E-rate News Flash
Announcements and News
Comments Due on Proposed Eligible Services List for FY2020
On August 2, 2019, the FCC released (DA 19-738) seeking comment on the proposed eligible services list (ESL) for the E-Rate program for funding year 2020.
The ESL does not include substantive changes, however, continued support for Managed Internal Broadband Services (MIBS), caching, and Basic Maintenance of Internal Connections (BMIC) may be subject to change. Absent Commission action on the Category Two Notice of Proposed Rulemaking (NPRM) (FCC 19-58), continued eligibility of MIBS, caching and BMIC will vary for applicants that began their five-year Category Two budget cycle in FY2015 versus those that first received Category Two support in subsequent years.
Interested parties are encouraged to file comments in the FCC's Electronic Comment Filing System (ECFS) under proceeding 13-184 by September 3, 2019, and reply comments by September 18, 2019. Parties may also view posted comments in EFCS by doing a search in ECFS under proceeding number 13-184.
CALNET Next Generation Eligibility Certification for Non-State Entities
The California Network and Telecommunications (CALNET) Program provides telecommunications and Internet master contracts that may be used by certain qualifying California public entities. The California Department of Technology (CDT) is requesting that non-state entities complete a Non-State Entity Service Policy and Agreement (NESPA) Form as soon as possible to assist with the transition from CALNET 3 to the CALNET next generation contracts. CALNET 3 contracts will expire June 30, 2020; non-state entities currently utilizing the CALNET 3 contracts may continue to do so until the contracts expire.
Any non-state entities wishing to purchase services off of the CALNET next generation contracts must submit a NESPA form even if they previously purchased services under the CALNET 3 contracts. Qualified non-state entities will be required to self-certify that their organization meets one of the following criteria:
•Is a local governmental entity: Local government entities are defined as "any city, county, city and county, district or other governmental body or corporation, including the California State Universities (CSU) and University of California (UC) systems, K-12 schools and community colleges, empowered to expend public funds for the acquisition of products," per Public Contract Code Chapter 2, Paragraph 10298 (a) (b); or
•is entirely 100% tax supported; or
•is an entity with a Joint Powers Agreement (JPA); or
•is a federally recognized Indian Tribe.
USAC Requests FCC Form 498 Updates
The August 9th USAC News Brief and the August 16th USAC News Brief include information and instructions for applicants and services providers to update their business type(s) and DUNS Number information on their FCC Form 498 in the E-rate Productivity Center. Applicants and service providers are to complete these updates as soon as possible so as not to experience delays in reimbursements as the October 28 invoice deadline approaches.
Please Note: If applicants are receiving and paying bills from their service provider in full, a completed FCC Form 498 is required to receive reimbursements via the FCC Form 472 BEAR invoicing form. However, applicants are not required to file a FCC Form 498 if they are solely using the discounted bill (FCC Form 474 Service Provider Invoice) method of receiving E-rate reimbursements.
California Funding Commitment Summary
Funding Year 2019
USAC released FY2019 Waves 15, 16 and 17 on August 1, 2019, August 8, 2019, and August 15, 2019, respectively. As of August 21, 2019, cumulative commitments for California applicants for Category One are $140,468,803.38 and $25,500,122.35 for Category Two.
Funding Year 2018
USAC has not released any FY2018 Waves of Funding Commitment Decision Letters (FCDL) for California since the July 24, 2019, E-rate News Flash.
Pending Dates and Deadlines
Applicants may view or calculate their E-rate deadlines on USAC's website.
Filing FCC Form 500 Service Delivery and Contract Extensions
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 request USAC to extend the service delivery deadline and report extended contract end dates.
The service delivery and/or contract extension requests must be submitted to USAC on or before the September 30, 2019, 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 coming directly from a service provider cannot be processed.
Applicants should check the expiration date on their contracts and, if allowed by the contract and local Board policy, extend their contracts and notify USAC of the new contract expiration date via the FCC Form 500. USAC will not approve invoices for services or products delivered after the contract expiration date reported on the funding request or after the original (or extended) service delivery deadline.
To file the FCC Form 500 for Funding Year 2016 and forward, the applicant must prepare its form in the E-rate Productivity Center (EPC). The May 17, 2019, USAC News Brief provides instructions on how to complete and certify the FCC Form 500 in EPC. To file the FCC Form 500 for Funding Year 2015 and previous funding years, refer to the USAC guidance on how to file FCC Form 500.
For more information on how to review for service delivery deadlines and instructions on how to complete the FCC Form 500 as well as invoice USAC for discounts, please visit the Trainings on the K12 High Speed Network website and view the webinar titled E-rate Invoicing and FCC Form 500.
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
The first FCC Form 486 deadline for FY 2019 will be October 28, 2019. 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.
Funding Year 2018 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.
Form 486 Due Date
Deadline passed for services starting July 1, 2018
Upcoming Training Events
Numerous training opportunities available for E-rate applicants.
USAC Applicant Fall Training Event
USAC still has space available at its October 31 – November 1, 2019, applicant training event to be held at the California State University, San Marcos. The training, available to attendees free of charge, begins with an optional half-day afternoon session targeted to beginners followed by a full-day training that includes separate breakout sessions for beginners and for more advanced users. USAC Applicant Fall Training Event registration is available here.
Recordings of previous webinars are posted on the USAC website. USAC most recently held a webinar on the FCC Form 470 and Competitive Bidding.
K12 High Speed Network Webinars
Recordings of previous webinars are posted on the K12HSN website.
Recordings of previous webinars are posted on the EducationSuperHighway website.
E-RATE Process: Activities to Work on Now
Service Substitution Requests
A service substitution request must be submitted to USAC any time 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.
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 amount the substitution will only be approved at the amount that was originally committed by USAC. If the service substitution results in a decrease to the pre-discounted amount, then the funding request will be approved at the lower amount associated with the substitution.