

• Number of Full Time Students
• Total Number of Part-Time Students
• Peak Number of Part-Time Students
• Total Number of Students Eligible for National School Lunch Program (NSLP)

The difference between the peak and the total number of part-time students is important for Category 2 budget purposes. The concept is that the budget should be determined by the peak number of students (including full-time students) served by a Wi-Fi system at any point in the day. Consider, for example, a school serving 100 part-time students in a morning session and 150 part-time students in an afternoon session. That school would have a total of 250 part-time students with 150 peak part-time students. In calculating the Category 2 budget, the determining factor would be the 150 peak part-time students, not the 250 total.

For discount rate purposes, the total number of enrolled part-time students (and full-time students) is the important factor. Thus, in our example, the discount rate would be determined by the number of eligible students out of the 250 part-time students unless — and this is a critical distinction — some or all of those part-time students are already being counted as a part of the enrollment of another school in the district. In that case, the district’s discount rate is based on total enrollment, i.e., without duplicative counting of students attending two of a district’s schools.

In other words, double counting of students within a district is fine to determine the peak-time count of students in each school for Category 2 purposes, but students cannot be double-counted in the district’s enrollment for discount rate purposes.

There is one more complication. The issue of double-counting for discount rate purposes does not arise if students attend part-time in their home district and part-time in another district, typically an ESA school. In this case, the ESA is a separate district. Attending students, therefore, are treated as being enrolled in two districts for discount rate calculations.

If this sounds a bit confusing, be comforted in the knowledge that the EPC system, including the Entity Profile Bulk Upload template, is confused as well. Currently the Total Number of Students Eligible for NSLP “Cannot exceed the number of Full Time Students.”  The presence of part-time students, at a minimum, may throw off the discount rate calculation. At worst, the system will not accept the correct number of eligible students.

Our recommendation is to carefully check the discount rate of any district having schools with part-time students. You may want to avoid updating the EPC profiles for such schools until USAC corrects the problem or provides clarifying guidance.

Form 471 Consortium Issues:

A number of consortium applicants are concerned about the following problems, some of which can, or will hopefully soon, be solved:

1. A number of consortia are still listed incorrectly as school districts or library systems in EPC. Until the applicant type can be corrected, a consortium cannot establish its member profile. Corrections need to be made through CSB, but there appears to be a backlog of requests. Any consortium needing to request an applicant type change should do so as early as possible.
2. A consortium cannot currently draft a Form 471 if certain profile information has not been completed in the accounts of one or more of its members. Consortia are reporting receiving the following error message:
   
   This is clearly a problem exacerbated by the lack of any indication as to which member profile(s) is causing the problem. We expect both issues to be resolved in a near-term system fix.
3. The good news for consortia is that all connectivity data resides at the member level, and that a consortium’s Form 471 application(s) is not contingent on the members’ completion of their connectivity profiles. The bad news, as indicated above, is that this is not true of member discount rate data. From an application review standpoint, USAC has indicated that a consortium’s discount rate will ultimately be determined after all the individual member discount rates are validated. Supposedly, this will not hold up review and approval of a consortium application, but it does subject the consortium to the possibility of a Revised Funding Commitment Decision Letter with a different consortium discount rate at some uncertain future time. One solution under discussion would be to fix a consortium’s discount rate at a certain date (e.g., the close of the window or the start of the funding year) regardless of subsequent updates to member NSLP updates.
4. Another way to provide consortium control of member discount rates is to provide consortium access to the student data profiles of its members. The only reasonable way to do this currently requires the consortium to register as a consultant, with a Consultant Registration Number (“CRN”), and encourage all members to add the consortium’s consultant user(s) to their EPC accounts with full or partial rights. Alternatives to this approach have been suggested.
5. In past years, some consortia have included other consortia as members. At present, EPC does not support a consortium of consortia. The only solution is to deconstruct the sub-consortia, listing their individual members as part of the major consortium.

Fixing School and Library Entity Lists:

When EPC first went live, a number of applicants reported that not all entities listed in their FY 2015 applications were ported over. USAC indicated that many of the missing entities were NIFs, and subsequently did an update. We’re still finding missing entities, again often NIFs.

School districts and library systems need to check their EPC entity lists carefully. Applicants planning to use the Entity Profile Bulk Upload template to update their entity profiles should note that the upload only affects listed entities. It does not add or delete entities. Entities can be added and/or deleted only by CSB. For one or two entities, the best way to do this is call CSB. For large scale changes, initiate a Customer Service Case attaching a list of corrections.

