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E-Rate News Brief
August 18, 2023
E-RATE TIPS:
• The FCC’s Wireline Competition Bureau (WCB) waived the following E-Rate program rules on August 18 for applicants and service providers located in the areas affected by the recent Hawaii Wildfires: (1) the 60-day deadline to file appeals and requests for waiver; (2) the deadline to file FCC Forms 486, 472, and 474; (3) the September 30, 2023 service implementation deadline for non-recurring services; (4) portions of the service and equipment substitution rule; and (5) document retention and production requirements for participating E-Rate applicants and service providers whose documents were destroyed by the Hawaii Wildfires. The Bureau also waived the following Emergency Connectivity Fund (ECF) program rules: (1) the 30-day deadline to file appeals and requests for waiver; (2) the deadline to file FCC Forms 472 and 474; (3) portions of the service and equipment substitution rule; and (4) document retention and production requirements for participating ECF applicants and service providers whose documents were destroyed by the Hawaii Wildfires. For both E-Rate and ECF participants, the deadline to file appeals and waivers and for the relevant FCC Forms, is 150 days from the release date of the Order. Read the WCB order (DA 23-723) to learn more.
• Change to EPC Commitment Adjustment (COMAD) Notifications. After August 25, 2023, the E-Rate Productivity Center (EPC) will send Demand Payment Letter (DPL) notifications to all user contacts with Post-Commitment full rights authorization to view information for the applicant and service provider on the impacted FRN(s) when there is a COMAD-related notification (i.e., DPL1, DPL2, etc.) for a funding request.
• As a reminder, Funding Year (FY) 2023 applicants who have received a funding commitment from USAC and whose services have started can certify an FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form). Service providers should submit and certify an FY2023 FCC Form 473 (Service Provider Annual Certification) as soon as possible, if you have not already done so. USAC cannot pay an invoice from either an applicant (FCC Form 472) or a service provider (FCC Form 474) unless both forms have been certified and approved.
• Applicants should carefully review the FCC Form 486 to confirm the correct CIPA certification status is selected, and that the service start date on the form is correct. Please confirm the service start date(s) with your service provider before submitting the FCC Form 486.
• Invoicing Service Certifications must be signed by applicants. USAC sends a service certification form to applicants and service providers to confirm that eligible equipment was delivered, or for funding request numbers (FRNs) that include installation, that the eligible equipment was delivered and installed. The service certification should be read carefully, completed accurately, provide the date that eligible equipment was delivered, and for FRNs that include installation, provide an accurate installation date for the eligible equipment. The form must be signed and certified by the applicant only. Service providers should work with their applicant to get the service certification signed for a submitted FCC Form 474 (Service Provider Invoice Form).
• Review the information below if you are an applicant that intends to invoice USAC by filing an FCC Form 472 (Billed Entity Applicant Reimbursement (BEAR) Form) and have not yet certified an applicant FCC Form 498 (Service Provider and Billed Entity Identification Number and General Contact Information Form). Remember that you need to recertify your form if you have made any changes, such as updating your banking information. The FCC now requires all entities (applicants and service providers) to have an active SAM.gov Unique Entity Identifier (UEI) if they submit a new FCC Form 498 or modify their existing form. See the April 2023 E-Rate News Brief for more information.
• The FCC Form 470 and the Competitive Bidding Process Webinar was held July 27. This webinar provides E-Rate participants with information on how to file the FCC Form 470 and about the E-Rate competitive bidding process. This webinar is for applicants and service providers of all levels of E-Rate experience, with an emphasis on beginner level participants. View the recording. View the webinar slides.
Contents
Commitments for Funding Year (FY) 2023 and FY2022
FY2023. USAC released FY2023 Wave 17 Funding Commitment Decision Letters (FCDLs) on August 17. As of August 17, FY2023 commitments total over $1.94 billion.
FY2022. USAC released FY2022 Wave 59 Funding Commitment Decision Letters (FCDLs) on August 16. As of August 17, FY2022 commitments total over $2.82 billion.
On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in EPC.
Requesting Service Delivery Deadline Extensions for FY2022 Non-Recurring Services (Other than Special Construction)
The deadline for delivery and installation of non-recurring services (e.g., installations, equipment purchases) is September 30 following the close of the funding year. For FY2022, the deadline for non-recurring services other than special construction is Monday, October 2, 2023 (September 30, 2023 is a Saturday).
