E-Rate News Flash 20-3

E-Rate
  Tuesday, February 18, 2020

Issue 20-3

February 13, 2020

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

FCC Eliminates Requirement to Amortize Funding Requests for Installation/Special Construction Charges Exceeding $500,000

In order to promote adoption of high-speed broadband connectivity, the Federal Communications Commission (FCC has) now permanently eliminated the requirement to amortize funding requests for Category One non-recurring installation and special construction for costs exceeding $500,000. This will help schools that need to pay significant up-front charges to bring broadband to their schools, allowing them to request funding on the full charge in the first year of the contract. The full text of FCC 20-3 can be found at https://www.fcc.gov/document/fcc-eliminates-e-rate-amortization-requirement.

Funding Year 2018 Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing the Universal Service Administrative Company (USAC) for FY 2018 recurring services was October 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 February 25, 2020. Any additional invoices filed after February 25, 2020, will not be accepted by USAC and will 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.

Respond to USAC Program Integrity Assurance Review Now for Certified Funding Year 2020 Applications

Even though the deadline to file the annual FCC Form 471 is not until March 25, over 325 California applicants have already successfully submitted one or more FCC Form 471 applications. USAC is actively reviewing these applications now in a process called Program Integrity Assurance Review (PIA). Applicants have 15 days to respond to USAC's questions. Questions are submitted to the FCC Form 471 contact via e-mail and must be responded to in the E-rate Productivity Center (EPC) by the 15-day deadline. Applicants may request a seven-day extension in order to respond to USAC's request for information. Frequent questions during review include documentation to support the cost of services and associated taxes as well as entity eligibility or discount validation. If you are the FCC Form 471 contact, monitor your e-mail closely for USAC's outreach with the subject line that includes the FCC Form 471 number followed by E-rate Review Information.

California Funding Commitment Summary

Funding Year 2019

USAC released FY2019 Waves 43 through 45 on January 23, 2020, January 30, 2020, and February 6, 2020, respectively. Cumulative commitments for California applicants are $296.6 Million.

Funding Year 2018

As of January 13, 2020, cumulative commitments for California applicants are $278.8 Million.

Pending Dates and Deadlines

E-rate deadlines may be viewed or calculated on the Universal Service Administrative Company (USAC) website at https://www.usac.org/sl/tools/deadlines/default.aspx.

Funding Year 2020 FCC Form 470 "Deadline"

E-rate competitive bidding rules require that an FCC Form 470 be posted for a minimum of 28 days before filing an associated FCC Form 471 funding request. The E-rate applicant must also follow all E-rate competitive bidding rules. Note that the last date to file an FCC Form 470 and meet the minimum 28-day requirement, and also file within the FCC Form 471 window, would be February 26, 2020. It's important to note, however, that compliance with E-rate competitive bidding requirements, as well as the time necessary to complete an FCC Form 471, make it unrealistic for most applicants to file their FCC Forms 470 by February 26th. Best practices are for applicants to plan for a 30-60 day competitive bidding cycle to allow for unexpected changes, review bids received, and award contracts. If you have not yet posted your FCC Form 470 for Funding Year 2020, and expect that you will need to do so, do not delay. More information on FCC Form 470 and competitive bidding best practices is available at https://www.usac.org/e-rate/learn/webinars/.

FCC Form 471 Filing Window for Funding Year 2020

The Universal Service Administrative Company (USAC) has announced the annual E-rate application FCC Form 471 filing window for Funding Year 2020. It opened at 9:00 a.m. PST on Wednesday, January 15, 2020. and will close at 8:59 p.m. PST on Wednesday, March 25, 2020. All applicants who are seeking E-rate funding for eligible services delivered between July 1, 2020, and June 30, 2021, must file their annual FCC Form 471 funding requests in USAC's E-rate Productivity Center (EPC) online portal by the March 25 deadline.

