Issue 19-04, March 8, 2019
E-rate News Flash
CALNET 3 Contract Extensions Posted
Many public agencies including public schools and libraries utilize the state master contract CALNET 3 for the purchase of broadband and telecommunications services, some of which may be eligible for E-rate discounts. California’s Department of Technology has recently posted extensions to CALNET 3 through June 30, 2020, on the California Department of Technology website. California E-rate applicants citing the CALNET 3 contract on their Funding Year 2019 FCC Form 471 funding requests will want to download copies of the contract amendments reflecting the contract extensions for their E-rate records. The contract amendments are located under the separate “Amendments” sections under Category 1 and Categories 2-7, and under each eligible provider. Check the amendment carefully to ensure the extension cited is through June 30, 2020.
FCC Form 471 Filing Window Closes March 27
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 47 Funding Commitment Decision Letters (FCDL) on March 1, 2019. As of March 1, FY2018 California commitments total over $273 million.
Pending Dates and Deadlines
Funding Year 2017 Non-Recurring Services Extended Invoice Deadline
In general, the deadline for invoicing USAC for FY 2017 non-recurring services was January 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 May 28, 2019. Any additional invoices filed after May 28, 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.
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.
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 EPC 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 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.
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.
K12HSN Webinars - K12HSN Webinars
EducationSuperHighway Webinars - EducationSuperHighway Webinars
Late-Window FCC Form 471 Filing Tips and Next Steps
As the FCC Form 471 deadline approaches on March 27, applicants should allow for adequate time to complete the necessary information on their applications and to submit and certify by the deadline to be considered “within window.”
Review of Existing Services/Contracts
Review and verify contracts for all eligible services expected to continue through the next funding year (July 1, 2019, through June 30, 2020). Review bills for service and ensure funding requests filed include all eligible services and costs expected, including taxes and surcharges. If you find discrepancies and have already certified your FCC Form 471 funding requests, you may either submit corrections via a Receipt Acknowledgement Letter (RAL) correction, or submit a new FCC Form 471 with the correct information prior to the filing deadline. USAC will require you to cancel any duplicate funding requests.
New Services and Estimating Taxes and Surcharges
Review any bids and/or new contracts for service to ensure they are complete and include the entire costs of all services you expect to order in the 2019 funding year. If they do not include estimated taxes and surcharges, make sure to include these estimates in your funding requests. Some E-rate eligible services, such as Internal Connections, are subject to California sales tax, while recurring broadband services may be subject to California Public Utilities Commission surcharges. If you are in any doubt as to whether or not your services will be subject to these, contact your awarded service provider for clarification.
Review Certified Applications and File Corrections
Once you have certified your FCC Form 471 application, it is a good idea to review the application for any errors. You may do this by reviewing the live FCC Form 471 in the 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 2019 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.
If you do identify an error, you may submit a request for correction through the Receipt Acknowledgement Letter (RAL) Correction process. Note that only certain FCC Form 470 or FCC Form 471 ministerial and clerical errors may be corrected. If your error does not meet these criteria, it is better to file a new FCC Form 471 with the correct information prior to the filing deadline and to ask USAC to cancel the application that was filed in error. Any errors found after the filing deadline of March 27 must be corrected through the RAL 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.
Respond to USAC Program Integrity Assurance (PIA) Review
All FCC Form 471 applications undergo Program Integrity Assurance (PIA) review. In some instances, USAC reviewers may reach out to the Contact person listed on the FCC Form 471 to ask questions about the application and/or request documentation to substantiate the eligibility of services, the eligibility of entities receiving services, and the data used to calculate the E-rate discount. Applicants have 15 days to respond to USAC’s request for information, and may request an additional seven-day extension. While responses to USAC’s questions occur in EPC, the outreach from USAC will be sent to the Contact’s e-mail address. Failure to respond to USAC’s questions will lead to the denial of the FCC Form 471 funding requests.
---
Comments