E-Rate News Flash 19-12

E-Rate
  Wednesday, August 7, 2019

Issue 19-12

August 6, 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

Comments Due for Continuation of Category Two Budgets

The July 24, 2019, E-rate News Flash contained information regarding the Federal Communication Commission’s (FCC) Notice of Proposed Rulemaking on continuing E-rate Category Two budgets. 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.

FCC Proceeding on Universal Service Fund Cap Reply Comments Due

Initial comments have been posted in ECFS under proceeding number 06-122 to the FCC’s proposal to cap the Universal Service Fund and to combine the caps of the E-rate and Rural Health Care Programs. Numerous educational agencies and advocacy groups in California and across the country have filed comments against the FCC’s proposal. Interested parties may submit reply comments in support of comments filed in ECFS by August 26, 2019.

K12 HSN Letter of Agency Collection

The K12 High Speed Network will be contacting participants in the statewide E-rate consortium for high-speed broadband access who have current Letters of Agency that are set to expire on June 30, 2020. The statewide consortium secures E-rate funding for high-speed aggregator circuits to connect regional node sites of the K12 HSN to California’s Research and Education Network (CalREN) operated by CENIC. If you are contacted by the K12 HSN, please plan to return your signed Letter of Agency by August 23, 2019. Participation in the consortium does not affect an individual school or school district’s ability to file for E-rate funding for its own Category One and Category Two services.

GAO Issues Report on Off-Campus Wireless Internet

In the Consolidated Appropriations Act, 2018, Congress directed the General Accounting Office (GAO) to undertake a study on the availability of wireless Internet hot spots in low-income neighborhoods, particularly for elementary and secondary school-aged children, and to identify how to encourage home broadband adoption by households with elementary and secondary school-age children in such neighborhoods. On July 29, the GAO issued its Wireless Internet report stating that children aged 6-17 in low income neighborhoods do face challenges in accessing wireless Internet. The GAO recommended that the FCC take steps to assess and publish the potential benefits, costs, and challenges of making off-premises wireless access eligible for E-rate support and the FCC agreed to undertake these steps.

California Funding Commitment Summary

Funding Year 2019

USAC released FY2019 Waves 13 and 14 on July 18, 2019, and July 25, 2019, respectively. As of August 1, 2019, cumulative commitments for California applicants for Category One are $119,752,580.52 and $14,181,606.24 for Category Two.

Funding Year 2018

USAC has not released any FY2018 Waves of Funding Commitment Decision Letters (FCDL) since the July 24, 2019, E-rate News Flash.

Pending Dates and Deadlines

Applicants may view or calculate their E-rate deadlines on USAC’s website.

Filing FCC Form 500 Service Delivery and Contract Extensions

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. Applicants with funding requests that contain non-recurring products or services that have not yet been delivered or installed must start working now on filing the FCC Form 500 to request USAC to extend the service delivery deadline and report extended contract end dates.

The service delivery and/or contract extension requests must be submitted to USAC on or before the September 30, 2019, deadline. Requests received after this deadline cannot be processed by USAC. The applicant must request a service delivery extension by filing the request on an FCC Form 500. Requests coming directly from a service provider cannot be processed.

Applicants should check the expiration date on their contracts and, if allowed by the contract and local Board policy, extend their contract and notify USAC of the new contract expiration date via the FCC Form 500. USAC will not approve invoices for services or products delivered after the contract expiration date reported on the funding request or after the original (or extended) service delivery deadline.

To file the FCC Form 500 for Funding Year 2016 and forward, the applicant must prepare its form in the E-rate Productivity Center (EPC). The USAC News Brief from May 17, 2019, provides instructions on how to complete and certify the FCC Form 500 in EPC. To file the FCC Form 500 for Funding Year 2015 and previous funding years, see USAC’s guidance on how to file.

For more information on how to review for service delivery deadlines and instructions on how to complete the FCC Form 500, as well as invoice USAC for discounts, please visit the Trainings on the K12 High Speed Network website and view the webinar titled E-rate Invoicing and FCC Form 500.

FCC Form 486 Filing Reminder

The FCC Form 486 Receipt of Service Confirmation and Children's Internet Protection Act Certification Form, notifies USAC that the billed entity and/or the eligible entities that it represents is receiving, or has received, service in the relevant funding year from the named service provider(s).

Funding Year 2019

The first FCC Form 486 deadline for FY 2019 will be October 28, 2019. 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 notification. This letter will allow the applicant a 15-day extension to submit an FCC Form 486 without penalty.  

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

Upcoming Training Events

Numerous training opportunities available for E-rate applicants.

USAC Applicant Fall Training Event

USAC still has space available at its October 31 – November 1, 2019, applicant training event to be held at the California State University, San Marcos. The training, available to attendees free of charge, begins with an optional half-day afternoon session targeted to beginners followed by a full-day training that includes separate breakout sessions for beginners and for more advanced users. See the E-rate Applicant and Service Provider Training Registration form.

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

Service Provider Identification Number (SPIN) Changes

Invoicing for a funding request may be put on hold due to an incorrect SPIN currently being associated with a funding request. There are two types of SPIN changes: Corrective SPIN Change or an Operational SPIN Change.

Corrective SPIN Change

Corrective SPIN Changes are required when the incorrect SPIN is reported on a funding request but services are still being provided by the service provider of record. Incorrect SPIN reporting may be a result of:

  • Data entry errors were made when the FCC Form 471 was submitted.
  • Your service provider has multiple SPINs and you chose the incorrect SPIN.
  • A merger or acquisition has occurred: The original service provider has merged or has been acquired by another company and the SPIN indicated on the FRN has changed.

Additional information and instructions for completing a Corrective SPIN Change are located at USAC’s website.

Operational SPIN Changes

Operational SPIN changes are commonly required when the applicant is required to change the associated SPIN on a funding request due to reasons beyond its control. This occurs when the original service provider is unable or unwilling to perform the services associated with the approved funding request.

Operational SPIN Changes are allowed in very limited situations that must meet the following requirements:

  • California and local procurement rules allow it.
  • Terms of any contract between the applicant and its original service provider allow it.
  • The applicant has notified the original service provider of its intent to change service providers.
  • There is a legitimate reason to change providers. For example, the service provider is non-responsive to communications, there is a breach of contract, or the service provider is unable to perform the requested services.
  • The newly selected service provider received the next highest point value in the original bid evaluation and has accepted and agreed to provide services.

Transitioning Contracts

The FCC rules allow for an Operation SPIN Change if the funding request is for a new contract and the new service provider is unable to deliver service in a timely manner. An applicant may file an Operational SPIN change to request some or all of the funding to be allocated to the previous service provider so that there are no interruptions of funding or services. However, the funding request cannot be increased if the previous provider’s service costs more than what is approved on the funding request.

Additional information and instructions for completing an Operational SPIN Change are located at USAC’s website.

SPIN Change Deadlines

SPIN Change requests must be submitted no later than the last date to submit an invoice. For Funding Year 2018, the deadline for recurring services is October 28, 2019, and the deadline for non-recurring services is January 28, 2020. However, the sooner your request is submitted and processed by USAC, the sooner invoicing may begin under the correct SPIN.

Applicants who file either Corrective or Operational SPIN Change requests must still comply with program deadlines and must continue to file their FCC Form 486. If the SPIN Change is submitted near the invoicing deadline, the applicant should also request an invoice deadline extension prior to the invoice deadline.