FCC Form 486 Filing Reminder

The FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form) at https://www.usac.org/wp-content/uploads/e-rate/documents/486.pdf 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

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, 2019, the following deadlines have passed or are approaching in the next month:

Waves #

FCDL
Date

Form 486 Due Date

1-28

04/27/2019-10/10/2019

Deadline passed for services starting July 1, 2019

29

10/17/2019

2/14/2020

30

10/24/2019

2/21/2020

31

10/31/2019

2/28/2020

32

11/7/2019

3/6/2020

33

11/14/2019

3/13/2020

34

11/21/2019

3/20/2020

Funding Year 2018

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

1-64

04/20/2018-10/7/2019

Deadline passed for services starting July 1, 2018

65

10/14/2019

02/11/2020

66

10/21/2019

02/18/2020

67

No California commitments

68

11/04/2019

03/03/2020

69

No California commitments

70

11/18/2019

03/17/2020

71

11/25/2019

03/24/2020

72

12/2/2019

03/31/2020

 

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.

Upcoming Training Events

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

USAC Webinars

Recordings of previous webinars registration for upcoming webinars are posted on the USAC website at https://www.usac.org/e-rate/learn/webinars/.

E-rate Office Hour Webinar: Service Provider Selection and FCC Form 471

Date: Thursday, February 27, 2020

Time: 10:00 AM PT

K12 High Speed Network E-rate Resources

Visit the K12 HSN website at https://www.k12hsn.org/resources/erate/training to access the new E-Rate Training Roadmap and Resource Guide and supplemental training materials, including recordings of previous webinars. The two most recent webinars recorded in December outline changes in the Category Two program. Webinars geared to participants in the Broadband Infrastructure Improvement Grant (BIIG) are also scheduled through March.

Broadband Infrastructure Improvement Grant (BIIG) Filing FCC Form 471 for Services Transferred from Grant

Date: Wednesday, February 19, 2020 

Time: 10:00AM PT

Registration Link: http://icoe.k12oms.org/1398-181112

and

Date: Thursday, March 5, 2020

Time: 2:00PM PT

Registration Link: http://icoe.k12oms.org/1398-181113

E-rate Process: Activities to Work on Now

Making Corrections to Locked EPC Profiles

In EPC each E-rate applicant will have a profile associated with its parent Billed Entity Number (BEN), as well as associated child entities such as schools, libraries, non-instructional facilities, and annexes. USAC requires that every eligible location to receive service be given one of these child designations in EPC. In addition, school and school district applicants must report enrollment and National School Lunch Program (NSLP) eligibility data in the profile for each of their schools in order to calculate the E-rate discount and available Category Two budget. Finally, both schools and libraries must be assigned an Urban or Rural designation in their unique profiles in order for the E-rate discount to be calculated.

Errors in Discount Calculations

If a school profile has no value in its enrollment, NSLP, or urban/rural fields, the E-rate discount for the BEN will not calculate in the FCC Form 471. This is demonstrated by an error message in the FCC Form 471 itself as well as in the Discount Rate display for the BEN's profile in EPC.

For libraries, errors in their associated school district E-rate discount calculations or having no value in an urban/rural field will also result in an error message on the FCC Form 471 and in the Discount Rate display for the library's BEN profile.

If you experience these error messages, you will not be able to proceed with filing the FCC Form 471 for your organization until the issues are identified and corrected. Because EPC profiles are currently locked for the duration of the FCC Form 471 filing window, contact USAC by either submitting a case in EPC or calling 888-203-8100 for assistance in identifying the source of the error so they may make the necessary correction to allow you to file your FCC Form 471.

Missing Child Entities

If you identify child entities missing from your BEN's profile, you may request that USAC create a new child entity number in EPC. However, you will not be able to add it to your BEN's profile until after the FCC Form 471 window is closed. It is important that you make a note in the Narrative section of any FCC Form 471 funding request of missing entities that will require corrections during USAC application review.