Finding PIA Inquiries
USAC initiated PIA inquiries last week. For the first time, PIA inquiries and applicant responses will be processed through EPC. It’s already clear that this is going to involve a learning process for applicants, consultants, and PIA reviewers alike.
The basic PIA inquiry/response process is as described in USAC’s Special Edition News Brief on April 27th and in our newsletter of May 2nd. What caused significant confusion last week was the email alert, such as the following, sent to the applicant contacts.
From: [PIA Reviewer Name]@sl.universalservice.org
Sent: Monday, May 09, 2016 10:35 AM
To: [Applicant Contact Name and Email]
Subject: PIA Has Inquiries About Your FCC Form 471 Application
Dear [Applicant Contact Name]
My name is [PIA Reviewer Name] and I am a part of USAC’s Program Integrity Assurance (PIA) review team, currently reviewing your Funding Year (FY) 2016 FCC Form 471 application(s). PIA review is the process of checking FCC Form 471 applications for compliance with program rules and policies.
My review has generated further inquiries about your application, and we have sent the inquiry request to you. It is waiting for you in our new IT system, the E-Rate Productivity Center (EPC). Beginning FY2016, applicants must receive and answer all PIA inquiries using only one method—EPC. PIA will no longer email or fax FY2016 questions to you.
In order to access, respond to, or manage PIA inquiries (or any PIA notifications), you must:
- Log in to EPC.
- View the PIA notice in the News tab. The notification in the EPC News tab reads: From the FCC Form 471 Review Team.
- Tip: To locate your inquiries more easily, enter "471 Review Team" in the News search function and hit the "Enter" key.
When you click the blue bar at the bottom of the notification, you will be able to access your inquiries under the Review Inquiries menu item.
- From the “Review Inquiries” page, select one of the following:
- Respond to inquiries
- Request an extension
- Submit a modification to your form ("RAL correction")
Note: USAC strongly recommends that you routinely monitor your News to make sure you do not miss any PIA inquiries.
Please refer to USAC’s News Brief for in-depth, specific guidance on how to:
- Understand how you will be notified about PIA questions
- Access your PIA questions
- Respond to your PIA questions
- Request an extension of time to answer PIA questions
- Submit modifications to your FCC Form 471
Please feel free to contact me via EPC or call me if you need more information or have questions. I kindly ask that you answer the inquiries promptly, in order for your application review to continue. If you need additional time to prepare your responses, please let me know as soon as possible.
This example is one of the earlier alerts received. One improvement to the template, quickly added by individual reviewers, was to include some identifying information to the subject line to at least indicate a Form 471 number and/or applicant name. This was a particularly important addition for contacts (such as consultants) dealing with multiple applications.
What the email does not include, as had been the case in all years past, is an attachment indicating the questions being posed. To get the questions, the applicant contact is directed to an EPC “News” feed which, in turn, links to an EPC “Review Inquiries” page showing “Pending Inquiries” and providing an online mechanism to submit responses, request extensions, or make RAL corrections.
The first challenge facing an applicant is to find the specific “News” feed leading to the PIA question(s). The general “News” tab in EPC, even if customized to narrow the type of news reported, is choked with unrelated items. There is, however, a search function. Unfortunately, at least as of last Friday, the PIA email’s suggestion to search for “471 Review Team” wasn’t leading to any useful results. We’ve found that searching for “15-Day,” which is also referenced in the “News” inquiry subject line, works better.
Another approach to finding the appropriate “News” inquiry notice is to use the applicant-specific “News” function. As discussed in our May 2nd newsletter, there are two links to “News” from the applicant’s “Landing Page.” The red arrow points to general “News;” the green arrow points to applicant-specific “News.”
Activation of Dummy SPIN:
USAC posted a notice last Thursday indicating that it has activated “143666666” as, what we call, the “dummy” or interim SPIN. USAC has traditionally activated this in the last few weeks of the application window. This is a temporary “Service Provider Identification Number” an applicant can use in funding requests if the applicant is new to E-rate and has not yet obtained its own SPIN. During PIA review, the applicant will be prodded to update the “dummy” SPIN with the vendor’s real SPIN, hopefully available by that time.
Note: An interim SPIN is not to be used in cases where the applicant is unsure as to which service provider they are going to select, but wants to submit their Form 471. The selection and notification of the service provider must be executed prior to submitting the Form 471.
Safe Sender Lists for FCDLs:
A small notice in last week’s USAC News Brief (referenced below) indicates that when Funding Commitment Decision Letters (“FCDLs”) are issued this year, emails, rather than actual letters, will be sent to the applicants — no doubt referring the applicants to FCDL “News” items. To make sure applicant contacts receive these emails, USAC suggests adding “portal@usac.org” to their email systems’ “safe sender” lists.
More broadly, with USAC’s greater reliance on email notifications, we would suggest earmarking both “usac.org” and “sl.universalservice.org” (used by PIA) as safe domain names.