E-Rate News Flash 18-14

E-Rate
  Friday, December 21, 2018

Issue 18-14

December 21, 2018

E-rate News Flash

Contents:

  • Announcements
  • Funding Commitment Summary
  • Pending Dates and Deadlines
  • Upcoming Training Events
  • E-rate Process: Activities to Work on Now

Announcements

Update on Funding Year 2019 FCC Form 471 Bulk Upload Templates

On November 30th, USAC released updated FCC Form 471 Bulk Upload Templates that allow filers to upload Category One and Category Two service information in bulk to their Form 471 applications. The templates are available on the USAC website and will be available in EPC when the application filing window opens. Please note the following:

  • The template for voice services has been removed. Starting with Funding Year 2019, voice services are no longer eligible for discounts.
  • For Internal Connections, applicants must use the revised template for Funding Year 2019. Previous templates will not be compatible with system requirements.

To download copies of the revised templates please refer to USAC’s November 30, 2018 News Brief. While USAC has not yet announced the Form 471 filing window for Funding Year 2019, applicants may plan ahead and complete their bulk uploads to be ready when the Form 471 is made available to file.

USAC Recovery Actions for Early Year Program Compliance Issues

In January 2017, the Federal Communications Commission issued an Order that affirmed that there is no limitation to the timeframe in which recovery of improperly committed and disbursed E-rate funds may occur. Henceforth USAC issued Commitment Adjustment Letters and Recovery of Improperly Disbursed Funds Letters to E-rate applicants and service providers for recovery of funds from very early years of the program, some more than 15 years old. Any applicant that receives such communication from USAC has 60 days in which to appeal the decision. It’s very important to not ignore the communication or any subsequent Demand Payment Letters which must be paid within 30 days. Failure to appeal or to make the required payment may initiate the applicant’s placement into Red Light Status. USAC may not make any recovery action if there is a timely filed appeal that is pending a decision either at USAC or the FCC, or both. If no appeal is filed and the entity responsible for paying the outstanding debt has not paid the debt, or otherwise made satisfactory arrangements to pay the debt within 30 days of the notice of delinquency, any pending FCC Form 471 applications will be dismissed.

USAC Transitioning of BPO Contractor

Starting January 1, 2019, USAC will transition its Business Process Outsourcing (BPO) from Solix to Maximus. The BPO functions include all E-rate Program Integrity Assurance Review, processing of pre and post-commitment forms and requests including Forms 471, 486 and 500, service substitutions, SPIN changes, appeals and invoices.

California Funding Commitment Summary

Funding Year 2018

USAC released FY2018 Wave 36 Funding Commitment Decision Letters (FCDL) on December 14, 2018. As of December 14, FY2018 California commitments total over $264 million.

Funding Year 2017

USAC released FY2017 Wave 61 FCDLs on November 9, 2018. There were no commitments for California applicants in Wave 61. As of November 9, FY2017 commitments total over $303 million.

Pending Dates and Deadlines

FCC Form 486 and Urgent Reminder Letters

FCC Form 486 must be filed 120 days from the date of the issuance of the Funding Commitment Decision Letter (“FCDL”) or the start date of E-rate eligible services, whichever is later. For ongoing recurring services, starting on July 1 2018, the following deadlines have passed or are approaching in the next month.

Wave #

FCDL
Date

Form 486 Due Date

1-12

4/20-6/28/18

10/28/18

13

7/6/18

11/3/18

14

7/13/18

11/10/18

15

7/20/18

11/17/18

16

7/27/18

11/24/18

17

8/3/18

12/1/18

18

8/10/18

12/8/18

19

8/17/18

12/15/18

20

8/24/18

12/22/18

21

8/31/18

12/29/18

 

USAC has begun issuing FCC Form 486 Urgent Reminder Letters to applicants that appear to have missed the deadline to certify an FCC Form 486. Applicants missing these or earlier deadlines should closely monitor their News Feed in the E-rate Productivity Center for an FCC Form 486 Urgent Reminder Letter. This letter will allow the applicant a 15-day extension to submit an FCC Form 486 without penalty.

