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E-Rate News Brief


April 22, 2022

E-RATE TIPS:
 
•   If you plan to request a waiver of the FY2022 application filing window deadline, be sure to certify and submit your FCC Form 471 in EPC before you file your waiver request with the FCC. Note that you will receive an out-of-window status notification after you certify your form.

•   Visit our updated web pages including Letter of Agency (LOA) information, the Consortium Bulk Entity Update worksheet, and a new Consortia FAQ section.


•   PIA and Selective Review Process Training (Thursday, May 12 at 2 p.m. ET) – This hour-long session provides an overview of the Program Integrity Assurance (PIA) and Selective Review processes and steps to prepare for them. Register

Commitments for Funding Year (FY) 2022 and FY2021

FY2022. USAC will release FY2022 Wave 1 on Friday, April 22 (Funding Commitment Decision Letters will be sent the next day).

FY2021. USAC released FY2021 Wave 52 Funding Commitment Decision Letters (FCDLs) on April 7.  As of April 21, FY2021 commitments total over $2.64 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).

FY2022 FCC Form 473 Now Available

The FY2022 FCC Form 473 (Service Provider Annual Certification (SPAC) Form) is now available through the E-File System. Service providers must have a SPAC Form on file before USAC can pay invoices – FCC Forms 472 (BEAR) or FCC Forms 474 (SPI) – for a funding year. Service providers who want a copy of their certified form should click the PRINTABLE PAGE icon at the top of the page to save or print their copy before exiting the form.

Since November 2019, the FCC has taken a number of actions to protect U.S. national security and the communications supply chain. In short, recipients of USF support may not use USF money to buy new equipment or to support or maintain equipment already in inventory, from companies on the FCC’s Covered List. Two new certifications of compliance with the FCC’s supply chain rules were added to the FCC Form 473. Please note: This list is not exhaustive and may be updated by the FCC as warranted. It is the responsibility of universal service recipients to stay up-to-date on all covered companies, their parents, affiliates, and subsidiaries.

Service providers who participate in multiple USF programs must complete the annual certifications for each program (i.e., E-Rate, Rural Health Care, High Cost, and Lifeline) in which they participate. For additional information, visit USAC’s Supply Chain webpage.

Next Steps Related to the FY2022 Application Filing Window

The application filing window for FY2022 has closed. However, if you are new Tribal library that is applying for E-Rate funding or the funding application includes a new Tribal library as a recipient of service, applicants have until May 26, 2022 to submit the FCC Form 471 application(s) without needing to submit a waiver request to the Commission.  Additional information regarding Tribal libraries and applying for FY 2022 E-Rate funding is below.  For all other E-Rate applicants, we are providing a few reminders below for actions you should take while the application process is still fresh in your mind.

Review your FCC Form 471 and submit a RAL Modification Request to correct or update information. Double-check your certified FCC Form 471 for accuracy. If you find any information that should be corrected or updated, you can submit a Receipt Acknowledgment Letter (RAL) Modification Request. To learn how to submit modification requests for your FCC Form(s) 471, view the FCC Form 471 Receipt Acknowledgment Letter Modification Guide.

Entity information. If your entity profile was locked before you could update the information for your organization and/or your member entities, you can file a RAL Modification Request to provide your updates. Specifically, you should pay attention to the following:

  • School districts: Contact information for your school district and each of your individual schools, along with their actual or estimated student counts (for your discount calculation and your Category Two budget calculation), their approved Community Eligibility Provision (CEP) percentage (if they have one), their urban/rural status, and their entity attributes (such as public, private, or Tribal).
  • Library systems: Contact information for your library system and each of your library branches, bookmobiles, and kiosks, along with their square footage, their urban/rural status, and their entity attributes (such as public, private, or Tribal). You must have identified one library as the main branch and identified the school district in which the main branch is located.
  • Independent schools and libraries: Review the contact information for your entity and your entity information necessary for the discount calculation and the Category Two budget calculation as noted above.
  • Consortia: Review your own contact information and the list of consortium members you reported as receiving or sharing services on each FCC Form 471.

FCC Form(s) 470 you cited on a funding request. Most applicants citing an FCC Form 470 on their FCC Form 471 funding requests certified that FCC Form 470 in EPC. However, applicants with multi-year contracts or those who started their competitive bidding process before the FY2016 FCC Form 470 was available in EPC may be citing an FCC Form 470 filed in our legacy system.

