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December 14, 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 29 for FY 2015 will be released this Thursday, December 17th. Funding for FY 2015 is available for both Category 1 and Category 2 services at all discount levels. As of Wave 28, cumulative funding for FY 2015 was $2.75 billion.

Wave 72 for FY 2014 will be released on Wednesday, December 16th. Funding for FY 2014 is available for Priority 1 services only. Priority 2 funding has been denied at all discount levels. Cumulative funding for FY 2014 is $2.29 billion.

Annexes for Multi-Location Schools and Libraries:

USAC has traditionally relied on the states to define individual schools and libraries. This is usually a straight-forward exercise as long as a single school or library is contained within a single building. In some cases, however, a school or library, as defined by a state, has two or more locations. Most often, we have seen this situation arise with private/parochial schools in urban areas when, for example, the school might house K-5 grade students in one building and 6-8 grade students in another. We refer to these types of situations as “multi-location schools.”  Multi-location libraries also exist, but less frequently. In either case, we are discussing instructional school or library facilities.

For E-rate purposes, USAC has historically addressed these situations by assigning separate entity numbers to each school or library location. Thus a multi-location school, for example, would have multiple entity numbers (unless they were on the same “campus”). Note that in either a multi-location school or library case, the aim is to designate separate instructional facilities (as opposed to an eligible non-instructional facility, or “NIF”).  This gives USAC the ability to track and validate that E-rate services are being delivered to eligible locations.

In particular, it is important to recognize that there is a difference between the way multiple locations were previously treated for Priority 2 services, and the way they are being handled as of FY 2015 for Category 2 services. The limiting 2-in-5 rule for Priority 2 treated each school or library location separately. Multi-location schools and libraries, therefore, had separate 2-in-5 accounts for each location. Category 2 budgets, on the other hand, refer to individual state-defined schools and libraries. Although USAC still needs to know and track where services are being delivered, a multi-location school or library has a single Category 2 budget.

The big change under the EPC portal is that a multi-location school or library will have one main listing, using its primary address. All other instructional facilities — as opposed to NIFs — will be treated as “annexes.”  A Category 2 budget for a multi-location entity covers expenditures for its main location and any annexes.

To view existing annexes within EPC, use the “Annexes” link in the activities list shown on the left-hand side of the school or library page reading:

 

Currently, since “annexes” is a new designation, what you are most likely to see is the following:

 

Annexes can be added or deleted using the “Manage Annexes” button in the top right-hand corner of the associated school or library page. Assuming the user has the requisite permission, this button leads to the following:

 

To add an annex, click the green “Add New Annex” button, then complete the following information:

 

The good news in this process is that a user can manage annexes within EPC without creating a Customer Service Case and/or calling the Client Service Bureau (“CSB”). Under the new system, annexes are not even assigned entity numbers. This is clearly advantageous for applicants adding new annexes.

What is not yet fully understood is how an existing multi-location school or library should treat any existing entities that are now being redefined as annexes. Because these entities (or locations) were not distinctly identified in USAC’s entity database, they were not automatically carried over as annexes into EPC. As a result, it appears that:

  1. Applicants will have to individually enter these associated multi-location sites as annexes into their EPC accounts.
  2. Multi-location applicants will have to check that their EPC accounts properly show only the main locations as being individual schools or libraries.
  3. Corrections may require CSB assistance to cancel the entity numbers for locations currently listed as individual schools or libraries in EPC, but which should now be listed as annexes.
  4. USAC will presumably have to validate annexes during PIA review to make sure that E-rate services are delivered only to eligible locations. To assist in this process, E-Rate Central will continue to maintain the New York State Multi-Location School database.

Multi-location applicants can begin adding annexes to their EPC accounts now. Additional USAC guidance on annexes is expected shortly.

FCC Website Redesign:

The FCC’s redesigned website (www.fcc.gov) was debuted last week. Our initial impression is that the new look is much cleaner, but that it will be a bit more difficult to review recent news. As of Saturday, for example, the “Headlines” portion on the home page linked to just four announcements dated last Wednesday and Thursday. Two clicks were necessary to access more recent news shown in Friday’s Daily Digest. The new site is more social network-oriented with easy access to FCC blogs and Twitter feeds. It also features prominent links into other key areas of the site such as the FCC’s Electronic Comment Filing System (also scheduled to be redesigned).

Jessica Rosenworcel Approved for Second FCC Term:

A second term for FCC Commissioner Jessica Rosenworcel, a strong E-rate supporter, was approved by the Senate Commerce Committee last week.

Upcoming E-Rate Training:

USAC has completed its eight regular fall applicant training sessions. Copies of the slides used can be accessed via USAC’s Training and Outreach archives. USAC has also posted many additional EPC resources (including videos used during its training sessions). Over the next 3-4 months, we expect USAC to conduct additional webinar-based training on EPC and on other critical FY 2016 application topics.

E-Rate Central will be conducting an E-rate training webinar on Tuesday, December 15th, and a workshop (and webinar) in Brooklyn on Wednesday, December 16th (see the NYSED FY 2016 E-Rate Workshop Schedule). A copy of the NYSED training slides is available on the same website.

Form 486 Deadlines for 2015:

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 2015 deadlines for approved FY 2015 applications (adjusted to Monday for 120-day deadlines falling on Saturdays) are:
                                          Wave 12                12/14/2015
                                          Wave 13                12/21/2015
                                          Wave 14                12/28/2015

Applicants who missed earlier Form 486 deadlines should review the related article in USAC’s News Brief of December 4, 2015. USAC has mailed FCC Form 486 Urgent Reminder Letters to many of these applicants giving them an additional 20 days (to December 22nd) to file without penalty.

No S&L News Brief Last Week:

USAC did not issue its regular Friday News Brief last week.