E-Rate News Flash 20-8

E-Rate
  Thursday, April 16, 2020

Issue 20-8

April 16, 2020

E-rate News Flash

Contents:

  • Announcements
  • Funding Commitment Summary
  • Pending Dates and Deadlines
  • E-rate Training Resources
  • E-rate Process: Activities to Work on Now

Announcements

Federal Communications Commission E-rate Program Response to Novel Coronavirus Disease 2019

The Federal Communications Commission (FCC) has initiated multiple response measures to support our nation’s schools in their response to Novel Coronavirus disease 2019 (COVID-19).

Waiver of Various E-rate Filing Deadlines

In recognition of the unprecedented impact on schools due to the COVID-19 pandemic, the FCC has waived and extended multiple E-rate deadlines as described below.

(1) Service delivery deadline for non-recurring: Any funding requests for non-recurring services with a September 30, 2020 deadline will receive an automatic extension to September 30, 2021. This primarily impacts the installation deadline for Category 2 Internal Connections and installation of Category 1 broadband services.

(2) Installation deadline of Category 1 special construction: The FCC requires that service is delivered and lit by June 30 of the funding year for funding requests that include one-time special construction of Category 1 broadband services, allowing for a single one-time, one-year extension request. The FCC has automatically extended the deadline for any special construction funding requests with a June 30, 2020 deadline to June 30, 2021.

(3) Appeal deadline: FCC rules require parties seeking review or waiver of a decision by the Universal Service Administrative Company (USAC), either directed to USAC or the FCC, to submit their requests within 60 days from the date of the decision. This deadline has been extended to 120 days. This waiver will be in effect for parties seeking review or waiver of an adverse USAC decision with an appeal deadline between March 11, 2020 and September 30, 2020.

(4) Invoice filing deadline: The FCC will provide all applicants and service providers with an automatic 120-day extension of the invoice filing deadline for any funding request with an invoice deadline between March 11, 2020, and October 28, 2020.

(5) FCC Form 486 deadline: The FCC Form 486 deadline is 120 days from USAC’s issuance of the Funding Commitment Decision Letter, or 120 days from the start of service, whichever is later. For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directs USAC to provide these applicants with an additional 120 days to submit these forms without penalty.

(6) USAC review deadlines: The FCC also directs USAC to grant automatic 30-day extensions to the deadlines associated with USAC’s review of and outreach pertaining to the following forms and requests: FCC Form 471 Program Integrity Assurance (PIA), USAC appeals, invoices, FCC Form 500 requests, service substitutions, Service Provider Identification Number (SPIN) changes, funding request cancellation requests, and program audits.

You may read the entire order addressing these extensions at the FCC’s website, https://www.fcc.gov/document/fcc-extends-key-e-rate-program-deadlines-due-covid-19-pandemic-0 and the Erratum further clarifying the deadlines at this website https://www.fcc.gov/ecfs/filing/041385109239.

Extension of FCC Form 471 Filing Deadline

As mentioned in our previous News Flash, the FCC directed the Universal Service Administrative Company (USAC) to extend the deadline for E-rate applicants to submit their FY2020 FCC Form 471 applications by an additional 35 days. E-rate applicants will now have until Wednesday, April 29, 2020, at 8:59 p.m. PDT to submit their FY2020 FCC Form 471 applications.

Reminder to Schools that the Community May Access On-Campus WiFi When Schools are Closed

In 2010, the FCC lifted restrictions to enable for community use of E-rate funded broadband services on a school’s campus while school is not in session. On March 23, 2020, the FCC reiterated that allowing for community access of WiFi on a school’s campus while schools are closed due to the COVID-19 pandemic is allowed under current program rules. However, the FCC declined to address allowing for the expansion of a school’s WiFi network beyond the school’s property line which is currently disallowed by E-rate program rules. You may read the entire public notice at the FCC’s website, https://www.fcc.gov/document/community-use-e-rate-supported-wi-fi-permitted-during-closures.

Waiver of E-rate Gift Rules

As mentioned in our previous News Flash, the FCC announced that it is temporarily waiving the E-rate gift rules through September 30, 2020. Due to the necessity for schools to acquire goods and services to meet increased broadband demand or to support connectivity to students at home while schools are closed, the FCC is waiving E-rate program gift rules to enable service providers to offer, and E-rate eligible schools to solicit or accept, broadband connections, devices, networking equipment, or other things of value that could help students and teachers affected by school closures during the coronavirus pandemic. You may read the entire order at the FCC’s website https://www.fcc.gov/document/fcc-acts-support-telehealth-remote-learning-during-coronavirus.

Reminder to Identify and Separate Out Taxes and Surcharges on E-rate Funding Requests

To expedite USAC’s review of FCC Forms 471, we remind applicants when completing individual Funding Request Number (FRN) Line Items to separate out the Monthly Recurring Costs or One-Time Costs from the taxes and surcharges of the associated service or product. Taxes and surcharges are best described by the “Miscellaneous” Function and “Taxes and USF Fees” Type of Connection within the FCC Form 471 funding request. Applicants should be prepared to provide source documentation to support the taxes and surcharges during PIA review.  Acceptable source documentation can be a current service provider bill, a service provider quote, or to refer to published rates on available websites. You will find information about the current California sales tax rates on the California Department of Tax and Fee Administration website at https://www.cdtfa.ca.gov/taxes-and-fees/sales-use-tax-rates.htm, information about the current California Public Utilities Commission Surcharges on the California Public Utilities Commission website at https://www.cpuc.ca.gov/surchargesfeestaxes/, and information about the current Universal Service Fund (USF) contribution factor on the Federal Communications Commission website at https://www.fcc.gov/document/proposed-1q-2020-usf-contribution-factor-212-percent.