For these earlier forms, check to be sure that each 15-digit application number you provided was for the correct FCC Form 470 that was posted for the correct service type and for which you waited at least 28 days before you chose your service provider. To view your legacy FCC Form 470 information online, you can use USAC’s Data Retrieval Tool (DRT). To request FCC Form 470 data (or FCC Form 471 data not found in the DRT), please contact us directly.
 
FCC Registration Number. Check this 10-digit number to make sure it is correct, especially if this is the first year you have filed E-Rate program forms. To verify your FCC Registration Number, you can use the FCC's Commission Registration System (CORES).

Costs and cost allocations. Check your math. The pre-discount costs of your funding requests should match the information in the contract(s) or other documentation you used to prepare your form. If you notice any incorrect information in any of the above fields, you can submit a RAL Modification Request to correct this information. 

Review and retain the competitive bidding process documentation that you relied on to complete your FCC Form 471. As part of your application filing process, you may have produced, accessed, or received a number of documents, and you may need to refer to one or more of these documents at various times during the application review process. If you collect and store this documentation in a manner that allows you or your successor to easily access and produce these documents, you can respond much more quickly to USAC requests.

All E-Rate program participants – applicants, service providers, and consortia – are required to maintain documentation that demonstrates compliance with the statutory or regulatory requirements for all E-Rate program purchases of services and equipment for a period of 10 years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request.
We suggest you take the time now to organize and file all documents related to your application in a manner that will allow you to easily locate and retrieve them for any future needs. Visit the Document Retention page to learn more about required program documents.

Prepare for Program Integrity Assurance (PIA) review. During PIA review (see overview below), we verify certain information on your FCC Form 471, and we may have additional questions to help us in our review. We will notify you by email and in your EPC News feed that there are PIA questions waiting for you to answer. This would be a good time to alert your service provider that you may need help with network diagrams, product descriptions, and other data that they should be able to supply. Please respond promptly to any PIA requests for information or documentation.
 
Monitor your contact email address and your EPC account. The contact person you identified on your form should regularly monitor their email address and EPC account so that they know when we have posted PIA review questions. You can file a RAL Modification Request to update your holiday/vacation contact information if we should use a different email address or telephone number to contact you, or if you have empowered someone else to answer questions on your behalf.

Monitor the status of applications for your district or state. You can check the status of your funding request using the open data FRN Status Tool.  The tool has easy to use filters so you can quickly isolate your data by BEN, SPIN, state, or Funding Year. Here is a link to a video for the tool.

Filing the FY2022 FCC Form 486

After applicants have received a Funding Commitment Decision Letter (FCDL) with a positive funding commitment and services have started for the funding year, they must file an FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form). The FCC Form 486 notifies USAC that services have started and certifies the status of the applicant’s compliance with the Children's Internet Protection Act (CIPA).

Applicants will be able to file an FCC Form 486 for Funding Year 2022 as soon as they receive a funding commitment from USAC. Be sure to verify your status under CIPA and, if you are a member of a consortium, that you have completed your FCC Form 479 (Certification by Administrative Authority to Billed Entity of Compliance with the Children’s Internet Protection Act Form) and provided it to your consortium leader.

Under certain circumstances you can file the FCC Form 486 early – that is, before services have started. In order to file early, you must be able to make all of the certifications on the form. The following are some reminders of the certifications you must be prepared to make now if you are filing your FCC Form 486 early.

Receipt of positive funding decisions
You must have received an FCDL with at least one positive funding commitment. In EPC, you will not be able to file an FCC Form 486 for an FCC Form 471 Funding Request Number (FRN) unless USAC has issued a commitment for that FRN.

Service start dates and contracts
You must have confirmed with your service provider(s) that the service(s) for your approved funding commitments will start on or before July 31 of the funding year. You must also confirm that those services will be provided to the eligible entities identified on the FRNs.

In addition, you certify that there are signed contracts covering all of the services listed on the FCC Form 486, except for those services provided under tariff or on a month-to-month basis.

Authorization to submit
You must also certify that you are authorized to submit the FCC Form 486 on behalf of the billed entity; that you have examined the form; and that to the best of your knowledge, information, and belief, all statements of fact provided on the form are true.

You can review the text of all the certifications on the FCC Form 486 after you have completed your entries for the required information on the form. Please review the certifications carefully to make sure that you can accurately make them as of the start of the receipt of discounted services. Do not forget to check the Early Filing box.

CIPA reminders
The administrative authority – the relevant authority with responsibility for the administration of the school or library – must report the status of compliance with CIPA.

