Two EPC “Improvements:”
USAC released a Special Edition News Brief of April 11, 2016, announcing changes to the EPC system to address two minor problems being encountered by certain applicants.
CEP Discount Rate Calculation Rounding:
Note: The following discussion applies only to schools participating in the Community Eligibility Provision (“CEP”) program — and more specifically to those CEP schools with a “identified student percentage” (“ISP”) in the range of 46–47%.
CEP schools, school groups, or school districts calculate their number of NSLP-eligible students and discount rate by:
- Using the direct certification process to determine the “identified student percentage” (“ISP”). This percentage is expressed to two decimal places. To be eligible for CEP, this percentage must be at least 40%.
- Multiplying the ISP by the Department of Agriculture-approved factor, currently 1.6x, to estimate the total percentage of NSLP-eligible students. This percentage must be at least 64% and is capped at 100%.
- Multiplying the NSLP-eligible percentage by total student enrollment, rounding up to the next highest integer to determine the number of NSLP-eligible students.
- Dividing the number of NSLP-eligible students by the total student enrollment, rounding that result to the nearest whole percentage point.
- Using the resulting percentage to determine the entity’s E-rate discount rate. For CEP schools, the E-rate discount rate will be either 80%, 85% (Category 2 only), or 90%.
The problem within EPC has been in step #1. EPC has been rounding the initial ISP down to the lower whole percentage point. Depending upon the size of the school, this rounding could affect the eligible student calculation by a few students. This error is a problem only if the initial CEP percentage is in the 46–47% range. Where it falls within this range could mean the difference between qualifying for an 80% discount or the higher 85–90% discount. The following is an example of this borderline problem. In this example, rounding down the CEP percentage, as EPC had been doing, results in a 10% lower discount rate.
| Step |
Description |
Without CPE
Rounding |
With CPE
Rounding Down |
| 1 |
Directly Certified CEP (ISP) % |
46.72% |
46% |
| 2 |
NSLP-Eligible % |
74.75% |
73.60% |
| 3 |
NSLP-Eligible Students* |
150 |
147 |
| 4 |
NSLP-Eligible Students % |
75% |
74% |
| 5 |
Discount Rate (Category 1) |
90% |
80% |
| |
|
|
|
| |
* Total enrollment = 200 |
|
|
Single Circuit Allocations for Multi-School Sites:
Note: The following discussion applies only to schools sharing a common site, but begins with a description of a seemingly related EPC problem that has not yet been fixed. The News Brief is somewhat confusing on this point. It refers to the need for an applicant choosing Data Transmission and/or Internet Access directly to one entity to allocate the connection to all the entities sharing that service.
The most common problem — and one not addressed in this News Brief — is for Internet Access via a single circuit to one location, but shared via a WAN to other entities.
In this case, when you get to the FRN section below, you would think that you would check “Yes” to the direct connection question, check “No” to the WAN question, then use the “Multiple buildings” pulldown to indicate that the Internet is being shared.
Responding this way creates an awkward EPC problem. If later in the FRN creation process you indicate that multiple sites are sharing the service, the system default assigns one circuit per site, not one circuit to the group.
A quick reading of the News Brief might suggest that the solution to this problem is to assign a fractional (actually a decimal) value to each site (e.g., 0.2 circuits per site for Internet shared over a 5-school WAN). As discussed below, this was not the intent of the News Brief.
The best way we have found to solve the EPC shared internet allocation problem is select the “One building/site listed” response, and subsequently select the one site directly connected to the Internet provider. In other words, although the Internet is shared, the “Connection used by” is only the gateway site.
The fractional allocation fix discussed in this News Brief is designed to address a less common problem of any circuit terminating in a single physical location shared by multiple schools. Most commonly, we see this situation arise in either of the two following situations:
- A small school district housing what its state considers to be 2-3 schools in the same building (e.g., an elementary, middle, and high school); or
- An urban school district that has split a large building into 2 or more individually-defined schools.
The solution — hopefully to be available this week — is to allocate a portion of the one circuit to each school, making sure that the total adds up to one. In the News Brief example, therefore, the allocation for a 3-school building would be 0.33, 0.33, and 0.34.
Forthcoming EPC Updates:
USAC’s Special Edition News Brief extending the filing window also pointed to a list of EPC upgrades that are expected to be implemented within the next few weeks to:
- Ensure that certain data that is currently missing from the PDF application review will appear, including some fields for Tariff and Month-to-Month FRNs and for certain portions of fiber FRNs.
- Ensure that users have the ability to bulk upload student counts for larger data sets. (Applicants, particularly those with a large number of entities, have continued to report problems with the bulk entity upload process.)
- Allow consortia applicants to have the ability to “select all” recipients of service on a funding request line item. (Currently, entities receiving service must be checked individually.)
- Remove the erroneous error message that appears on the interest rate field for FRNs with special construction costs.
- Display Billed Entity Numbers and FRN Line Item numbers rather than the internal tracking numbers on error messages for certain consortium applications. (EPC uses its own 6-digit internal entity numbers, beginning with a “3,” often creating undecipherable error messages for applicants.)
- Remove the requirement to allocate Internet Access by individual recipients of service. (One temporary workaround for this problem is discussed above.)
- Allow FRN Line item uploads using Excel 2013. (The recently released template for uploading FRN line item and recipient of service data currently requires the use of Excel 2010. A temporary workaround to support Excel 2013 is now being tested.)
- Allow the FRN line item upload template to accommodate partial line allocations. (The use of fractional — more precisely “decimal” — line allocations is one of the “improvements” discussed above.)
- Prevent the Entity upload template from rounding CEP percentages. (The rounding of CEP percentages within the EPC system itself has been fixed, as discussed above.)
- Allow users to enter data in all fields of the Connectivity template. (USAC’s offer to help large users complete their connectivity profiles has been hindered by a formatting error in the USAC-provided template.)