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October 17, 2016

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Wave 16 for FY 2016, released last Monday, totaled $45.9 million. Cumulative national funding through Wave 16 is $694 million. Wave 17 is scheduled for release today, October 17th.

Funding delays, particularly for large applications, continue to be a problem for applicants and service providers alike. The CEO of one public technology company recently explained disappointing third quarter revenues stating: “The pace of E-Rate funding approval letters slowed significantly in the last weeks of the third quarter. As of the end of the quarter, funding approvals for the program were running nearly 70 percent below the pace of last year.”  Commenting on fourth quarter expectations, the company noted that its outlook  “…assumes no improvement in the pace of E-Rate funding approvals.”

USAC will release Wave 66 for FY 2015 on Wednesday, October 12th.  Cumulative funding through Wave 65 is $3.31 billion.

Using the BEAR System’s Track Form Tool:

The deadline for filing invoices (BEARs and SPIs) for FY 2015 recurring service discounts is October 28th, less than two weeks away. The two most important points applicants need to know about filing BEARs by this date are that:

  1. Creating and certifying BEARs in the online BEAR system requires both an approved Form 498 and a personal PIN. Fulfilling either or both pre-filing requirements can easily take two or more weeks.
  2. Applicants in danger of missing the October 28th deadline must file an Invoice Deadline Extension Request (“IDER”) on or before that date.

Applicants filing one or more BEARs should carefully track submitted BEARs and payments. The best way for tracking the BEARs themselves is to use the Track Form tool within the BEAR system itself.

Track BEAR Form

The search screen provides a flexible means of generating a list of submitted BEARs. The following tips may prove useful.

  1. There are several search options for finding summary data for a specific BEAR, including:
    1. The “Invoice Id” — generated and displayed as soon as the BEAR is submitted
    2. The “Applicant Form Identifier”
    3. The “Created Date Range”

  2. Hint:    To find a BEAR on the day it was submitted, the date range must include the following day’s date. If not, the search result will show:

    No BEARs exist warning.
     
  3. “BEAR” is the default on the “Display Results As” radio buttons (as shown above). The alternative “FRN” display includes the same basic BEAR information (10 fields), but (as shown below) provides additional BEAR Line Item information (5 fields per line). Both displays link to the invoice itself.
    BEAR Search Results
  4. The BEAR “Status” shows “PASSED VALIDATION” when first submitted and changes to “COMPLETED” when approved. The “Line Item Status” shows “CERTIFIED” when first submitted, may change to “IN USAC REVIEW,” and to “COMPLETED” when approved.
  5. Because the online BEAR is part of USAC’s legacy system, not EPC, the tracking tool includes historical BEAR data tracing back to FY 1999. For a complete BEAR history, leave all the search fields blank and simply click “Search.”

We recommend using the BEAR tracking tool to periodically — and most importantly prior to the October 28th invoice deadline — generate a list of all FY 2015 BEARs filed to date, checking that:

  1. BEARs have been filed for all FRNs funded and used (not otherwise discounted by the service providers).
  2. The requested pre-discount and requested reimbursement amounts are correct.
  3. No BEARs have been duplicated.
  4. Actual reimbursement bank payments for “COMPLETED” BEARs have been received electronically.

Upcoming 2016 E-Rate Deadlines:

October 21 FCC deadline to submit nominations for six directors on the USAC Board. (See DA 16-1018 or our newsletter of September 19th.
October 28 Invoicing deadline for recurring service charges for FY 2015. Applicants planning to file for BEAR reimbursements need an active PIN and must have filed (subject to approval) a Form 498. Completion of either of the preceding steps can easily take two or more weeks. (See our newsletter of August 29th.)  Invoice deadline extension requests (“IDERs”) must be made — and are recommended to be made — on or before this date. (See our newsletter of September 12th.)
October 31 Form 486 deadline for FY 2016 funding committed in Waves 1–2. More generally, the Form 486 deadline is 120 days from the FCDL date or the service start date (often July 1st), whichever is later. This means that Form 486 deadlines for funding received in later waves will follow at roughly one week intervals, including the following November deadlines:

Wave 3        11/07/2016
Wave 4        11/14/2016
Wave 5        11/21/2016
Wave 6        11/28/2016

November 3 FCC deadline for submitting comments on the Boulder Valley and Microsoft petitions regarding off-campus use of existing E-rate supported connectivity. (See DA 16-1051 and our newsletter of September 26th).

USAC Fall Training Schedule:

The locations and dates for USAC’s remaining regional trainings are listed below. Note that USAC has added a session in Puerto Rico, to be conducted “EN ESPAÑOL.”  For registration information, see Trainings & Outreach.

Philadelphia, PA Tuesday, October 18, 2016
San Juan, PR Thursday, October 27, 2016
Minneapolis, MN Tuesday, November 1, 2016 (waiting list only)
St. Louis, MO Thursday, November 10, 2016 (waiting list only)
Seattle, WA Wednesday, November 16, 2016
Los Angeles, CA       Friday, November 18, 2016 (waiting list only)

Slides for the Philadelphia training have been posted on the USAC website.

USAC Training Videos:

USAC added two more short training videos to its Online Learning Library demonstrating the filing of a Form 486 and Form 472 (BEAR).

USAC’s Schools and Libraries News Brief of October 7, 2016, discusses the process for filing a Form 486 in EPC to confirm that services have started and that, if required, the applicant is CIPA-compliant. The following steps are discussed:

  1. Creating the basic Form 486
  2. Selecting the FRNs
  3. Specifying service start dates
  4. Early filing and CIPA waiver
  5. Previewing the completed form
  6. Certifying the completed form

The News Brief also deals with the following three situations, likely to affect only a limited number of filers, but requiring special attention:

  1. Correcting a Form 486 inappropriately filed by a “child” (as opposed to a “parent”) entity
  2. Filing a new Form 486 for FRNs included in a previously canceled Form 486
  3. Dealing with — actually avoiding — multiple Form 486s referencing the same FRNs