  • If you are the administrative authority for the school or library and you are the billed entity, you certify your status of CIPA compliance on your FCC Form 486.
  • If you are the administrative authority but not the billed entity – for example, if you are a member of a consortium and the consortium files for discounted services on your behalf – you certify your CIPA compliance status on the FCC Form 479 and provide a copy of that form to your consortium leader. Your consortium leader must have copies of FCC Forms 479 on file from all of its members before it can accurately make the appropriate CIPA certifications on the FCC Form 486 on behalf of its members.

Starting August 1, early filing no longer applies. At that point, you must wait until services have actually started before you file your FCC Form 486.

Overview of the PIA Review Process

Program Integrity Assurance (PIA) is the process USAC uses to review applications for compliance with program rules and policies. USAC reviews the information on your FCC Form 471 and may contact you with additional questions on specific items. Below is a summary of the Initial Review, Final Review, and Quality Assurance steps in the PIA review process.

Initial Review
USAC assigns an initial reviewer to process your FCC Form 471. The information you provided on your form may be sufficient for the initial reviewer to complete your review. If not, the initial reviewer prepares the questions that USAC must ask based on the information you provided (or did not provide) on your application.

The initial reviewer issues questions to you via EPC. You will receive an email when the questions are available. If you are a public school or library, we also notify your state E-Rate coordinator.

  • You can click the link provided in the email to access our questions. You can also navigate to the Pending Inquiries section of your organization's landing page in EPC and, using the drop-down menus, choose "FCC Form 471" for the Type and "2022" for the Funding Year.
  • Read each question carefully. The inquiry may require you to provide a Yes/No answer, a short response in a text field, or a file or scanned document.
  • Only one user can work on a specific inquiry at one time, although different users can work on different inquiries simultaneously. One user can allow another user to review and/or edit their work by saving a draft response and then exiting the inquiry.

Please respond promptly to any PIA requests for information or documentation. Reviewers will continue their attempts to contact applicants to ensure that they are available to respond to inquiries.

During the PIA review process, you always have the following options:

  • If you do not understand one or more questions, you can ask your initial reviewer what the question means or what information USAC expects in your response.
  • You can ask for more time to respond. However, note that your initial reviewer may not be able to return to your application quickly once you provide the information.
  • You can ask to speak to a manager if you are having trouble communicating with your initial reviewer. USAC will not penalize you for doing so, and the manager can help you understand the questions USAC is asking and the responses USAC expects to receive.

If USAC intends to modify or deny a funding request, your initial reviewer will notify you through EPC. You can provide additional information at this point, but you must respond quickly because we do not stop the review process to wait for a response.

Final Review and Quality Assurance
Final Review is a peer review of the work done during Initial Review. The final reviewer checks each step of the Initial Review process to verify that they followed the correct procedures, asked the appropriate questions, and received complete answers. If the final reviewer has any concerns, they will return the application to the initial reviewer for follow-up.

As a result, your initial reviewer may contact you with additional questions to gather the required information that they did not request or receive during Initial Review. Make sure you understand the supplemental information requested and that you respond as quickly and accurately as possible.

Some applications go through a third level of review called Quality Assurance (QA). QA is an additional check to verify that the reviewers correctly completed all parts of the application review. As with Final Review, the QA reviewer may return applications to the initial reviewer for follow-up.

The review process is not linear. If a QA reviewer returns an application to an initial reviewer, the status on the progress bar at the top of your FCC Form 471 may move to the left – that is, to an earlier review status. If you do see such a movement, monitor your email in case an initial reviewer attempts to contact you.

Update Your Contract Award Date to Aid Quicker PIA Reviews

If you are using a new or existing contract on your FCC Form 471, you must have a contract record for that contract in your EPC profile. A contract record provides specific details about a contract – e.g., the establishing FCC Form 470, the number of bids received, the service provider, the contract terms, the contract award date (CAD), etc. – so that this information can be auto-populated from your profile to the appropriate funding request on your FCC Form 471.
 
It is particularly important to make sure the CAD is accurate for the contract you cited on your FCC Form 471.  An accurate CAD and uploading a copy of the contract to the contract profile can help Program Integrity Assurance (PIA) reviewers expedite the review process by avoiding additional outreach.

To create a contract record in your EPC profile, go to the organization page for the parent organization (independent school, school district, independent library, library system, or consortium), click Contracts from the menu choices at the top of the page, then choose Manage Contracts, and click on Add a New Contract.

