Final “Hazard” Warnings:
Applicants, who have not responded (or who have submitted only incomplete responses) to PIA within the normal 15-day due date period are now beginning to receive the following email “Hazard” warnings.
These new emails are apparently generated automatically by EPC. However, the only references to the applications in question are reproduced sections of the earlier 7-day reminder notices.
Note that these are serious warnings of missed PIA deadlines. USAC can and will deny funding requests from non-responsive applicants.
Form Cancellations or Corrections:
With all the new or revised forms now available within EPC or the legacy system, questions are arising as to how to cancel or correct forms filed prematurely or in error. Here are a few suggestions:
- Form 470: Limited changes to a Form 470, already filed for FY 2017, can be made within EPC as long as the applicant is careful not to materially alter the nature and scope of the services being procured. Allowable changes are limited to the Form 470 nickname, contact information, and RFP addendums. To make such a change, navigate to the Form 470, and choose “Related Actions.”
If material (or “cardinal”) changes — or, to be safe, any changes — are to be made to services being procured, a new Form 470 should be filed. Note that, if a new Form 470 is filed, there is no way within EPC, even with CSB support, to cancel a previously filed Form 470. Our suggestion in this situation is to change the nickname of the first form to include the word “Canceled.” For an older Form 470 with an RFP, you can also append another RFP document pointing to the new Form 470.
- Form 472: The direct payment of BEARs, which became effective last July, means that BEARs are no longer subject to service provider review. In the past, depending upon the diligence of the provider, applicant errors (ineligible amounts, incorrect SPINs, etc.) may or may not have been caught prior to filing. Applicants now need to be more careful from the outset. The most likely errors are those involving eligible amounts — errors that may or may not be corrected during USAC invoice review, much of which has been automated. Errors discovered post-payment can be corrected with additional work. For example:
- If the BEAR requested too little, a second BEAR may be filed for the difference. A later billing or shipping date should be used to distinguish between the two amounts.
- If the BEAR payment was too much, the applicant should return the excess amount (see Returning Funds to USAC).
- Form 486: Form 486s, once filed within EPC, cannot be changed to correct service start dates, CIPA certifications, etc. One option is to cancel the Form 486 (via a Customer Service Request or by calling CSB), and refile (hopefully before the Form 486 deadline). Errors in service start dates, resulting in reduced funding, may be appealed — perhaps citing a clerical or ministerial error.
- Form 498: Form 498s filed within EPC can be changed. Once validated by USAC, however, altered Form 498s will have to be revalidated before use. It should be noted that applicants may file additional Form 498s — a process designed to permit the use of two or more bank accounts. However, filing of a second Form 498, while leaving an incorrect Form 498 in place, is not recommended.
New “FST” Data Tool Expected for FY 2016:
USAC expects to release Version 1 of a new FY 2016 funding report, to be called “FRN Status Tool” (“FST”) later this week. The initial version is expected to be similar to the Data Retrieval Tool (“DRT”), the long-time standard source of E-rate funding data for all funding years through FY 2015 (and the primary database driving E-Rate Central’s funding tools). The new FST may replace the existing View/Download FCC Forms 471 for FY 2016 tool, previously the main source of current year funding data, but which is difficult to use. Version 1 of the FST will provide a few additional information fields, most critically the Service Start Date denoting the approval of applicant Form 486s.
Version 2 of the FST, containing still more data elements, is expected to be released in the October/November timeframe.
IDERs for FY 2015:
The basic invoicing deadline for recurring FY 2015 services is October 28, 2016. As we have discussed in recent newsletters, this may be a tight deadline for applicants needing to file for last year’s reimbursements because of the new requirement to first file — and have USAC validate and approve — Form 498s. Many BEAR filers will also have to request and receive PINs in order to use the new online filing system.
Under new FCC rules and regulations, invoice deadlines are sacrosanct. The FCC rules permit USAC to automatically grant applicants one invoice deadline extension request (“IDER”) if — and this is critical — the IDER is filed on or before the initial deadline. For reasons we cannot comprehend, the FCC, which has been flexible in dealing with Form 471 and Form 486 deadlines, has been ruthless in denying invoice deadline waiver requests. October 28th, therefore, is a critical date to file most FY 2015 invoices or IDERs.
Applicants expecting any difficulties in meeting the October 28th invoice deadline can — and should — file their IDERs now. This will result in a new invoice deadline 120 days later (plus, in this case, the weekend) of February 27, 2017. The preferred procedure for filing an invoice deadline extension is to use USAC’s online Submit a Question feature.