E-Rate News Flash 19-07

E-Rate
  Monday, April 29, 2019

Issue 19-07

April 29, 2019

E-rate News Flash

Contents:

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

Announcements and News

2019 FCC Form 471 Filing Window Closed: Statistics

The Funding Year 2019 FCC Form 471 application window closed March 27. While the 2019 E-rate program cap was set by the Federal Communications Commission at $4.151 billion, the total demand as of the close of the window was reported by the Universal Service Administrative Company (USAC) as $2.896 billion, well below the cap. Nationally, 66% of the funding requests filed were for Category 1 services and 34% were for Category 2. The total funding requested by California’s school and library applicants was $357 million, a little over 12% of all funding requested nationwide. California’s applicants requested $245 million in Category 1 and $112 million in Category 2 funding. Nearly 3,000 FCC Form 471 applications were filed in California for a total of 8,036 funding requests. As of April 19, over one thousand California applications representing 1,587 funding requests are in “Wave Ready” status and will be receiving Funding Commitment Decision Letters (FCDLs) when USAC issues the first funding wave.

California Teleconnect Fund Rulemaking 13-01-010

The California Public Utilities Commission (CPUC) has undertaken further rulemaking in its comprehensive examination of the California Teleconnect Fund (CTF) program. The CTF program provides eligible schools an additional discount up to 50% on qualifying broadband services, net of E-rate Category 1 discounts. Currently, schools may also receive a 25% discount on voice services. On March 18, 2019, Commissioner Liane M. Randolph issued a decision to eliminate the 25% CTF discount for voice services, effective July 1, 2019, and to expand CTF-eligible services to include all mobile data services. The Commission is scheduled to vote on this decision at its April 25, 2019, CPUC Voting Meeting in San Francisco. Stakeholders may comment on this rulemaking either in person at the April 25 public meeting or by contacting the CPUC’s Public Advisor.

California Funding Commitment Summary

Funding Year 2018

USAC released FY2018 Wave 54 Funding Commitment Decision Letters (FCDL) on April 18, 2019. As of April 19, FY2018, California commitments total over $275 million.

Pending Dates and Deadlines

Funding Year 2017 Non-Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing USAC for FY 2017 non-recurring services was January 28, 2019.  Applicants and service providers that requested and were approved for the single one-time 120-day extension now have an invoice deadline of May 28, 2019. Any additional invoices filed after May 28, 2019, will not be accepted by USAC and require an approved waiver from the FCC of the invoice deadline extension rule. Note that the FCC will only issue waivers of the invoice deadline for extraordinary circumstances.

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.

Waves #

FCDL
Date

Form 486 Due Date

1-37

4/20-12/20/18

Deadline passed for services starting July 1, 2018

38

12/27/2018

4/26/2019

39

1/3/2019

5/3/2019

40

1/11/2019

5/11/2019

41

1/16/2019

5/16/2019

 

USAC issues 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.

June 30 Category 1 Special Construction Deadline

Funding Year 2018

The deadline for completion of special construction for Category 1 services for Funding Year 2018 is on or before June 30, 2019. Applicants seeking support for special construction related to Category 1 services must request a one-time extension of the June 30 service delivery deadline by demonstrating that construction was unavoidably delayed due to reasons beyond the Applicant’s and/or Service Provider’s control. Applicants who have received Funding Commitment Decision Letters for their 2018 special construction funding request(s) may obtain this one-time extension by filing an FCC Form 500 for the associated FRN(s) on or before the June 30 deadline. Applicants that have 2018 funding requests that have not yet received a funding commitment decision must still file a request for extension on or before the June 30, 2019, deadline. Please see USAC’s May 25, 2018, News Brief for more information on how to file Special Construction extensions.

Funding Year 2017

It is important to note that USAC may only authorize a single one-year extension for special construction funding requests. For applicants who may have received this extension for 2017 funding requests, the extended deadline for delivery of services is June 30, 2019. If services are not installed and operational by this deadline, the applicant should file a waiver request with the Federal Communications Commission (FCC) under proceedings 02-6 and 13-184, and explain what extraordinary circumstances prohibited timely installation and delivery of services.

