March 25, 2016

TIP OF THE WEEK: CONSORTIA: Before you start your FCC Form 471, check the entities in your EPC profile to make sure that (1) the list is complete and (2) all of the entities have the correct entity type (that is, independent school, independent library, school district, library system, or non-instructional facility). If they do not, and you start your FCC Form 471, you may need to take an additional step before the Client Service Bureau can perform the necessary entity type updates.

Commitments for Funding Year 2015

Funding Year 2015. USAC will release Funding Year (FY) 2015 Wave 43 Funding Commitment Decision Letters (FCDLs) on March 31. This wave includes commitments for approved requests for all service types and at all discount levels. As of March 25, FY2015 commitments total over $3.16 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC's Automated Search of Commitments tool.

Piggybacking and Piggyback Clauses in Contracts

In the FY2016 FCC Form 471, applicants are asked if other entities can piggyback off the cited contract and, if the cited contract was created by another applicant, if they are piggybacking off the other applicant's contract.

A piggyback clause in a contract allows an entity to use another eligible entity's existing contract to purchase products and services in lieu of establishing its own contract. A piggyback clause is permissible for E-rate purposes only if the following conditions are met:

  • It must be permissible under your state and local regulations,
  • The contract or RFP must allow for other entities to be added,
  • You must still post your own FCC Form 470, AND
  • You must conduct your own competitive bid evaluation and follow all applicable E-rate competitive bidding requirements.

To determine how to answer these questions in the contract records that you create in your EPC profile, review the following scenarios.

  • State Master Contracts are not considered piggyback contracts, so if you are purchasing off a State Master Contract, answer no to both questions.
  • If the contract that you cited in an FRN is between you and your service provider, and you allow other applicants to use that contract as well (subject to the conditions mentioned above), answer yes to the first question. If not, answer no.
  • If the contract that you cited in an FRN was originally signed between another school district, library system, or private school and your service provider and you exercised the piggyback clause in that contract (as explained above), answer yes to the second question. If not, answer no.

Update on Bulk Upload Templates

In response to overwhelming requests from our stakeholders, one of our top priorities for the opening of the FY2016 application filing window was to enhance the current Funding Request bulk upload feature to include the recipients of service. The benefit of using this feature is that applicants can prepare FRN line item information in an Excel template where the data can be more easily manipulated prior to uploading it directly into the FRN.

Extending this upload feature to include recipients of service will allow applicants to also identify the specific entities that are receiving the service in the FRN line item and to provide the required allocations of the connections for Category One services or dollars to Category Two recipients of service. Finally, users asked that we allow copy and paste functionality so that the data could more easily be manipulated.

We were not able to deliver these new and improved templates with the recipients of service functionality by the opening of the window as we had hoped, so we created a simpler version mirroring the FY2015 functionality – that is, one without the ability to allocate connections for Category One services or dollars to Category Two recipients of service – that we hoped would help applicants prepare and upload at least some of the required information. At the same time, USAC continued development on the enhanced functionality.

Unfortunately, those templates did not accomplish the larger goal of providing complete data at the FRN line item level. In the end, earlier this week we took the templates and the associated instructions down from the website and temporarily deactivated the functionality in EPC in order to prepare for the updated functionality. We apologize for doing this without advance notice to all of our stakeholders.

We are now nearing the end of the development of new versions of these templates that will provide all of the functionality we promised earlier. Just as in the past, there will be a separate template for each of the following five service types: Data Transmission and/or Internet Access, Voice Services, Internal Connections, Basic Maintenance of Internal Connections, and Managed Internal Broadband Services. Each template will allow the user to create multiple FRN line items within the single FRN, along with the recipient of service allocations for each FRN line item on the spreadsheet.

Each of these improved templates will consist of three tabs:

  • The first tab will allow the data entry of the services and cost information for the line items on an FRN. The information in this tab is largely the same as that in the previous spreadsheets, but we have added a few additional columns to allow us to tie the FRN line item to the associated recipients of service data.
  • The second tab will allow the data entry of the required recipients of service information, together with the associated allocations, and contain a mechanism to automatically link the correct recipients of service to each FRN line item in the first tab.
  • If the upload attempt is unsuccessful, the third tab will provide a list of errors that prevented the information in the template from being uploaded into the form, so that the applicant will understand exactly which information must be corrected before he or she can attempt a new upload. (If the data are not correct, none of the information in the file will be uploaded, so as to avoid any confusion.)

Final review and testing will occur during the early part of next week. We will release individual templates early if they are ready to go, but we expect to have all five templates available by the end of next week. At that time, we will also be providing full instructions to applicants on how use the new templates.

Please keep an eye out in EPC for online communication regarding the status of the bulk upload feature.

Again, we apologize for any inconvenience.

State Matching Provision for Special Construction of Fiber

In the Second E-rate Modernization Order, the FCC adopted rules providing additional Category One funding to match state funding for special construction to connect schools and libraries to high-speed broadband services that meet the FCC's long-term capacity broadband goals. The E-rate Program will increase an applicant's discount rate for special construction charges up to an additional 10% to match state funding on a one-to-one dollar basis. For schools operated by the Bureau of Indian Education or Tribal governments and libraries operated by Tribal governments, the one-to-one dollar match of up to 10% will be available for funding received for special construction costs from states, Tribal governments, or other federal agencies.

Information about the availability of such state match funding has been posted on USAC's website. The webpage includes information about particular state broadband programs that we believe (based on information received to date) would qualify as matching funds for purposes of increasing the funding an applicant is eligible to receive from the E-rate program for special construction of services. If you are aware of any other state, Tribal, or federal program that provides funding for broadband special construction charges that is not included on this web page, please contact USAC to provide further information about the program.

Last Week in "File Along with Me":

  • Category Two budgets. Read More
  • Inputs to your Category Two budget (square footage and student counts). Read More
  • Category Two budget recalculation, plus changing student counts. Read More
  • Category Two budgets for non-instructional facilities (NIFs). Read More

"File Along with Me" is a blog that covers the E-rate Program application process step-by-step, and serves as a schedule you can follow to manage your application. Ready to join us? Read the Blog

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