This service delivery deadline (SDD) can be extended for up to one year under certain circumstances, through an extension request. In some cases, the extension will be automatically made based on the Funding Commitment Decision Letter (FCDL) date or the revised FCDL (RFCDL) date.
Requesting extensions
Service providers who are (1) unable to meet their service delivery deadline for reasons beyond their control such as supply chain delays, or are (2) unwilling to complete delivery and installation because USAC withheld invoice payments on the services for more than 60 days, can ask the affected applicants to request a one-year extension with USAC, which must be approved.
Applicants can request the one-year extension by completing and certifying an FCC Form 500 (Funding Commitment Adjustment Request Form) on or before October 2, 2023 for FY2022 non-recurring services. If your service delivery deadline for a Funding Request Number (FRN) is approved and the deadline extended to September 30, 2024, USAC will automatically extend the invoice deadline for that FRN to January 28, 2025. There is no need to submit an invoice deadline date (IDD) extension request for an extended FRN when submitting an SDD extension request. If you do submit an IDD extension request at the same time, it will count towards your one-time invoicing extension, and you will not be able to request a second IDD extension request in the future if you need it.
If, as a service provider, you are aware of the need to request an SDD extension, work with your customer (the applicant) to get the FCC Form 500 completed and certified no later than October 2, 2023.
Automatic extensions
If USAC issues an FY2022 FCDL on or after March 1, 2023, the SDD is automatically extended for one year to September 30, 2024. This also applies to RFCDLs issued on or after March 1, 2023, for one of the following:
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Approval of an appeal for a funding request that originally denied or reduced funding,
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Approval of a Service Provider Identification Number (SPIN) change, or
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Approval of a service substitution.
The FCDL or RFCDL contains the extended SDD date when it is issued. You can also find the SDD by searching for the FRN using the E-Rate FRN Status Tool FY2016+.
Summer Deferral Period for FY2023 PIA Review Ends September 8
During the summer contact period, Program Integrity Assurance (PIA) will put the review of your application on hold if we cannot make a live contact by telephone with the contact person or someone else who has been designated to respond to our questions. You also have the option to request a summer deferral before September 8 if you know you will not be available to answer PIA questions and you cannot designate someone to answer questions on your behalf. You can place your application on summer deferral in EPC or ask your PIA reviewer to do so.
Our summer contact period is defined as the Friday before Memorial Day through the Friday after Labor Day. For 2023, the summer deferral contact period began May 26. The summer deferral contact period will end Friday, September 8.
If your application currently shows a summer deferral status in EPC but you are available to answer questions and want to restart your application review, simply contact your reviewer using the contact information featured on your PIA questions in EPC. You can also call the Customer Service Center (CSC) at 888-203-8100 for assistance if you cannot find your reviewer's contact information.
E-Rate Training Opportunities
USAC will hold a Service Provider webinar in September that will provide an understanding of the service provider’s role in the process of delivering E-Rate supported services and equipment to applicants. USAC will hold two E-Rate Open Data webinars in September to help E-Rate program participants learn about available E-Rate Open Data resources and how to create custom reports.
Service Provider Webinar
Tuesday, September 12
3 p.m. to 4 p.m.
This session will give service providers who are new to the E-Rate program an understanding of their role in the process of delivering E-Rate supported equipment and services to applicants.
E-Rate Open Data Course 1: Open Data Overview
Thursday, September 14
3 p.m. to 4 p.m.
Do you want easy access to your E-Rate data? USAC's data sharing platform, Open Data, gives you that access with the added benefit of tools to help make your data easier to sort and track. This webinar gives an overview of what Open Data is and how you can make it work for you.
E-Rate Open Data Course 2: Creating Reports and Visualizations
Thursday, September 21
3 p.m. to 4 p.m.
A follow-up to the September 14 Open Data Overview, this webinar will dive deeper into the tools and visualizations that are available. You will be taken through the steps to create your own custom reports and how to turn them into clear, comprehensible visuals.
BEAR and SPI Form Reminders for Date Fields
Some applicants and service providers have experienced automatic denials or manual reviews where they have entered incorrect dates on their invoices (FCC Form 472 /applicant BEAR Form and FCC Form 474 /Service Provider Invoice (SPI) Form) for specific Funding Request Number (FRN) line items. This includes FRN invoice line items for both recurring and non-recurring services. We are providing the reminders below to assist program participants with correctly entering dates on invoice forms.
