Form 486 and Invoicing Capability for FY 2017:
As noted in our newsletter of July 10th, EPC has been updated to permit the filing of Form 486s for approved FY 2017 applications. As a part of the update, EPC will also generate the electronic equivalent of Form 486 Notification Letters once Form 486s have been approved.
What has not been implemented yet — but should be shortly — is the Form 486 interface between EPC and USAC’s legacy invoice system. Until this occurs, neither service providers nor applicants can file invoices for FY 2017 FRNs. The effect of this temporary restriction is most likely to impact applicants seeking discounted service provider invoices (“SPIs”) for services billed in the month of July.
Our recommendation for applicants in this position is to:
- Clearly indicate to their service providers that they are choosing discounted billing;
- Make sure that their service providers have received notification that their FRNs and associated Form 486s have been approved; and
- Seek agreement that they will be paying only the non-discounted portions of any July invoices.
Jefferson-Madison Invoice Extensions:
On May 30th, the FCC released the Jefferson-Madison Order on Reconsideration (DA 17-526) that, in the main, granted invoice extensions to a list of applicants who had filed timely BEARs for FY 2014, but had those BEARs rejected because their service providers had not acknowledged the BEARs by the invoice deadline (as was required at the time*. This was a reversal of a previous FCC decision denying such extensions. In addition to the applicants specifically listed in Appendix A of the Order, the FCC instructed USAC to process invoices from any other applicants whose BEARs had been denied for a similar reason (see our newsletter of June 5th).
As of last week, USAC indicated that all of the applicants listed in the Order had been notified that their previously-denied invoices can now be re-filed. In doing so, USAC established a new invoice deadline of August 28th — ninety days from the release of the Order. The new deadline for the associated FY 2014 FRNs is reflected in the FRN Extension Table.
USAC is still working to identify and notify any other applicants not specifically listed in the Order.