E-Rate News Flash 19-08

E-Rate
  Friday, May 17, 2019

Issue 19-08

May 17, 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

USAC Issues First Funding Waves for 2019

The Universal Service Administrative Company (USAC) issued the first wave of funding commitments for Funding Year 2019 on April 27, 2019. In the first wave, USAC approved 1,675 funding requests for over 1,000 of California’s school and library applicants, for a total of 14% of all funding requested in California. The majority of the approved funding requests were for Category 1 services. USAC typically issues funding waves on Thursday evenings; the contact person and certifier of the FCC Form 471 will receive a notification via e-mail with the attached Funding Commitment Decision Letter (FCDL). Applicants may check the status of their FCC Forms 471 using USAC’s FRN Status Tool and doing a search by their associated main Billed Entity Number (BEN).

Tariffs on Chinese Imports and Category 2 Services

On May 10, 2019, the United States Government published the Statement By U.S. Trade Representative Robert Lighthizer on Section 301 Action announcing that it would impose 25% tariffs on goods imported from China. E-rate applicants may have questions about how these tariffs may impact the cost of their Category 2 network infrastructure projects. Applicants are encouraged to contact the manufacturers of the equipment they plan to purchase to request information on whether or not the cost of tariffs will be passed on to the end customer. To date, neither USAC nor the Federal Communications Commission (FCC) has formally addressed the possible increased cost that E-rate applicants may pay due to tariffs, nor have there been any adjustments to the per-school Category 2 budget amount to accommodate price increases due to tariffs.

EBS Proceeding

In May 2018 the Federal Communications Commission (FCC) initiated a proceeding on the Educational Broadband Service (EBS) which consists of wireless spectrum licensing in the 2.5 GHz band (2496-2690 MHz). Historically, educational agencies exclusively were able to apply for and obtain licenses to this spectrum for educational purposes. However, access to new licenses by educational agencies has been severely limited since 1995 even as many educational agencies have initiated community-wide wireless projects to allow for students to access the Internet while at home in order to close the so-called “Homework Gap.” In its Notice of Proposed Rulemaking under proceeding number 18-20, the FCC asked for comment on opening access to EBS licensing again, first to educational agencies for a short period of time, and then after that single one-time application period to public auction. At this time, the FCC may make a decision on the proceeding during the summer, although certain parties have requested an extension of the comment period through the FCC Electronic Comment Filing System (ECFS) Proceeding WTB 18-120. There is also a public advocacy effort (SaveEBS) to retain EBS for use by educational agencies for educational purposes. Any parties wishing to comment on the proposed changes may do so by submitting comments through the ECFS Express Comment web page and citing proceeding number 18-20.

California Funding Commitment Summary

Funding Year 2019

USAC released FY2019 Wave 2 and Wave 3 Funding Commitment Decision Letters (FCDL) on May 2, 2019, and May 9, 2019. As of May 14, 2019, California commitments total over $67 million.

Funding Year 2018

USAC has not released any new FY2018 Funding Commitment Decision Letters (FCDL) since April 18, 2019. As of May 14, 2019, FY2018 California commitments total over $274 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.

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

1-41

4/20/2018-1/16/2019

Deadline passed for services starting July 1, 2018

42

1/25/2019

5/25/2019

43

*No funding for CA applicants

44

2/7/2019

6/7/2019

45

2/15/2019

6/15/2019

46

*No funding for CA applicants

47

3/1/2019

6/29/2019**

48

3/8/2019

7/6/2019**

**Deadlines that fall on a weekend are due the following business day

 

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 visit the USAC Appeals web page, 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

Recordings of previous webinars are posted on the USAC website. USAC most recently held a webinar on starting services and preparing the FCC Form 486.

K12 High Speed Network Webinars

K12 High Speed Network Webinars

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

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

  • FCC Form 486 and CIPA Compliance

06/27/2019 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

Review Your 2019 Funding Commitment Decision Letter

The purpose of the Funding Commitment Decision Letter (FCDL) is to notify applicants and service providers which funding requests were approved, denied or cancelled, and how much funding was committed. The FCDL notification will arrive via email to the FCC Form 471 contact person, form certifier, and the general contact for the service provider.  The email notification will include a PDF summary and a CSV file supporting the commitments and/or changes made by USAC during the review process. Additionally, the FCDL is accessible in the applicant’s “News” header in the E-rate Productivity Center (EPC) and viewable by any user in the organization with viewing rights. FCDLs are issued by individual FCC Form 471.

Applicants are encouraged to review the FCDL as soon as they are issued. If an applicant does not agree with a commitment, denial, cancellation, and/or change that USAC has made to the application or any funding request, the applicant has 60 days from the date of the FCDL to file an appeal through the USAC Appeals web page.

When reviewing FCDLs, applicants should verify the application comments, committed amounts, monthly recurring and one-time costs, discount percentage, service provider information, and total number of funding requests. The PDF and CSV files provide summary information.  If applicants are looking to verify corrections or changes to more detailed information such as: contract records, individual site enrollments, parent/child relationships, line item details and unit costs, quantities, or recipient of services (ROS), the applicant will need to log in to EPC.

In EPC, the applicant may access individual modules from the main BEN landing page and navigate to the “FCC Forms” section. From there, select “FCC Form 471” as the Category and “2019” as the Funding Year. A list of FCC Form 471s will load for the applicant. Using the hyperlinks to individual FCC Form 471s, the applicant can navigate and view: Summary, Funding Requests, Discount Calculations, or Entity Information. Funding Request Number (FRN) line item details can be accessed by using the individual FRN hyperlinks and selecting each line item to view details.

Currently, under the Summary view for individual FCC Form 471, applicants may scroll to the bottom of the section to view “FCC Form 471 Generated Documents”. The “Original Version” of the FCC Form 471 can be downloaded in PDF form by selecting the hyperlink. USAC system updates will soon include a full PDF version of the “Committed Version” of the FCC Form 471 to help simplify and avoid having to view individual module information via multiple screens in EPC. In between the system updates, Applicants who receive an FCDL will be sent “Committed Version” of the FCC Form 471 at a later date.