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September 28, 2015

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.

Wave 19 for FY 2015 will be released on Friday, October 2nd. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. Cumulative funding for FY 2015, as of last week, is $1.99 billion.

No Wave is scheduled for FY 2014 this week.

Posting an RFP with the Form 470

As this newsletter has previously noted, all Forms 470s must be posted on USAC’s E-rate Productivity Center (EPC). This includes any RFP that the Form 470 may reference. Should an RFP include a question and answer period when potential service providers can request clarifications or more details, this also needs to be posted via the EPC portal. The applicant may even edit the question to make it more understandable. Most importantly, it is vital that all potential bidders have access to any clarifications about the requested services. Whether the RFP is also posted on the applicant’s own website is up to the applicant and the internal regulations that may govern RFP postings.

Frequently the questions and answers are turned into an addendum to the RFP. There is a codicil to this process pertinent to EPC. Should you post an addendum, and we suppose also the question and answer document, you will most likely get a warning pop-up from EPC that admonishes the applicant with the Form 470 that when uploading additional RFP documents, you cannot make a cardinal change to the scope of services sought. If you are requesting a cardinal change to what you have already posted, you must file a new Form 470, which will start a new 28-day clock.

The operational wording is “cardinal”. USAC provides examples of a cardinal change as additional speeds, adding additional products and services, and adding additional locations or entities. The warning then asks if you wish to proceed. We suggest that every effort be made so that both the Form 470 and its corresponding RFP, if there is one, are as complete as possible, and to review thoroughly the more stringent requirements that USAC has put into place.

Form 470 Service Options

As Form 470 postings go into full swing, below are the drop-down options that EPC offers for Category 1 services:

  • Transport Only – No ISP Service Included
  • Cellular Data Plan/Air Card Service
  • Cellular Voice
  • Dark Fiber
  • Internet Access & Transport Bundled
  • Internet Access: ISP Service Only
  • Lit Fiber Service
  • Other
  • Self-provisioning
  • Voice Service (Analog, Digital, Interconnected VoIP, etc)

Note that “Wireless” is not on the drop-down menu. The “Transport Only – No ISP Service Included” or “Internet & Transport Bundled” are selections that would ostensibly include wireless services, yet be agnostic vis-à-vis service providers. USAC’s possible offering of an additional session about dark fiber and special construction charges at the first training workshop in Washington D.C. indicates that there are applicant and service provider questions about how to post for some Category 1 services.

Upcoming E-Rate Training and Deadlines:

September 30th Service delivery deadline for FY 2014 non-recurring (e.g., installation) services. Requests to extend this service delivery deadline, due to circumstances beyond the applicants’ or service providers’ control, must be submitted on or before the September 30th deadline.
October 2nd USAC will conduct the first of this fall’s eight regional applicant training sessions in Washington, D.C. Although registration (including the waiting list) for this session is full, copies of the training materials should be available online a day or two before this first session. The remaining seven USAC training sessions will occur approximately weekly from October 8th through November 16th. The full USAC training schedule is available online. Registration at this point is assured only in Albuquerque and Portland.
October 28th Invoicing deadline for FY 2014 recurring services. Applicants filing Form 472 reimbursement forms must allow time for these “BEARs” to be pre-acknowledged by the applicable service providers before the forms can actually be submitted. Requests to extend this invoicing deadline must be submitted on or before the October 28th deadline.
         
October 29th First Form 486 deadline for certifying the start of service (and CIPA compliance, if applicable) for FRNs approved for FY 2015 on or before July 1, 2015 (i.e., in Waves 1-6). On a going forward basis, the Form 486 deadline is 120 days from the later of the FCDL approval date or the start of service date, whichever is later.

The S&L News Brief of September 25, 2015, highlights deadlines to submit invoices. These deadlines are especially important this year due to the new rule that stipulates that if an invoice deadline extension is necessary, you may do so one time only.

The deadline to submit reimbursement forms for recurring services, whether it is via the BEAR (Form 472) or SPI (Form 474) modes, is October 28th, 2015 for most applicants. USAC determines the deadline for submitting invoices in two ways, whichever of the two is later: 120 days after the last date to receive services, which is for the most part is June 30th of the funding year; or 120 days after the date of the FCC Form 486 Notification Letter. The deadline to receive services for non-recurring services, for both Category 1 and Category 2 services is September 30th (after the close of that funding year).

Applicants should take into account the time it may take for service providers to sign BEAR forms . The News Brief offers tips for filing BEAR forms for the two parties, applicant and service provider, along with suggestions for service providers using the SPI method, such as making sure that the SPAC (Service Provider Annual Certification) form is up-to-date.