Upcoming Training Events

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

USAC Webinars

USAC Webinars

  • Starting Services: FCC Form 486

05/15/2019 at 12:00 p.m.

K12 High Speed Network Webinars

K12 High Speed Network Webinars

  • Reviewing and Understanding the Funding Commitment Decision Letter

05/16/2019 at 2:00 p.m. (Note: NEW DATE!)

  • Appeals and Requests for Waiver, CALs and RIDFs, Red Light Status

06/13/2019 at 2:00 p.m.

Recordings of previous webinars are posted on the K12HSN website

EducationSuperHighway Webinars

EducationSuperHighway Webinars

Recordings of previous webinars are posted on the EducationSuperHighway website.

E-RATE Process: Activities to Work on Now

Responding to USAC PIA Inquiries

All FCC Form 471 applications undergo Program Integrity Assurance (PIA) review. In some instances, USAC reviewers may reach out to the Contact person listed on the FCC Form 471 to ask questions about the application and/or request documentation to substantiate the eligibility of services, the eligibility of entities receiving services, and the data used to calculate the E-rate discount. Applicants have 15 days to respond to USAC’s request for information, and may request an additional seven-day extension. While responses to USAC’s questions occur in the E-rate Productivity Center (EPC), the outreach from USAC will be sent to the Contact’s e-mail address. Failure to respond to USAC’s questions will lead to the denial of the FCC Form 471 funding requests; make sure to respond by the deadline indicated or request an extension, if needed.

How are Applicants notified of PIA Inquiries?

The PIA reviewer will send an email to the FCC Form 471 Contact to let them know that questions are available through the EPC News Tab.

The notification in the EPC News tab will include:

  • Today's date
  • Response due date
  • Contact name
  • Applicant name
  • FCC Form 471 application number
  • A brief description of the question or questions
  • Your PIA reviewer's name and telephone number
  • A hyperlink to your questions (the blue bar at the bottom of the notification)

How do Applicants view and respond to PIA Inquiries?

The EPC News item will include a hyperlink to the application that will take applicants to the application Summary page of the associated FCC Form 471. To view a complete list of PIA inquiries applicants must then navigate to the Review Inquiries page.

If applicants submitted more than one FCC Form 471 that requires PIA review, they will receive a separate set of questions for each form. Make sure to respond to all inquiries/questions on each FCC Form 471.

Applicants can perform the following actions from the Review Inquiries page by following the menu options on the top of the page:

  1. Respond to Inquiries
  2. Request an extension of time to respond
  3. Submit a RAL modification request (See Previous News Flash (19-06) for more information on RAL Corrections)

When responding to inquiries, applicants will see two-page sub-menus: Pending Inquiries and Submitted Inquiries.

Pending Inquiries will include the list of any pending inquiries, the read status, the outreach type, the reviewer’s name and contact information, the date the inquiry was issued, the date inquiry is due, and inquiry status. When selecting individual inquiries, applicants have the ability to view the individual question and upload supporting documentation. Please note: Only one user can work on an inquiry at a time. Users must Save and Close out of inquiries for other to access the inquiry. When applicants are satisfied with the drafted response and any supporting documentation, if any, they must click Submit to send the response to the inquiry.

Submitted Inquiries are responses that have been submitted to the PIA reviewer.

How do Applicants request an extension of time to respond to PIA Inquiries?

Generally, PIA inquiries are due 15 days from the day they are issued. If they due date falls on a weekend, inquiries are moved to the following business day. Applicants may request more time to respond to PIA inquiries while they gather necessary information. When extension requests are submitted in EPC, applicants will automatically be granted the first request and will receive an additional seven days to respond.

Subsequent extension requests are not approved automatically and are subject to review by the PIA Director. The decision to grant the extension request will appear in the Review Inquiries page in the form of an extended due date. Decisions to deny the extension request appear in the comments section at the bottom of the original PIA News notification. Applicants are encouraged to call or e-mail their assigned PIA reviewer if there are special circumstances that will necessitate additional time and if their request for extension is denied. If the PIA reviewer is unresponsive, open a customer service case in EPC, or call USAC at (888) 203-8100.