On both BEAR and SPI Forms, the Customer Billed Date field is for recurring services and the Shipping Date to Customer is for non-recurring services. A single FRN line item should have a date in one field or the other, but not both fields.
The date in the Customer Billed Date field for each line item should be the date of the customer bill, that is, the date of the bill sent by the service provider to the applicant. The customer bill will either be for the full cost of the service (if the applicant is filing BEAR Forms) or for the applicant's share of the cost (if the service provider is filing SPI Forms). In all cases, this date should be the first date of service for that line item. For example:
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An applicant wants to enter three line items on a BEAR Form, one for each month of recurring services in the first quarter of the funding year (i.e., July, August, and September). The applicant should put the date of the customer bill they received from the service provider for July on the first line item, the date of the bill for August on the second line item, and the date of the bill for September on the third line item.
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Similarly, a service provider wants to enter three line items on a SPI Form, one for each month of recurring services in the first quarter of the funding year. The service provider should put the date of the customer bill they sent to the applicant for July on the first line item, the date of the bill for August on the second line item, and the date of the bill for September on the third line item.
If you enter the first day of the funding year for all three line items instead of the date of the actual customer bill for each line item, the second and third line items will either be automatically denied or flagged for manual review, and the processing of your BEAR or SPI form may be delayed.
Filing the Applicant Version of the FCC Form 498
Applicants who request reimbursements directly from USAC by submitting an FCC Form 472 (BEAR Form), must first certify an FCC Form 498 (Service Provider and Billed Entity Identification Number and General Contact Information Form). USAC must review and approve your FCC Form 498 before you can receive your 498 ID, the identifying number that will appear at the top of your BEAR Form after you log in to the E-Rate Productivity Center (EPC).
You do not have to re-file an FCC Form 498 if you already have an approved form. Be sure, however, to review and update your form if any of your information has changed.
If you are filing the FCC Form 498 for the first time, be sure you have provided the required banking information and documentation with your FCC Form 498.
On May 12, 2023, USAC updated the FCC Form 498 for all E-Rate applicants to require entities to have an active SAM.gov Unique Entity Identifier (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. See the April 2023 E-Rate News Brief for more information.
Bank account information for direct payments
To identify the bank account where you want USAC to send your direct payments, you will be asked to provide your bank's name, your bank's routing number, and your account number at the bank. The bank account information provided on the form cannot be for a bank account owned by a consultant.
After you certify your form for the first time – or you update your additional BENs and/or your bank account information on your existing form – USAC must review your form.
We will ask you for proof of your bank account information, such as a bank statement or canceled check. Once USAC has verified and approved your documentation, your form status will change from "Certified" to "Approved" and your 498 ID will show up at the top of your BEAR Form after you log in to EPC.
A common mistake made by first-time filers is not submitting the supporting documentation. You do not have to wait for us to notify you to upload the documentation. You can upload your bank account documentation to our secure server immediately after you certify your form.
Finally, you can log into EPC to check the status of your form.
FCC Adopts Order Providing Tribal Libraries Greater Access to E-Rate Program Funding
The Federal Communications Commission (FCC) took steps to further enhance Tribal applicants’ access to the E-Rate program through program simplifications and other changes aimed to encourage greater Tribal participation. The FCC, in the July 21 order (FCC 23-56), also took steps to simplify E-Rate processes for other E-Rate applicants.
Specific updates to the E-Rate program rules include:
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Granting E-Rate eligibility to Tribal College and University libraries that also serve as public libraries in their communities;
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Adopting a formal definition of “Tribal” in the E-Rate program to better identify Tribal applicants seeking E-Rate funding;
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Creating an exemption to the competitive bidding requirements for libraries (Tribal and non-Tribal) seeking E-Rate support for Category Two (C2) services that total a pre-discount price of $3,600 or less per library per funding year;
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Increasing the maximum C2 discount rate to 90% and the C2 funding floor to $55,000 for Tribal libraries;
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Adding a Tribal community representative to the USAC Board of Directors and to the Schools and Libraries Committee of the Board; and
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Directing USAC to provide increased outreach and training to Tribal applicants.
Go to the FCC’s Tribal Order page to learn more.
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