FY 2016 Application Window is Open:

The Form 471 application window for FY 2016 opened on February 3rd. The window is scheduled to close at 11:59 p.m. EDT on Friday, April 29, 2016. The entire application process for FY 2016 is being handled through USAC’s new EPC portal with its own learning curve. Please do not wait until later in the window to file Form 470s, update pre-471 EPC applicant profile information (entity, student, connectivity, and contract data), and begin the Form 471.

Eric Flock Joins E-Rate Central:

E-Rate Central is pleased to announce that Eric Flock is joining our firm. For the past nine years, Eric was at USAC as a part of the Schools and Libraries Division’s senior management team. In his role at USAC, Eric was responsible for determining the eligibility of products and services, and for creating and updating the PIA application review procedures. Prior to USAC, Eric worked at USAC’s contractor, Solix Inc., as an Initial Reviewer, Final Reviewer and Quality Assurance Reviewer, before serving as the Cost-Effectiveness Manager and the Services Team Manager. Eric has over 12 years of E-rate experience and we welcome him to the E-Rate Central team. Eric can be reached at 516-801-7803 or eflock@e-ratecentral.com.

USAC en Español:

USAC introduced a new “USAC en Español” section of its website to provide E-rate information in Spanish. As discussed in a Special Edition News Brief dated February 10th, in both Spanish and English, the new site is divided into four key areas covering forms, search tools, “Contact Us,” and reference materials.

USAC EPC Webinars:

USAC has scheduled the following series of webinars on the EPC Form 471 filing process, preceded by a set of more general sessions for beginners. Note that there are two choices of dates for the more advanced webinars. Registration is available now on the Trainings & Outreach page on the USAC website.

Webinars for beginners:

• E-rate 101: Introduction to the E-rate Program: February 16th at 3:00 p.m. EST
• E-rate Program Application Process, Part 1 (FCC Forms 470 and 471): February 17th at 3:00 p.m. EST
• E-rate Program Application Process, Part 2 (PIA and Invoicing): February 18th at 3:00 p.m. EST

Webinars for all FCC Form 471 filers (times subject to change):

• How to Complete Basic and Entity Information to Prepare for Filing FCC Form 471: February 23rd and February 25th

• Schools and school districts at 1:00 p.m. EST
• Libraries and library systems at 2:30 p.m. EST
• Consortia at 4:00 p.m. EST

• How to Complete Category 1 Funding Requests on FCC Form 471: March 1st and March 3rd at 1:00 p.m. EST
• How to Complete Category 2 Funding Requests on FCC Form 471: March 1st and March 3rd at 2:30 p.m. EST
• How to Understand and Complete the Certifications Section, and Complete FCC Form 471: March 8th and March 10th at 1:00 p.m. EST

20th Anniversary of the Telecom Act of 1996:

In remarks delivered at the Library of Congress last week, FCC Chairman Wheeler celebrated the 20th anniversary of the Telecommunications Act of 1996, enacted February 8th of that year. Most broadly, the Act marked “a watershed between the era of analog networks and the competition-enhancing, converged networks of the digital era.”  Most notably, the Act was the establishing legislation for the E-rate program whose first funding year began January 1, 1998, less than two years later.

Form 486 Deadlines for February:

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 February deadlines (adjusted for weekends and holidays) for approved FY 2015 applications are:

Wave 21                02/16/2016
Wave 22                02/19/2016
Wave 23                02/26/2016

The S&L News Brief of February 12, 2016, provided the following five tips for navigating through EPC and filing forms:

1. To get to “My Landing Page,” click the USAC logo in the upper left-hand corner of any EPC page.
2. If you believe you are set up as a user in EPC but you can't update any information in EPC, you probably have not accepted your “Terms and Conditions.”
3. For consortia: You can add missing consortium members to your EPC account yourself.
4. Account administrators that can't file program forms can grant themselves full or partial rights as appropriate.
5. When asked for a nickname, create one that is specific, easy to remember, and pertinent.

One point we’d add to the last tip is that the requirement to add nicknames is often useful, but just as often can be annoying. Descriptive nicknames are particularly important when associated with forms and customer service cases which will appear in EPC lists otherwise identified only by numbers. In these instances, the use of nicknames makes later searches much easier. On the other hand, the requirement to provide a nickname for every modification (e.g., successive entity updates) can become tiresome. One way to speed up the nickname process for repetitive updates is to simply enter any character (including a blank, i.e., space) in the nickname field.