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E-Rate News Brief
April 21, 2023
E-RATE TIPS:
• The FY2023 FCC Form 473 (Service Provider Annual Certification (SPAC) Form) is now available in 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. View the FCC Form 473 User Guide for more information.
• FY2023 Window Waiver Requests. If you plan to request a waiver of the FY2023 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. If the waiver request is granted, the FCC Form 471 will be treated as timely filed during the filing window.
• USAC will host a PIA and Selective Review Process Webinar on Tuesday, April 25, 2023, 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.
• USAC will host a E-Rate Program Participant Webinar on the System Consolidation on Thursday, April 27, 2023, from 2 p.m. to 3 p.m. ET. E-Rate staff will discuss the system changes, who is affected, the implementation timeline, and how USAC will support applicants and service providers throughout the transition. Register.
Contents
Commitments for Funding Year (FY) 2022
FY2022. USAC released FY2022 Wave 52 Funding Commitment Decision Letters (FCDLs) on April 13. As of April 19, FY2022 commitments total over $2.84 billion.
On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in EPC.
Next Steps Related to the FY2023 Application Filing Window
The application filing window for FY2023 has closed. Below we provide a few reminders 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:
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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).
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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.
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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.
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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 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 many 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, 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 if 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 FCC Form 471 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 E-Rate FRN Status Tool FY2016+. 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 FY2023 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 2023 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. To file early, you must be able to make all 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.
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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.
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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.
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Certifications. You certify that there are signed contracts covering all the services listed on the FCC Form 486, except for those services provided under tariff or on a month-to-month basis.
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.
Starting August 1, early filing no longer applies. At that point, you must wait until services have 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 E-Rate 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 the E-Rate Productivity Center (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.
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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 "2023" for the Funding Year.
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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.
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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:
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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.
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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.
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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 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.
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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.
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For a contract that has been voluntarily extended through FY2023, 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 Acknowledgement Letter (RAL) to both the applicant and service provider(s) in EPC after an FCC Form 471 application is submitted and 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 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 submitting and 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.
UEI Required Beginning May 12 for Applicants that Update or Submit New FCC Form 498
On April 6, 2022, the FCC released a Public Notice (DA-22-371) announcing that the General Services Administration’s SAM.gov will transition from the use of the Data Universal Numbering System (DUNS) number to the SAM.gov assigned Unique Entity Identifier (UEI). In the September 15, 2022 E-Rate News Brief, USAC announced that all service providers receiving funding through the universal service programs will be required to obtain and use a UEI when making changes to their existing or submitting a new FCC Form 498.
On May 12, 2023, USAC will update the FCC Form 498 for all E-Rate applicants to require entities to have an active UEI to submit a new FCC Form 498 or to modify their existing FCC Form 498 if they will be using the BEAR method of reimbursement. After this deployment, the FCC Form 498 system will only accept the applicant’s UEI if the following criteria are met:
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The SAM.gov registration for your entity is active;
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The Employer Identification Number (EIN) for the UEI matches the EIN for the FCC Registration Number; and
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The EIN for the UEI matches the EIN on the FCC Form 498.
The update of the FCC Form 498 will affect E-Rate applicants that must submit a new FCC Form 498 or revise their current FCC Form 498, after the May 12, 2023 deployment date.
Next Steps
After May 12, 2023, USAC will require all E-Rate applicants with a 498 ID (i.e., that use the Billed Entity Applicant Reimbursement (BEAR) method for reimbursement) to obtain and use the SAM.gov UEI when making changes to their existing form or submitting a new FCC Form 498. E-Rate applicants that do not currently have a 498 ID or only uses, or will only use, the service provider invoicing (SPI) method for reimbursement, are not required to register in SAM.gov to obtain a UEI.
If you are already registered in SAM.gov, you have a UEI. To find your UEI, log into SAM.gov and select the Entity Management widget in your Workspace or log in and search Entity Information. Please ensure that your SAM.gov registration is active and the EIN for your UEI, the FCC Registration Number, and the FCC Form 498 numbers match. Once you have completed these steps, add your UEI to your FCC Form 498 ID. Entities’ registrations in SAM.gov require annual renewal or the accounts will be deactivated. Please ensure that your organization annually renews its SAM.gov registration prior to the expiration date listed in your entity’s record in SAM.gov.
If you are not registered in SAM.gov, register now to obtain your UEI. You may need to allow up to six weeks for the registration to be completed for SAM.gov. Once you register with SAM.gov, you will be automatically assigned a UEI and can add your UEI to your FCC Form 498 ID.
If you need help obtaining a UEI or have additional questions, please contact USAC’s Customer Service Center, Contributors/Service Providers option, at (888) 641-8722 or visit SAM.gov for additional information on how to obtain a UEI or register your entity.
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