Form 486 Approvals and the FST:
USAC appears to have made significant progress in reducing the backlog of pending Form 486 approvals which had been held up pending Service Start Date and CIPA certification corrections. That’s good news for applicants eager to start E-rate discount invoicing for FY 2017. Usually within 1-2 days of Form 486 approvals (and notification in applicants’ EPC News feeds), updates are made to the legacy invoicing system.
Unfortunately, Form 486 updates to the FRN Status Tool (“FST”) are less reliable. The date appearing in the FST’s “486 Service Start Date” field is usually the Tool’s indication that the associated Form 486 has been approved. However, we are finding numerous examples of approved Form 486s with no entries in the “486 Service Start Date” field despite approvals occurring one to two months ago. Applicants and service providers relying on the FST to track multiple Form 486 approvals will be misled. E-Rate Central’s Funding History Search tool, which also relies on FST data, will be similarly misleading. This is especially troubling given that many service providers and E-rate data services rely on the FST data to verify if certain activities have occurred.
Applicants seeking to confirm their own Form 486 approvals can do so within EPC, locating the Form 486 via the Forms pulldown tab, and checking the status of each Form 486. More detailed Form 486 Notification data can be found by searching the News feed using the Form 486 number. This approach is fine for individual applicants, but is not useful for vendors trying to determine if they can begin invoicing USAC via the SPI process.
FRN Continuation and Copy Warning:
Applicants creating ongoing FRNs for multi-year contracts need to be careful when using the Copy FRN function for contracts initiated in the previous year. Here’s the sequence that can cause a problem:
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- The first field encountered when starting a new FRN requires a Funding Request Nickname (which we suggest applicants make clearly descriptive).
- The next step asks: “Is this Funding Request a continuation of an FRN from a previous funding year?” If “Yes,” you enter that FRN.
- The third step gives you the option to copy an existing FRN, most frequently (but not necessarily) from last year’s application.
If you use the “Copy FRN” feature with the previous year’s FRN, and that year was the first year of a multi-year contract, then last year’s FRN answer would have been “No” to the FRN continuation question. Using “Copy FRN” will revert this year’s “Yes” in the continuation field to last year’s “No” — a change that’s easy to overlook. The trick is to use the “Copy FRN” first, then edit/update the continuation question after the FRN has been copied.
Answer to Last Week’s Category 2 Budget Tool Quiz:
For E-rate geeks: Our last two newsletters discussed the differences between USAC’s two Category 2 budget tools, the one built into EPC and the new non-EPC Category Two Budget Tool. The biggest difference is that the EPC tool does not reflect any Category 2 commitments for FY 2015. But both newsletters included brief reader quizzes concerning the small difference between the two tools in calculating the inflation-adjusted per-student Category 2 budget limit for FY 2017. EPC uses the unrounded $153.4695 figure, whereas the non-EPC Category Two Budget Tool uses the correct, FCC-approved, rounded $153.47 figure. Although the difference appears small, last week’s question focused on the issue of what would happen if the difference was carried forward into future years. The specific question was:
If the inflation factor for 2018 is again 1.3%, could the EPC C2 per-student number be off by one penny?
The first correct answer — “Yes” — came from Patrick Doyle at Erie 1 BOCES. He wrote:
If the EPC system decides to round the 1.3 % multiplication for FY 2018 you will have a one penny difference. 153.4695 x 1.013 = 155.4646035 which would round down to $155.46.
As Mr. Doyle notes, the correct calculation would be 153.47 x 1.013 = 155.46511 which would round up to $155.47 — one penny more.
Please note that the 1.3% inflation adjustment used in this question was for illustrative purposes only. The FCC is not expected to announce the real inflation factor for FY 2018 until later this month or early in March. For conservative planning purposes, we suggest that schools use $155 per student, a 1% increase (for libraries, we’d suggest $2.38 or $5.17 per sq.ft.).