Non-Recurring Service Delivery Deadline September 30th:
The regular service delivery deadline for non-recurring services (e.g., the delivery and installation of Category 2 equipment or the installation charge component of Category 1 services) for FY 2015 is September 30, 2016. Requests to extend this deadline must be made on or before this date. Note the following:
- FY 2015 non-recurring service delivery deadlines already may have been automatically extended one full year if the associated FRNs, FCDLs, operational SPIN changes, or service substitutions were approved on or after March 1, 2016.
- Service delivery deadlines may also be extended upon request if: (a) USAC payments on valid invoices had been withheld; or, more commonly, (b) “the service provider was unable to complete delivery and installation for reasons beyond the service provider’s control.”
- A service delivery extension request may be made only by an applicant via a Form 500 (Section 8, page 2). Although the Form 500 requires only a simple check-off for one of the acceptable extension reasons, USAC will generally require a fuller explanation before the extension is granted. Since the Form 500 is a paper form, an applicant may shorten the approval process by appending that explanation when submitting the form.
- The easiest way to check if a service delivery extension request has been approved is by using USAC’s Display FRN Extensions tool, previously referred to as the “FRN Extension Table.” This tool shows both invoice and service delivery deadline extensions. Service delivery extensions will also automatically extend the associated invoice deadline.
- Often, when a service delivery deadline is extended, the associated contract must also be extended. This is a separate two-step process, namely:
- The applicant and the service provider must agree in writing to extend the contract through the new service delivery deadline; and
- The applicant must notify USAC of the extended contract expiration date, again via a Form 500 (Section 7, page 2). Note: If the applicant first extends the contract, the same Form 500 may be used to request the service delivery extension and to notify USAC of the new contract expiration date.
ALA Softens Stance on Library Internet Filtering:
The American Library Association (“ALA”) conducted a webinar last week discussing E-rate, filtering, and cyber-security. Historically, the ALA has been a strong critic of E-rate’s CIPA requirements, particularly the requirement to filter Internet access. To date, many libraries have foregone E-rate discounts — except, in some cases, for telecommunications services not subject to CIPA.
As noted in its webinar slides, the ALA still “cannot” recommend filters and continues to support libraries that don’t filter. Its stance, however, seems to be softening. It now “understands” that some libraries feel they must filter either because of local (e.g., political) or economic considerations.
Changes in the E-rate rules have dramatically changed the economics of, and to what extent, libraries would or would not participate in E-rate. In particular:
- The phase-out of discounts for voice services is severely cutting the benefits of those libraries previously limiting E-rate use to telecommunications-only services; and
- Enhanced funding for broadband Internet and internal WiFi services, increasingly needed by the libraries, is enhancing the value of E-rate.
ALA’s focus in this webinar was a call to minimize filtering for libraries needing to be CIPA-compliant, recommending:
- Selecting the most flexible filter
- Maintaining maximum local control
- Using the lowest filter setting possible, i.e.:
- Blocking as little as possible consistent with CIPA
- Not be tempted to block otherwise “offensive” content just because a filter makes that “easy to do”
FCC Proposes 4Q16 USF Contribution Factor:
The proposed contribution factor (see DA 16-1024) for the fourth quarter of 2016 is 17.4%. This is the percentage of interstate and international telecommunications revenues charged to telecommunications carriers to support the four Universal Service Fund (“USF”) programs, including E-rate. The 4Q16 percentage rate is consistent with recent quarters. What is significant, however, is that the contributing factor associated with the E-rate program’s requirement to fund FY 2016 equates to barely over $1.6 billion on an annual basis — only because the FCC had previously rolled over $1.9 billion in unused funding from earlier years, the largest roll-over amount in E-rate history.
Looking forward to FY 2017, and with three quarters to go, the amount of E-rate funds available for roll-over is just $200 million. Assuming a lower roll-over amount for FY 2017, the USF contribution factor may climb closer to 20%.
FCC Seeks Nominations for USAC Board:
The FCC issued a Public Notice (DA 16-1018) seeking nominations for six positions on the USAC Board. Terms of the current Board members in these slots expire December 31, 2016. From an E-rate perspective, the two most important nominations are held by Robert Bocher (an experienced E-rate consultant for the Wisconsin Department of Public Instruction), representing libraries, and Dr. Daniel A. Domenech (Executive Director of the American Association of School Administrators), representing schools. Both are expected to seek re-nomination.
Nominations are due October 21, 2016.
USAC Fall Training Schedule:
USAC has posted the following locations and dates for its annual fall training series on its Trainings & Outreach site. Note that registration for two of these sessions is already on a waiting list basis.
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Washington, DC |
Monday, September 26, 2016 (waiting list only) |
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Orlando, FL |
Thursday, October 6, 2016 |
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Houston, TX |
Friday, October 14, 2016 |
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Philadelphia, PA |
Tuesday, October 18, 2016 |
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Minneapolis, MN |
Tuesday, November 1, 2016 |
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St. Louis, MO |
Thursday, November 10, 2016 |
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Seattle, WA |
Wednesday, November 16, 2016 |
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Los Angeles, CA |
Friday, November 18, 2016 (waiting list only) |