  • You do not need to create a new contract record for a multi-year contract or a contract with voluntary extensions if you previously created the contract record in EPC.
  • For a contract that has been voluntarily extended through FY2022, you can cite the existing contract record on the appropriate funding request on your FCC Form 471 and then enter the extended date in the field labeled "What is the date your contract expires for the current term of the contract?"

If you have a new contract or need to make changes to an existing contract record, you must create a new contract record. EPC does not allow edits to a contract record after it has been submitted. You are encouraged – but not required – to upload a copy of your contract into your contract record. If you do not upload your contract, be sure to keep a copy handy in case USAC requests it during the review of your application.

View the How to Create a Contract Record video for a demonstration on entering your contract information.

RAL Modification Requests & Post-Commitment Corrections

USAC issues an FCC Form 471 Receipt Acknowledgment Letter (RAL) to both the applicant and service provider(s) in the E-Rate Productivity Center (EPC) after an FCC Form 471 application is certified.  The letter contains many of the details submitted on the FCC Form 471 and provides a means to correct any mistakes.  If you were not able to make all of the appropriate updates to your applicant profile in EPC before the close of the EPC FCC Form 471 administrative window, you can provide updated information by filing a RAL Modification Request after submitting and certifying your FCC Form 471 application(s) but before you receive your Funding Commitment Decision Letter.

Many times FCC Form 471 applications are submitted with multiple types of equipment placed on a single funding request (FRN) Line Item, which can slow down the PIA review process. You can use the RAL Modification Request process to separate unique types of equipment into separate FRN Line Items, which will help reviewers more quickly complete your form reviews.

Applicants receive the RAL in their EPC News Feed after certifying an FCC Form 471. The RAL Modification function in EPC allows you to provide specific information in an organized format, which makes it easier for PIA reviewers to locate and understand the changes you want to make. Go to the Ministerial & Clerical Errors page to see the types of changes that are allowed and not allowed for the FCC Form 471. To learn how to submit modification requests for your FCC Form(s) 471, view the FCC Form 471 Receipt Acknowledgment Letter Modification Guide.

If USAC has issued an FCDL, you must request any modifications through a post-commitment request such as a Service Substitution request, a SPIN Change request, or an Appeal.

May 26 Deadline for New Tribal Libraries to Submit FY2022 FCC Form 471

The FCC's Wireline Competition Bureau (WCB) released an order (DA 22-231) granting a waiver of the FY2022 E-Rate application filing deadline for new Tribal library entities that file within 65 days of the window close. Applications with at least one new Tribal library listed as a recipient of service will have until Thursday, May 26, 2022 at 11:59:59 p.m. ET to submit and certify the FCC Form 471 in EPC.

Please note that Thursday, April 28, 2022 is the last date for these Tribal library applicants to submit and certify an FCC Form 470 and still wait the required 28 days before submitting and certifying the FCC Form 471 by the May 26 filing deadline. We encourage Tribal library applicants to file their FCC Form 470 as soon as possible and not to wait until April 28, 2022.

USAC’s Tribal Training page has resources available to assist Tribal entities in applying for funding including:

Upcoming Training

  • Office Hours for Tribal E-Rate Applicants (Tuesday, May 17)

♦ Register

Overview: This session provides an opportunity for Tribal E-Rate applicants and consultants to ask the USAC E-Rate team questions regarding the FY2022 E-Rate funding application process and the recent E-Rate Tribal training sessions.

Recorded Training Sessions

  • E-Rate Information Session for Tribal Library Applicants (April 5)

    ♦ View a Recording
    ♦ Slide Deck

    Overview: This session provides an overview of the E-Rate program and covers general topics such as the application process, the competitive bidding requirements, important program terms, eligibility, and program discounts.
  • Establish a Consortium (April 12)

    ♦ View a Recording
    ♦ Slide Deck

    Overview: This session provides an overview of the different roles and responsibilities for the consortium leader and members followed by a live Q&A session.
  • Office Hours for Tribal E-Rate Applicants (April 19)

    ♦ View a Recording
    ♦ Slide Deck

    Overview: This session provides an opportunity for Tribal E-Rate applicants and consultants to ask the USAC E-Rate team questions regarding the FY2022 E-Rate competitive bidding and funding application process and the recent E-Rate Tribal training sessions.

You may contact the USAC Tribal Liaison, Kraynal Alfred, at Tribaltraining@usac.org or the Customer Service Center at (888) 203-8100 Monday through Friday, 8 a.m. to 8 p.m. ET, if you have any questions about the FCC Form 470 or the FCC Form 471.

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