E-Rate News Flash 19-11

E-Rate
  Wednesday, July 24, 2019

Issue 19-11

July 24, 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

FCC Notice of Proposed Rulemaking on Continuing Category Two Budgets

In 2015 the Federal Communications Commission (FCC) initiated the five-year Category Two budget test program which established a per student/per school five-year funding allocation to help schools purchase equipment and services necessary to distribute the Internet on a school campus, commonly known as internal connections or WiFi.

On July 9, 2019, the FCC released a Notice of Proposed Rulemaking (NPRM) (FCC 19-58) proposing to make the Category Two budget approach permanent, and also seeks comment on the sufficiency of the per-student budget multiplier set in 2015 at $150 per student and annually indexed to inflation. The FCC asks for comment on whether or not the current five-year budget floor of $9,200 for small schools is sufficient, and if the floor is raised to $25,000 or higher, will it incentivize more small schools to participate in the E-rate program. The FCC is also seeking feedback from schools in rural areas on the sufficiency of the per-student budget to meet their needs and if there are examples of special circumstances which would warrant an increase in the budget multiplier for these schools.

The FCC also seeks comment on ways to improve the administration of the Category Two budget to make it easier for schools to apply for and receive funding. Suggested ideas include moving to a districtwide per-student formula rather than the current limitation to a school-based formula. The FCC asks if the five-year budget should be a five-year rolling model where each year’s formula is reduced by any funding committed in the previous four years, or if it should be a set five-year model where the budget resets every five years.

Interested parties are encouraged to file comments in the FCC’s Electronic Comment Filing System (ECFS) under proceeding 13-184 by August 16, 2019, and reply comments by September 3, 2019. Parties may also view posted comments in EFCS by doing a search in ECFS under proceeding number 13-184.

USAC to Fully Fund 2019 Category One and Category Two Applications

On July 17, 2019, the FCC announced that there is sufficient funding available to fully meet the Universal Service Administrative Company’s (USAC) estimated demand for Category One and Category Two funding requests for Funding Year 2019. This continues the trend observed since Funding Year 2015 when the FCC permanently raised the E-rate cap which was previously set at $2.25 billion. The current annual cap is $4.15 billion and the 2019 demand estimate is $2.896 billion, well under the cap.

USAC Reprints BEAR Notification Letters

On July 8, 2019, USAC reprinted FCC form 472 (BEAR) Notification Letters for applicants that submitted BEAR reimbursement requests from December 21, 2018, through June 14, 2019.

Applicants that received reprints should verify that the disbursement amounts listed within the letter match the requested amounts or the agreed adjusted amounts of the BEAR. Applicants that received zero payment notifications and/or do not agree with the adjusted amounts have 60 calendar days to file an appeal with USAC from the date of the letter.

IMPORTANT: If the last day to invoice on the funding request has passed, applicants must also request an invoice deadline extension in their BEAR Notification Letter appeals.

Applicants should follow appeal instructions outlined in the BEAR Notification Letters.

California Funding Commitment Summary

Funding Year 2019

USAC released FY2019 Wave 12 Funding Commitment Decision Letters (FCDL) on July 11, 2019, bringing cumulative commitments to over $119 million for California applicants. Funding for Category Two remains sluggish representing only 8% of funding commitments thus far.

Funding Year 2018

USAC released FY2018 Wave 59 Funding Commitment Decision Letters (FCDL) on July 2, 2019. The wave did not include additional commitments for California. California commitments remain just over $276 million.

Pending Dates and Deadlines

Funding Year 2018 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

1-50

4/20/2018-3/22/2019

Deadline passed for services starting July 1, 2018

51

*No funding for CA applicants

52

4/4/2019

8/2/2019

53

*No funding for CA applicants

54

4/18/2019

8/16/2019

55

5/14/2019

9/11/2019

 

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.

Funding Year 2019 FCC Form 486

The First FCC Form 486 deadline for FY 2019 will be October 28, 2019.

Invoice Deadline for Funding Year 2018 Recurring Services and Special Construction

The invoice deadline for recurring services is the first business day 120 calendar days after the date of the FCC Form 486 Notification Letter or 120 calendar days after the last date to receive services, whichever is later. October 28, 2019, is the deadline for most applicants and service providers to submit invoices for recurring services and products delivered during Funding Year 2018.

Applicants and service providers may request a one-time, 120-day extension of the invoice deadline. The extension request must be filed on or before the invoice deadline of October 28, 2019. You can use USAC’s Instructions for completing an Invoice Deadline Extension Request.

IMPORTANT: Applicants are advised to request the one-time 120-day invoice deadline extension for funding requests currently pending appeal decisions and/or post-commitment changes.

Service Delivery Deadline for Non-Recurring Services other than Special Construction

The deadline for delivery and installation of non-recurring services such as Category One broadband installation and Category Two Internal Connections is generally September 30 following the close of the funding year (i.e., 15 months after the beginning of the funding year). The exception is for Category One special construction which has a service delivery deadline of June 30 of the applicable funding year.

Applicants with funding requests that contain non-recurring products or services that have not yet been delivered or installed must file a Service Delivery Deadline Extension Request on or before the September 30, 2019 deadline.

Use FCC Form 500 to file an extension request. You can use USAC’s guidance on how to file the extension.

Upcoming Training Events

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

USAC Webinars

USAC Webinars

  • The E-rate Invoicing Process

08/21/2019 at 12:00p.m. PDT

Recordings of previous webinars are posted on the USAC website. USAC most recently held a webinar on the FCC Form 470 and Competitive Bidding.

K12 High Speed Network Webinars

K12 High Speed Network Webinars

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

Collect and Document Bills for Funding Year 2018 Recurring Services

The Funding Year 2018 Invoice Deadline for Recurring Services is October 28, 2019, and is applicable to both the Service Provider Invoice (SPI) and Billed Entity Applicant Reimbursement (BEAR) invoicing methods.

The FCC Form 472 (BEAR) is filed after eligible services have been both received and paid for by the applicant. Determining the E-rate eligible costs is accomplished by compiling the bills for the approved services on your FCC Form 471. Arriving at the total eligible costs will require a calculation that is based on the monthly bills for services received during the period of July 1, 2018, to June 30, 2019. By identifying the eligible services on the bills and deducting the costs for any ineligible services you will arrive at the amount to request reimbursements for on the BEAR.

The FCC Form 474 (SPI) is filed by the Service Provider after the eligible discounts have been applied to the applicant’s bills. The process of collecting the bills and calculating the total eligible costs is still necessary for the SPI method in order to confirm that the correct amount of E-rate discounts were applied to the bills.

Remember to retain all bills and calculations to support your E-rate discount requests for a minimum of 10 years from the last date to receive service.