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E-Rate News Brief


June 15, 2023

E-RATE TIPS:
 
•  USAC will host a Beginning E-Rate Services Webinar on June 27. This session gives applicants and service providers a high-level overview of the next steps in the E-Rate process, after equipment and services are funded. Register.

•  FY2023 Invoicing Begins on July 1. After USAC has processed your FCC Form 486 you or your service provider can begin the process of invoicing USAC for the discounted share of costs for the approved eligible equipment and services. View the February 10, 2022 webinar slides to learn more about the invoicing process and for key reminders.

•  Reminder: The Summer Deferral period, which applies to USAC’s processing of program forms and requests, started May 26. If our first attempt to contact you about a program form or request is on or after May 26, and we do not receive a response to our questions, we will put your application or request on a deferred status and will continue the review after September 9. You can always contact your reviewer or respond to our pending questions to restart the review, or you can designate someone to answer questions in your absence.

•  Reminder: On May 12, 2023, USAC updated the FCC Form 498 for all E-Rate applicants (who use or will use the BEAR method of reimbursement) to require entities to have an active SAM.gov generated Unique Entity Identifier (UEI) if they submit a new FCC Form 498 or if they modify their existing FCC Form 498. See the April 21, 2023 E-Rate News Brief for more information.


Contents

Commitments for Funding Year (FY) 2023 and FY2022

FY2023. USAC released FY2023 Wave 7 Funding Commitment Decision Letters (FCDLs) on June 8. As of June 14, FY2023 commitments total over $1.38 billion.

FY2022. USAC released FY2022 Wave 55 Funding Commitment Decision Letters (FCDLs) on June 7. As of June 14, FY2022 commitments total over $2.83 billion.

On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in EPC.

Complete and Certify Any In-Process FY2023 FCC Forms 470 by June 23

Some applicants currently have uncertified FY2023 FCC Forms 470 within the EPC system. In order to prepare for the deployment of the FY2024 FCC Form 470 on July 1, USAC must delete uncertified FY2023 FCC Forms 470 at the end of this month.

Any applicant who wants to rely on an uncertified FY2023 FCC Form 470 that is currently in the EPC system should certify that form no later than June 23. The FY2023 FCC Form 470 will then be posted to USAC's website and can then still be cited, for example, to open a competitive bidding process for FY2024.

Reminder: Request a Service Delivery Deadline Extension by June 30 if you will not Complete Special Construction Required to Light or Use Your Fiber

To be eligible for E-Rate program discounts for special construction charges, special construction must be completed in time for the fiber to be lit or to be in use by the end of the relevant funding year (i.e., June 30, 2023 for FY2022). This applies to leased lit fiber, leased dark fiber, or a self-provisioned network involving another technology. If this June 30 deadline is not met and you have not received an extension, the special construction charges will not be eligible for support under program rules and a waiver will be needed from the FCC.

If you sought support for special construction related to leased lit fiber, leased dark fiber, or self-provisioned networks for FY2022, you may request a one-year extension of the June 30 deadline by demonstrating that construction was unavoidably delayed due to weather or other reasons, or by the late issuance of an FCDL. You must demonstrate that the reason or reasons have unavoidably delayed special construction in a manner that prevents the fiber from being lit (or a self-provisioned network using another technology to be in use) by the June 30 deadline.

Applicants must file an FCC Form 500 by June 30 to request this one-year extension. See the FAQS: Eligible Fiber Services for additional information regarding deadlines and extensions in relation to non-recurring special construction charges.

If you have not received your FCDL and you need to request an extension of this deadline, file a customer service case in EPC and attach a completed FY2022 Special Construction Deadline Extension Request (SCDER) to the case on or before June 30, 2023.

If you need assistance, you can open a customer service case in EPC or call the Customer Service Center at (888) 203-8100.

Filing the FY2023 FCC Form 486 Early

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 the applicant certifies the status of their compliance with the Children's Internet Protection Act (CIPA).

Under certain circumstances, you can file the FCC Form 486 before the services have started. In order to file early, you must be able to accurately 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.

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 also 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 equipment and services on your behalf – you certify your status of CIPA compliance on the FCC Form 479 (Certification by Administrative Authority to Billed Entity of Compliance with the Children's Internet Protection Act Form) 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.

You can also refer to the CIPA page on the USAC website for additional information about the requirements under CIPA.

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 Funding Request Numbers (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 a 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 equipment and services. Do not forget to check the Early Filing box.

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.

FY2024 FCC Form 470 will be Available in EPC on July 1

The FY2024 FCC Form 470, which starts the competitive bidding process, will be available July 1 in the E-Rate Productivity Center (EPC). Applicants with long procurement cycles or other reasons for starting their FY2024 competitive bidding processes early will be able to complete and certify this form as soon as it is available in EPC. The FY2024 FCC Form 470 remains unchanged from last year.

