Oct 2, 20206 min read

#USAC / #ERATE Schools and Libraries News Brief for The Week of October 2, 2020

TIP OF THE WEEK:

Please check to make sure you have provided the required information in the Funding Request Number (FRN) narrative field(s) of any FCC Form 471 you file during the second FY2020 application filing window. Check the September 18 SL News Brief for the three numbered requirements, and file a RAL modification if you need to add missing information.

Commitments for Funding Year (FY) 2020 and FY2019

FY2020. USAC released FY2020 Wave 23 Funding Commitment Decision Letters (FCDLs) on October 1. As of October 2, FY2020 commitments total just under $1.71 billion. FY2019. USAC released FY2019 Wave 74 FCDLs on September 30. As of October 2, FY2019 commitments total over $2.41 billion. On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in the E-rate Productivity Center (EPC).

More FAQs about the Second FY2020 Application Filing Window

In the September 25 SL News Brief, we provided a list of frequently asked questions (FAQs) about the second FY2020 application filing window. Below are some additional FAQs we have received.

Q. Should I put my entire request (original and additional bandwidth) in my second window FCC Form 471, or just the difference between the two?

A. The Order indicated that the FCC Form 471 you certify during the second filing window should only include the additional bandwidth. However, we realize that in some cases it may be easier for applicants to submit the entire amount on the FCC Form 471 certified during the second window. As long as you indicate in the FRN narrative whether you are including the entire request for FY2020 or just the additional bandwidth, your reviewer will understand how to conduct the review of your form. If there is any confusion, the reviewer will reach out to you to confirm the details and verify that your request is not duplicative.

Q. My original Category One funding request for internet access was denied and I have filed an appeal with USAC. Can I still apply for additional bandwidth?

A. Yes. In addition to the information that you are already providing in the FRN narrative for your FCC Form 471, be sure to note that you have filed an appeal. This will help us keep track of all of the details of your request. Be advised, however, that if USAC denies your appeal due to a competitive bidding violation based on the original FCC Form 470, the request for additional bandwidth would be denied as well.

Q. I filed a service substitution for my original internet access funding request. Can I apply for additional bandwidth?

A. Yes. For any post-commitment request (previous or pending), note the details of your request in the FRN narrative for your FCC Form 471 along with the information already required.

Q. If I post a new FCC Form 470 now, can I sign a multi-year contract and receive discounts on those services for the life of the contract?

A. No. The waiver of the competitive bidding requirements only applies to additional bandwidth requested for FY2020 (i.e., services received through June 30, 2021). You would have to rebid the services that will start on July 1, 2021.

Streamlined BEAR Process Begins Next Week

USAC is modifying the review process for the FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form so that we can process payments by FRN line item instead of waiting for the entire BEAR Form to complete the review and payment processes. This means that FRN line items that do not require manual review, or require a lower level of manual review, can be processed for payment while the other FRN line items are under review. The streamlined BEAR process also means that applicants with multiple line items on their BEAR Forms may receive more than one BEAR Notification Letter – one letter for each payment file – until USAC has made review decisions on all of the FRN line items on that BEAR Form. Going forward, each BEAR Notification Letter will contain summary information about the entire invoice, a summary table with the current status of each FRN line item, and specific details about the FRN line item decisions featured in the letter. USAC will continue to produce BEAR Notification Letters for a specific invoice until all of the FRN line items on that invoice have been processed. Below is a description of the changes to the structure of the revised BEAR Notification Letter and the information it will contain:

First page - summary of totals

The first page of the letter will feature four totals:

Invoice reimbursement payment in this letter: This is the total dollar value of the payments for all of the FRN line items for the invoice which we are reporting in this letter.
Invoice reimbursement adjustments in this letter: This is the total dollar value of the reductions and denials for the FRN line items for the invoice which we are reporting in this letter.
Summary of reimbursement payments on this invoice to date: This is the total dollar value of payments for the FRN line items featured in this letter and all previous letters for this invoice.
Summary of invoice reimbursement pending payments: This is the total dollar value reported by the applicant for the FRN line items for this invoice which are still pending.

You will also notice that we have reduced the text of the letter and instead provided links to various guidance documents on the USAC website that contain the information that was previously included.

Second page - Line Summary Table

The second page of the letter will contain a table with the details of all the FRN line items on the invoice. Here is a sample BEAR Notification Letter table so you can follow along:

The column headers identify the following information:

Line # - the FRN line item number
FY - the funding year associated with the FRN
FRN - the FRN for the line item
Dollars - the dollar amount paid for the FRN line item
Status - There are three possible statuses:
- -- "Sent to USAC mm/dd/yyyy" is the date that the FRN line item review was completed and the FRN line item sent to be processed for payment.
- -- "Canceled" means the FRN line item was canceled in consultation with the applicant.
- -- "In Progress" means that that the FRN line item is still under review.
Decision code(s) provides high-level information about any reduction or denial that occurred during review.

In the example above:

The first and second FRN line items (status of "Sent to USAC 08-11-2020") were processed and the line item details provided in a previous letter.
The third and fourth FRN line items (status of "Sent to USAC 10-01-2020") were processed and the line item details provided in the subsequent pages of this letter. (See Subsequent pages below for a description of the FRN line item details provided.)
The fifth FRN line item was canceled.
The sixth FRN line item is still in review with USAC.

Note the following:

The total of the dollar values of all the FRN line items with a status of "Sent to USAC xx/xx/xxxx" (where the x's represent the most recent date) is the same dollar value as the entry for Invoice reimbursement payments in this letter on the first page. (Using the example above, the entry on the first page of this letter would be $5,800.00, the total of the two FRN line items with a status of "Sent to USAC 10-01-2020.")
The total of the dollar values of all the FRN line items with a status of "Sent to USAC" that feature any date is the same dollar value as the entry for Summary of reimbursement payments on this invoice to date on the first page. (Using the example above, the entry on the first page of this letter would be $7,600.00, the total of the four FRN line items with a "Sent to USAC" status that includes any date.)
Any FRN line items with the status "In Process" will not show a dollar value because USAC's review decision is still pending.
A table of the Invoice Decision Codes and their plain-language and historical decision explanations is available on the USAC website for your reference. Note that there is additional decision information available on subsequent pages for the FRN line items featured in the letter (see below).

Subsequent pages - Line Details Reviewed in This Report

For each FRN line item with the status Sent to USAC that features the most recent date (using the example above, the FRN line items with the status "Sent to USAC 10-01-2020"), the letter includes an individual record with detailed information, including the decision code(s) and an explanation of the decision(s) for that FRN line item. This is the same information in the same format that was featured on the earlier version of the BEAR Notification Letter. Both the applicant and the service provider (SPIN) featured on the BEAR Form will receive a copy of the letter, and either one can request a copy of a letter by opening a customer service case in EPC or calling the Client Service Bureau (CSB) at (888) 203-8100.

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