California Funding Commitment Summary

Funding Year 2020

As of April 1, 2020, California applicants have successfully submitted 4,204 funding requests for $158 million. Of these requests, 30% are in Wave Ready or Final Review status, 55% are for Category 1 services, and 45% are for Category 2 services. We anticipate that these amounts will increase as we approach the April 29 filing deadline.

Funding Year 2019

California applicants submitted over 8,000 funding requests in FY2019 for over $358 million. To date, USAC has issued commitments for 7,792 of these requests for a total of $305 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 2018 Non-Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing USAC for FY 2018 non-recurring services was January 28, 2020.  Applicants and service providers that requested and were approved for the single one-time 120-day extension now have an invoice deadline of May 27, 2020. Per the COVID-19 Order, the FCC has now granted an additional 120-day extension to September 24, 2020. We encourage applicants, if they are able, to continue to try and meet invoice deadlines so as to not delay receipt of E-rate funding.

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

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

Extended COVID-19 Due Date*

 
 

1-32

04/27/2019-
11/07/2019

Deadline passed for services starting 07/01/2019

N/A

 

34

11/21/2019

3/20/2020

7/18/2020

 

35

11/27/2019

3/26/2020

7/24/2020

 

36

12/5/2019

4/3/2020

8/1/2020

 

37

12/12/2019

4/10/2020

8/8/2020

 

38

12/19/2019

4/17/2020

8/15/2020

 

39

12/27/2019

4/25/2020

8/23/2020

 

* For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

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

Extended COVID-19 Due Date*

 
 

1-68

04/20/2018-
11/04/2019

Deadline passed for services starting 07/01/2018

N/A

 

70

11/18/2019

3/17/2020

7/15/2020

 

71

11/25/2019

3/24/2020

7/22/2020

 

72

12/2/2019

3/31/2020

7/29/2020

 

73

12/9/2019

4/7/2020

8/5/2020

 

78

1/13/2020

5/12/2020

9/9/2020

 

* For FCC Form 486 deadlines that fall between March 11, 2020 and September 30, 2020, the FCC directed USAC to provide applicants with an additional 120 days to submit these forms without penalty.

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.

E-rate Training Resources

Applicants may access multiple recordings and other supporting material at the following websites.

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/.

K12 High Speed Network E-rate Resources

Visit the K12 HSN website 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.

E-rate Process: Activities to Work on Now

Reviewing FCC Form 471 Applications for Errors and Submitting Corrections

Applicants should review Certified FCC Forms 471 for accuracy and submit corrections where needed. Applicants may do this by reviewing the live FCC Form 471 in the E-rate Productivity Center (EPC) or by reviewing the PDF version of the original application. From your Billed Entity’s home page in EPC, select the FCC Forms menu to access the Funding Year 2020 certified forms. Each form filed will have a hyperlink taking you to the live form that you may click through to verify information, and which also has a PDF link to the original form which you may download.

Common corrections include but are not limited to:

  • Incorrect Entity Information
    • School Districts: Review the contact information for your school district and each of your individual schools. For each school in your district, review the actual or estimated student counts; the approved Community Eligibility Provision (CEP) percentage, if you have one; the urban/rural status; and the attributes (such as public, private, or tribal).
    • Library Systems: Review the contact information for your library system and each of your library branches, bookmobiles, and kiosks. For each library in your library system, review the square footage, the urban/rural status, the Institute of Museum and Library Services (IMLS) locale codes, and the attributes (such as public, private, or tribal). You must have identified one library as the main branch and also identified the school district in which the main branch is located.
    • Independent Schools and Libraries: Review the contact information for your entity and also your entity information necessary for the discount and Category Two budget calculations as noted above.
    • Consortia: Although you cannot change profile information for your members, you should review your own contact information and the list of consortium members you reported as receiving or sharing services on each FCC Form 471. You can also provide any other information that may be necessary for USAC to correctly process your application.
  • Incorrect Form 470 Cited on a Funding Request: The FCC Form 470 cited must support the services requested on the funding request.
  • Incorrect Contract Records Cited on a Funding Request: Contract records cannot be edited once they are submitted in EPC. If an error is found in any contract record, applicants must create and submit a new contract record in EPC and ask that the FRN be linked to the correct record.  
  • Incorrect Services, Equipment and Installation Costs: Applications should verify the pre-discount costs and quantities listed in the funding request line items. Costs should be supported by the information in the contract(s), vendor bills, vendor quotes or other documentation you used to prepare your form.

For more information on corrections, please review USAC’s web page addressing Ministerial and Clerical errors here https://www.usac.org/e-rate/applicant-process/competitive-bidding/ministerial-clerical-errors/. If you do identify an error, you may submit a request for correction through the Receipt Acknowledgement Letter (RAL) Correction process. Note that RAL corrections may be submitted to USAC up until a Funding Commitment Decision Letter is issued on the FCC Form 471 application.