E-Rate News Flash 19-01

E-Rate
  Wednesday, January 9, 2019

Issue 19-01

January 9, 2019

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

USAC Announces FCC Form 471 Filing Window and Deadlines

USAC has announced that the FCC Form 471 filing window for Funding Year 2019 will open on Wednesday, January 16, 2019, at 12:00 noon EST (9:00 a.m. PST) and will close on Wednesday, March 27, 2019, at 11:59 p.m. EDT (8:59 p.m. PDT). FCC Form 471 applications must be certified within an applicant’s E-rate Productivity Center (“EPC”) portal within these dates in order to be considered to be filed “within window.”

EPC profiles will lock on Tuesday, January 15, 2019, at 11:59 p.m. EST (8:59 p.m. PST). You will not be able to make changes to your EPC profile after that date. EPC profiles indicate the eligible locations to receive service as well as data used to determine the discount calculation. Incomplete profile data can prevent an applicant from being able to prepare its Form 471 successfully. USAC has a recorded webinar which outlines how profiles may be updated in EPC. The K12 High Speed Network (K12HSN) also has a recorded webinar for California-specific tips for updating profiles and calculating discounts.

Impact of Partial Government Shutdown on E-rate Program

On December 31 the Federal Communications Commission announced its plan to shut down effective January 3. However, USAC will continue its operations as will the U.S. Treasury in processing authorized disbursements of E-rate funds. This means that the shutdown will not impact normal operations of the E-rate program.

USAC Transitioning of BPO Contractor

Effective January 1, 2019, USAC has transitioned its Business Process Outsourcing (BPO) functions from Solix to Maximus. This includes 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. Applicants with pending forms and requests will receive specific outreach from USAC and a new reviewer will be assigned for any ongoing cases.

California Funding Commitment Summary

Funding Year 2018

USAC released FY2018 Wave 38 Funding Commitment Decision Letters (FCDL) on December 27, 2018. As of December 27, FY2018 California commitments total over $265 million.

Funding Year 2017

USAC released FY2017 Wave 62 FCDLs on December 20, 2018. As of December 20, 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.

Waves #

FCDL
Date

Form 486 Due Date

1-21

4/20-8/31/18

Deadline passed for services starting July 1, 2018

22

9/7/2018

1/5/2019

23

9/14/2018

1/12/2019

24

9/23/2018

1/21/2019

25

9/30/2018

1/28/2019

 

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.  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.

USAC E-rate Program Applicant Training Series

USAC has posted recordings of its 2018 E-rate Program Applicant training materials.

K12HSN 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: Completing Bid Evaluations and Awarding Services 

The FCC Form 470, associated request for proposal (RFP), if any, and all relevant information needed for a service provider to bid must be publicly available for a minimum 28-day period before applicants can close the competitive bidding process.

Evaluating Bids and What to Do if You Receive No Bids

After you close your competitive bidding process, you must evaluate the bids received and choose the bid that is the most cost-effective. You may consider factors in addition to the price of goods and services in your evaluation. FCC competitive bidding requirements specify that the price of the E-rate eligible products and services must be the primary factor and must be weighted more heavily than any other single factor in the evaluation. For examples and guidance on constructing a bid evaluation please see USAC’s “How to Construct a Bid Evaluation” guidance.

If you receive only one response to your competitive bidding process, the response must still comply with the cost-effective requirement. If you receive only one response and determine that it is cost-effective, you must document it. This may be documented with a memo or email to yourself and placed in your records.

If you do not receive any responses, you may solicit responses from service providers. If you currently receive service from a service provider, you can ask your current provider to submit information in response to your FCC Form 470. Again, you must document if no responses are received and if you continue services with your incumbent provider.

IMPORTANT: If your Form 470 had an associated RFP, please verify with your local rules that an award may be issued for any single response or no response scenario. In some cases, local rules may require that you restart your competitive process. All competitive bidding documentation, including winning and losing bids, bid evaluations, and contract documents must be retained for a minimum of 10 years from the last date to receive service or the end date of the contract, whichever is later.

Awarding Services

Applicants may award and receive services under tariff, month-to-month or contracted terms. Under tariff or month-to-month terms, services such as digital transmission service or Internet access may not require a contract. However, we remind applicants that they must post an FCC Form 470, open a competitive bidding process, wait 28 days, and evaluate responses for these services on an annual basis prior to filing the FCC Form 471. The contract award date reported on the Form 471 is the date that you select the service provider and should be documented in an evaluation matrix, e-mail, memo, or all of the above.

Services provided under a binding agreement, enforceable by law, between two or more parties for specific contracted terms with specific contracted rates are considered to be contracted services. If you posted an FCC Form 470 and signed a multi-year contract resulting from that posting, you may not have to post an FCC Form 470 or open a competitive bidding process for the remainder of the term of that contract. However, we caution applicants to check their contracts for any additions, increases, moves and/or changes to services that may require a posting of a new FCC Form 470.

Except for services to be delivered under tariffed or month-to-month arrangements, applicants must have a contract or other legally binding agreement in place with the service provider before certifying an FCC Form 471. A verbal agreement is not considered a legally binding agreement under program rules. For additional information on contracts, please see USAC’s “Contracts” section.