Here are some resources on the FCC Form 470 and the competitive bidding process:

Also keep an eye on the E-Rate Webinars page for information on upcoming training on the FCC Form 470 and Competitive Bidding in July.

Getting Ready for Invoicing

After USAC has processed your FCC Form 486 (Receipt of Service Confirmation and Children’s Internet Protection Act Certification Form), you or your service provider can begin the process of invoicing USAC for the discount share of the approved eligible equipment and  services (see Filing the FY2023 FCC Form 486 in April's News Brief). USAC can process invoices from either the applicant or the service provider after the following have occurred:

  • USAC has issued a Funding Commitment Decision Letter (FCDL) with a positive funding commitment;
  • Services have started (USAC can process invoices for progress payments after review of the contract if it includes a specific payment schedule);
  • The applicant has submitted, and USAC has successfully processed, an FCC Form 486; and
  • The service provider has filed an FCC Form 473 (Service Provider Annual Certification (SPAC) Form) for the relevant funding year.

There are two methods that can be used to invoice USAC. Once USAC has processed an invoice for a Funding Request Number (FRN), that method of invoicing must be used for that FRN for the remainder of the invoicing process.
 
Invoicing Method #1 – FCC Form 472
Applicants file the FCC Form 472 (Billed Entity Applicant Reimbursement (BEAR) Form) if they have paid the service provider in full for the equipment and services and want to be reimbursed for the discount amount. For BEAR invoices, the applicant must have paid the service provider in full for the received equipment and services and before invoicing USAC.

Applicants file BEAR forms online in the Schools and Libraries (E-Rate) program legacy system. Billed entities will receive payment directly to their bank account. In order to begin direct BEAR payments, the applicant must have completed an FCC Form 498 to obtain an applicant 498 ID.

Invoicing Method #2 – FCC Form 474
The service provider files the FCC Form 474 (Service Provider Invoice (SPI) Form) if you have billed the applicant for the non-discount amount (the applicant’s share of the cost) and want to be reimbursed for the discount amount. For SPI invoices, the applicant must pay the service provider their non-discounted portion for the received equipment and services before you can invoice USAC.

USAC will review the SPI Form and disburse the payment to the service provider if payment is approved. The applicant is always required to pay the non-discounted portion of the costs for the equipment and services.

There are two options for completing and submitting the SPI Form:

  • Service providers can file online, or
  • Service providers can file electronically. USAC will set up electronic invoicing upon request and then service providers can submit invoicing information to USAC in a comma-delimited file.

Invoice Filing Deadlines
Invoices must be submitted no later than 120 days after the last day to receive service; 120 days after the FCC Form 486 Notification Letter date; or 120 days after the date of a revised Funding Commitment Decision Letter approving a post-commitment request made by the applicant or service provider or a successful appeal of a previously denied or reduced funding request, whichever is later. Generally, the deadline is October 28 for recurring services and January 28 for non-recurring services based on the last day to receive service.
 
Applicants and service providers may request and automatically receive a single one-time 120-day extension of the deadline to submit an invoice for the FCC Form 472 (BEAR Form) or FCC Form 474 (SPI Form). Invoice deadline extension requests must be submitted on or before the invoice filing deadline in order for the request to be considered timely filed. If the deadline to file an invoice or to request an invoice filing deadline extension is missed, a request for waiver of the invoice filing deadline must be filed with the FCC and approved before any additional payments can be paid.
 
Invoicing Reminders
Below are some reminders to help ensure you submit successful invoices.

  • Invoice USAC only for your FCC Form 471 approved eligible equipment and services, in the correct quantity and rates, and delivered only to the approved Recipients of Service (ROS).
  • Invoiced amount must be actual charges, not the amount committed through the E-Rate program.
  • Manual calculations for prorated amounts must be accurate.
  • Billed rates must not exceed the contracted rates. USAC will only pay up to the contracted rate.
  • Make sure that all equipment purchased is installed and in use before the Service Delivery Date.
  • Establish a process to prevent duplicate invoice submission.
  • Invoices can be submitted until the Invoice Filing Deadline.
  • Request a one-time invoice deadline extension, even if you do not anticipate needing one, before the invoice filing deadline.
  • Remove ineligible items (equipment and services not approved on FCC Form 471, for FY and ROS).
  • Retain your supporting documentation and bills for all invoices for at least 10 years.
  • Respond in a timely manner to all outreach to expedite your payment.

USAC’s website has video tutorials on how to submit the FCC Form 472 or the FCC Form 474, a webinar recording and slides from the February 2022 E-Rate Invoice Training, and pages for the FCC Form 472 and FCC Form 474 to help you navigate the invoicing process.

 

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