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E-Rate News Flash- Issue 19-02, February 1, 2019

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E-RATE NEWS FLASH 

Announcements 
Limited Waiver for Victims of October 2017 California Wildfires

On January 3, 2019, the Federal Communications Commission (FCC) issued a limited waiver (DA 19-15 PDF) for victims of the October 2017, wildfires in eight counties designated by Federal Emergency Management Agency (FEMA) as eligible for disaster relief: Butte, Mendocino, Napa, Nevada, Sonoma, Lake, Orange, and Yuba. Applicants in the affected counties may have additional time to file appeals or requests for waiver with the FCC or the Universal Service Administrative Company (USAC) and to file FCC Forms 486, Forms 472, and Forms 474. Applicants that had E-rate records destroyed by fires may be exempt from the 10-year documentation retention rule if they attest to the destruction of records and make every attempt to recover available records from third parties. USAC published a list of affected applicants and issued instructions on how affected applicants may initiate requests in the USAC January 22, News Brief.

USAC Transitioning of BPO Contractor and Impact on Pending Forms and Processes

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 Reviews, processing of pre and post-commitment forms and requests including Forms 471, 486 and 500, service substitutions, SPIN changes, appeals and invoices. All pending forms and requests will be assigned to new reviewers by February 1, 2019. Applicants will receive outreach from either the new reviewer or a manager by February 1. If you do not receive this outreach, and you have a pending request, contact USAC by filing a customer service case in the E-rate Productivity Center (EPC) or by calling 888-203-8100 for assistance.

USAC Announces FCC Form 471 Filing Window and Deadlines

USAC has announced that the FCC Form 471 filing window for Funding Year 2019 opened 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."

California Funding Commitment Summary 
Funding Year 2018

USAC released FY2018 Wave 42 Funding Commitment Decision Letters (FCDL) on January 25, 2019. As of January 25, FY2018 California commitments total over $271 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
                                           Deadline passed for services
1-25         4/20-9/30/18             starting July 1, 2018
26             10/5/2018                       2/2/2019
27             10/12/2018                     2/9/2019
28             10/19/2018                    2/16/2019
29             10/25/2018                    2/22/2019

USAC issues 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 Form 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 Recurring Services Extended Invoice Deadline

In general, the deadline for invoicing USAC for FY 2017 recurring services was October 28, 2018. Applicants and service providers that requested and were approved for the single one-time 120-day extension now have an invoice deadline of February 26, 2019. Any additional invoices filed after February 26, 2019, will not be accepted by USAC and 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.

Funding Year 2019 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 27, 2019. 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 on February 27. 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 2019, 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 on K12 HSN's E-rate training website.

Upcoming Training Events

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

USAC E-rate Program Applicant Training Series

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

USAC Office Hours

In February, USAC conducted webinars will allow for attendees to submit live questions about previously-published materials.

K12 High Speed Network Webinars

Completing FCC Form 471 for Category 2 Services

02/12/2019 at 2:00 p.m. (Note NEW Date) K12 High Speed Network Webinars

EducationSuperHighway Webinars
  • Build vs. Buy Calculator: Evaluate Your Fiber Bid Responses

02/13/2019 at 10:00 a.m. EducationSuperHighway Webinars

  • 4 Ways to Get More Bandwidth for Your Budget

02/21/2019 at 10:00 a.m. EducationSuperHighway Webinars

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 BEN 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 USAC may make the correction necessary 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.

E-Rate News Flash Issue 19-03, February 22, 2019
CALPADS Flash #150 - February 15th, 2019
 

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