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E-Rate News Brief


April 18, 2024

Contents

E-RATE TIPS:

•  Join us for the Program Integrity Assurance (PIA) Review and Selective Review Process Webinar today, April 18, from 2 p.m. to 3 p.m. Eastern Time (ET). This webinar will provide E-Rate participants with an overview of the Program Integrity Assurance (PIA) Reviews, Selective Reviews, and the funding decision processes. Register.

•  FY2024 Window Waiver Requests. If you plan to request a waiver of the Funding Year (FY) 2024 application filing window deadline, be sure to certify and submit your FCC Form 471 in the E-Rate Productivity Center (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.

•  If you used the Interim SPIN. If you used the interim Service Provider Identification Number (SPIN) 143666666 to submit your FY2024 funding requests, submit a Receipt Acknowledgement Letter (RAL) modification request to provide the actual SPIN. View the FCC Form 471 Receipt Acknowledgment Letter Modification Guide.

•  FCC Form 470 Legacy Tools Retired April 15. USAC decommissioned the View an FCC Form 470 and the Download FCC Form 470 Information tools on April 15. The same data is found in the E-Rate FCC Form 470 Download Tool in USAC’s Open Data platform, which has easy-to-use filters to locate FCC Form 470 data and Request for Proposal (RFP) documents. Users can create their own custom reports or pull data using an API call via the E-Rate FCC Form 470 Tool Data Set.

•   With the invoicing migration to EPC, it's important to ensure 472/BEAR (applicants) and Invoice (service providers) permissions are up to date in EPC. You must have one full rights user – two are recommended – to ensure you have someone who can certify and sign important invoice documents. Only a full rights user can sign and certify documents and forms.

•  Did you know that you can upload all necessary documents, like bills and worksheets, when submitting your invoice for review? This helps USAC review and process invoices more efficiently and reduces the need for outreach. You can upload these documents when creating an invoice line item in EPC. View the Invoice Line Item Summary section of Applicant Course 1: Submitting and Certifying Invoices in EPC or Service Provider Course 1: Submitting and Certifying Invoices in EPC to learn how to upload supporting documentation at the time you submit your invoices.

•   Remove ineligible items to speed invoice reviews. Applicants and service providers should remove all ineligible services and equipment before submitting invoices to USAC. Only invoice for the specific equipment and services at the quantities and rates approved and only for the approved Recipients of Service (ROS) on your FCC Form 471.


Commitments for Funding Year (FY) 2023

FY2023. USAC released FY2023 Wave 51 Funding Commitment Decision Letters (FCDLs) on April 11. As of April 17, FY2023 commitments total over $2.58 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). 

Service Providers: Have You Filed the FCC Form 473?

Have you checked your filing status for FCC Form 473 (Service Provider Annual Certification (SPAC) Form) in EPC for FY2024 and prior funding years? USAC started sending reminders to service providers who have not yet filed their annual SPAC on April 1, 2024, and will send subsequent reminders periodically through June 30.

Service providers must have a SPAC Form on file for a funding year before USAC can pay invoices – FCC Forms 472 (BEAR) or FCC Forms 474 (SPI) – for that funding year. Only Full or Partial Rights users can complete the SPAC in EPC. For step-by-step directions on how to complete the SPAC online, go to the FCC Form 473 (SPAC) User Guide.

Service providers can check the status of their FCC Form 473 for a given funding year by opening their organization's summary page in EPC. You can also use the E-Rate FRN Invoicing Deadline Tool to lookup your Service Provider Identification Number (SPIN) and check the SPAC Filed? column.

Overview of the PIA Review Process

Program Integrity Assurance (PIA) is the process USAC uses to review FCC Forms 471 for compliance with E-Rate program rules and policies. USAC reviews the information on your application 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 provide 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 and 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 "2024" 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 what supplemental information is being requested and that you respond as quickly and as 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.

Next Steps Related to the FY2024 Application Filing Window

The application filing window for Funding Year (FY) 2024 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 EPC 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: Review the contact information for your school district and each of your individual schools, along with their actual or estimated student counts (for your Category One 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: Review the 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 Category One 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 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 recommend that all applicants and services providers take the time now to organize and save all documents related to your application in a manner that will allow you to easily locate and retrieve them for any future needs. Go to the E-Rate Document Retention page and review the E-Rate Program List of Documents to Retain for Audits and to Show Compliance with Program Rules to learn more.

Prepare for 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 account 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 Billed Entity Number (BEN), Service Provider Identification Number (SPIN), state, or Funding Year. View a video on how to use the tool.

Update Your Contract Award Date to Aid Quicker PIA Reviews

If you are using a new or existing contract on your FY2024 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.

  • 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 FY2024, 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 and 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 (FCDL).

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, an FCC Form 500, or an Appeal.

2024 Training and Outreach

USAC is coming to an event near you in 2024. Below are some events we will attend in the next few months. Visit the In-Person E-Rate Training Events page to learn more about the events we’ll be attending where we can answer your E-Rate questions.

Conferences  

  • Visit USAC at the 2024 Utah Library Association (ULA)/Mountain Plains Library Association (MPLA) Conference May 8-10, 2024 in Salt Lake City, Utah (Booth #107). Event Link.
  • Visit USAC at the American Library Association (ALA) Annual Conference June 27-July 2, 2024 in San Diego. Event Link.
  • Visit USAC at the Southeastern Library Association (SELA) Annual Conference July 14-16, 2024 in Huntsville, Alabama. Event Link.

2024 In-Person Training

E-Rate experts will provide training and discuss program updates. There will be time at the end of the sessions for USAC to answer questions from both new and experienced participants.

Registration will open on April 23 at 3 p.m. Eastern Time (ET). Register for a training by selecting a link below when registration opens.

  • E-Rate Training: September 17, 2024 from 9:30 a.m. to 5:30 p.m. Central Time in Dallas, Texas. Register.
  • E-Rate Training: October 7, 2024 from 9 a.m. to 4 p.m. Eastern Time in Washington, D.C. Register.
  • E-Rate Training: October 29, 2024 from 9:30 a.m. to 5:30 p.m. Central Time in Fayetteville, Arkansas. Register.

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