E-rate Update Issue 18-08, Sept 6, 2018
September 6, 2018
E-rate News Flash
· Pending Dates and Deadlines
· Upcoming Training Events
· E-rate Process: Activities to Work on Now
FCC Issues Public Notice on Draft Eligible Services List for FY 2019
On July 30, 2018, the Federal Communications Commission (FCC) released a Public Notice (DA 18-789) establishing the comment period for the Funding Year (FY) 2019 Eligible Services List (ESL). Comments on the draft ESL, which is attached to the Public Notice, are due to the FCC on or before August 29, 2018. Reply comments are due to the FCC on or before September 13, 2018. For information on filing comments with the FCC, please refer to the Public Notice at https://docs.fcc.gov/public/attachments/DA-18-789A1.pdf.
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.
Filing FCC Form 500 Service Delivery and Contract Extension
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 extend the service delivery and contract extension dates.
The Service Delivery and Contract Extension Request must be submitted to USAC on or before the September 30, 2018 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 that come directly from a service provider cannot be processed.
Applicants should check the expiration date on their contract and, if allowed, extend their contract and notify USAC of the new contract expiration date via FCC Form 500. USAC will not pay for services delivered after the contract expiration date on file or after the original (or extended) service delivery deadline.
To file the FCC Form 500 for Funding Year 2016 and forward, the applicant enters its form data directly into the FCC Form 500 in EPC. The USAC News Brief from May 25, 2018 provides instructions on how to complete and certify the FCC Form 500 in EPC at https://www.usac.org/sl/tools/news-briefs/preview.aspx?id=835.
To file the FCC Form for Funding Year 2015 and previous funding years, USAC provides guidance on how to file the FCC form 500 at https://www.usac.org/sl/applicants/before-youre-done/500-filing.aspx.
The K12 High Speed Network will be conducting a webinar E-rate Invoicing and FCC Form 500 on Thursday, September 13 to review service delivery deadlines and provide instruction on how to complete the FCC Form 500 as well as invoice USAC for discounts. Select this link to register now for the event https://www.k12hsn.org/resources/erate/trainings. The webinar will be recorded and content posted on the K12 HSN website.
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 2018
The First FCC Form 486 deadline for FY 2018 will be October 28, 2018.
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.
Universal Services Administrative Company Webinars
9/19/2018 at 12:00 p.m.
K12 High Speed Network Webinars and Workshops
· E-rate Invoicing and Form 500
9/13/2018 at 2:00 p.m.
Register here: https://www.k12hsn.org/resources/erate/trainings
· Beginner's Guide to EPC and FRN Status Tool
9/20/2018 at 2:00 p.m.
Register here: https://www.k12hsn.org/resources/erate/trainings
· E-rate 101: What’s New for 2018-19?
9/12/2018 at 10:00 a.m.
· E-rate Category 2 Masterclass #1: Optimize Your Internal Network Upgrade
9/19/2018 at 10:00 a.m.
· E-rate Category 2 Masterclass #2: How to Launch a Successful Procurement
9/26/2018 at 10:00 a.m.
E-rate Process: Activities to Work on Now
Service Provider Identification Number (SPIN) Changes
Invoicing to a funding request may be on hold due to an incorrect SPIN currently being associated to a funding request. There are two types of SPIN changes: Corrective SPIN Change or Operational SPIN Change.
Corrective SPIN Changes
Corrective SPIN Changes are commonly required when the applicant or USAC made a data entry error and/or a change to the service provider identification number occurred. For example:
· Data entry errors were made when the FCC Form 471 was submitted.
· Your service provider has multiple SPINs and you chose the wrong SPIN.
· A merger or acquisition 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 at https://www.usac.org/sl/applicants/before-youre-done/spin-changes/corrective-changes.aspx.
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 and 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: non-responsive communications, 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.
Note: FCC rules also allow for an Operational SPIN Change if the funding request is for a new contract and the new service provider is unable to deliver the 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 to funding or service. 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 at https://www.usac.org/sl/applicants/before-youre-done/spin-changes/operational-changes.aspx.
SPIN Change Deadlines
SPIN change requests must be submitted no later than the last date to submit an invoice. For Funding Year 2017, the deadline for recurring services is 10/29/2018 and the deadline for non-recurring services is 1/28/2019. 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 being submitted near the invoicing deadline date, the applicant should also request an invoice deadline extension. This will extend the invoice deadline while USAC reviews and processes the SPIN change.
Service Substitution Requests
A service substitution request must be submitted to USAC anytime an applicant wants to change the products and/or services on the approved FCC Form 471. In the service substitution request you will be required to provide USAC the original product and/or service that was approved on the FCC Form 471 and the substituted product and/or service. Each Funding Request Number (FRN) line item requiring a substituted product and/or service must be requested through the E-rate Productivity Center (EPC) for Funding Year 2016 forward. For Funding Year 2015 and previous years, the service substitution is submitted via an EPC customer service case. For step-by-step instructions, please refer to USAC’s user guide at https://www.usac.org/_res/documents/sl/pdf/e-rate-productivity-center/EPC-User-Guide-Service-Substitution-Requests.pdf.
When Service Substitutions May Be Submitted
A service substitution may be submitted to USAC as soon as your FCC Form 471 Receipt Acknowledgement Letter (RAL) is available in EPC which is generally moments after the FCC Form 471 has been certified. Service substitutions must meet the following conditions:
· The substituted services or products have the same functionality as the services or products contained in the original proposal.
· The substitution does not violate any contract provisions or any California or local procurement law.
· The substitution does not result in an increase in the percentage of ineligible services or functions.
· The requested change is within the scope of the establishing FCC Form 470, including any Requests for Proposals (RFPs), for the original products and/or services.
If the service substitution results in an increase to the pre-discounted request then the funding request will be approved at the amount that was originally committed by USAC; the funding request amount will not be increased. If the service substitution results in a decrease to the pre-discounted request, then the funding request will be approved at the lower amount associated with the substitution.
Service Substitution Deadline
The deadline to file a service substitution is on or before the last day to receive services for the applicable FRN: June 30 of the relevant funding year for recurring services or for non-recurring special construction charges, and September 30 that follows the close of the funding year for non-recurring services.
Corrective Service Substitution
If you discover that a product and/or service that has already been provided is different from what was reported on your FCC Form 471 funding request, a corrective service substitution should be submitted, even if it was not discovered until after the last date to receive service. This request may be submitted as a customer service case in EPC. Be sure to prominently indicate within your request that it is a “corrective service substitution.” Keep in mind that it’s recommended to submit service substitution requests within the deadlines noted above to ensure pre-approval of your service substitution before the service delivery deadline.
Schools and Libraries Program Weekly News Briefs on E-rate
The Schools and Libraries Program (SLP), commonly known as E-rate, provides timely information and insight through their Weekly News Brief. If you have not already done so, we encourage you to sign up to receive these communications by visiting the SLP’s Web page at http://www.usac.org/sl/tools/news-briefs/Default.aspx .