USAC calculates the date to issue this letter based on the service start date reported on your FCC Form 471. If your actual service start date is later than the date you reported on FCC Form 471 then the deadline may not have passed. In this case, you are responsible for calculating your actual deadline as USAC will not issue additional reminder letters.  You can use the 486 Deadlines Tool to calculate your specific deadline.

If you miss the deadline, the service start date will be adjusted to 120 days prior to the date that the Form 486 was actually certified which will likely reduce the funding commitment.

Funding Year 2017 Non-recurring Services Invoice Deadline

In general, the deadline for invoicing USAC for FY 2017 non-recurring services is January 28, 2019.  While this date is still a few months off, it is important to be aware of this timeline since you are only allowed a single, one-time, 120-day extension of the invoicing deadline.

Applicants and service providers should plan to either (1) complete their invoicing process for these services or (2) request an invoice deadline extension no later than the January 28, 2019. 

How to File an Invoice Deadline Extension Request

For Funding Years 2016 and later, use the Invoice Deadline Extension Request Tool in the E-rate Productivity Center (EPC). The process is described in the September 21, 2018 Schools and Libraries Program News Brief.

For funding requests from Funding Years 2015 and prior, applicants may request the extension in the online BEAR system, by initiating a Customer Service Case initiated in EPC, or by calling the Client Service Bureau (CSB) at 888-203-8100. Service providers must request the extension via the CSB. Remember that an applicant must have a Personal Identification Number (PIN) issued by USAC in order to access the BEAR system.

Upcoming Training Events

Numerous training opportunities available for E-rate applicants are coming soon.

K12 High Speed Network Webinars and Workshops

https://www.k12hsn.org/resources/erate/trainings

Webinars

  • Completing FCC Form 471 for Category 1 Services

1/24/2019 at 2:00 p.m.

  • Completing FCC Form 471 for Category 2 Services

1/31/2019 at 2:00 p.m.

Workshops (Face-to-Face)

All face-to-face workshops start at 9 a.m. and end at 4:30 p.m.

  • Fresno County Office of Education

E-rate Beginner                                                                              1/14/2019

E-rate Intermediate/Advanced                                                     1/15/2019

EducationSuperHighway Webinars

https://www.educationsuperhighway.org/webinars/

  • 4 Ways to Get more Bandwidth for Your Budget

01/17/2019 at 10:00 a.m.

  • Build vs. Buy Calculator: Evaluate Your Fiber Bid Responses

01/24/2019 at 10:00 a.m.

 

E-RATE Process: Activities to Work on Now

Competitive Bidding and Responding to Service Provider Questions

As of July 1st, 2018, applicants have been able to post an FCC Form 470 for Funding Year 2019. The FCC Form 470 provides a Description of Services Requested and opens the minimum 28-day competitive bidding process. The competitive bidding process must identify the products and services an applicant is seeking so that potential service providers can review those requests and submit bids for them. Any additional documents, such as a request for proposal (RFP) must be uploaded onto the FCC Form 470 in the E-rate Productivity Center portal.

It is the applicant's responsibility to run an open and fair competitive bidding process.

  • All bidders must be treated the same.
  • No bidder can have advance knowledge or ‘insider’ information.
  • All questions received by the due date and due time must be answered.
  • All information must be shared with all potential bidders and all bidders must know what is required of them.

Applicants should be aware that answering questions that may change the original scope of services and/or requirements outlined in the Form 470 and/or RFP may require the restart of the 28-day competitive bidding period and in some cases may also require the posting of a new FCC Form 470.

Most often, a new FCC Form 470 is required when:

  • The original FCC Form 470 was certified without attaching any RFP documents, but you have now issued an RFP document and need to attach it.
  • You did not post services for a specific dropdown menu service type, and now realize that you need to post for services in that dropdown menu service type.

We caution applicants that if changes are significant, applicants must restart the 28-day clock. Applicants must count out the 28-days outside of EPC and extend due dates accordingly.