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June 12, 2020

TIP OF THE WEEK: As a reminder, June 30, 2020 is the last day to receive recurring services for Funding Year (FY) 2020. While October 28, 2020 would normally be the last day to file an invoice for those services, the FCC has provided all applicants and service providers an automatic 120-day extension of the invoice filing deadline for any funding request with an invoice deadline between March 11, 2020, and October 28, 2020 to provide relief to E-rate Program participants affected by COVID-19 (see the April 3, 2020 SL News Brief).

Commitments for Funding Year (FY) 2020 and FY2019

FY2020. USAC released FY2020 Wave 6 Funding Commitment Decision Letters (FCDLs) on June 11. As of June 12, FY2020 commitments total over $909 million.

FY2019. USAC released FY2019 Wave 62 on June 10. As of June 12, FY2019 commitments total over $2.37 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).

FCC Form 470 Unchanged for FY2021

The FY2021 FCC Form 470 will be available July 1, 2020. Applicants with long procurement cycles or other reasons for starting their FY2021 competitive bidding processes early will be able to complete and certify this form as soon as it is available in EPC.

On June 8, 2020, the FCC released a Public Notice (DA 20-598) to inform program participants that the FCC Form 470 — including the drop-down menu options for requesting internet access — will remain unchanged for FY2021 to minimize burdens on schools and libraries impacted by COVID-19. This public notice defers changes to this form until FY2022.

On June 8, the FCC also issued guidance in the form of a letter to USAC (DA 20-597). The letter reminds applicants that:

  • The appropriate drop-down option for an applicant seeking bids for internet access delivered to its premises (i.e., a service that includes data transmission service) is either Leased Lit Fiber (with or without Internet Access) or Internet Access and Transport Bundled (Non-Fiber).
  • The appropriate drop-down option for an applicant seeking bids on bulk internet, which the applicant is responsible for transporting to its premises, is Internet Access: ISP Service Only (No Transport Circuit Included).

In this letter, the FCC also directed USAC not to deny or issue a commitment adjustment for any FY2020 E-rate application "solely because the applicant selected the Internet Access: ISP Service Only (No Transport Circuit Included) drop-down menu option and subsequently selected on its FCC Form 471 a service that delivers internet access to its premises. For those applications, USAC should not find a competitive bidding violation so long as the applicant has otherwise complied with all of the Commission's competitive bidding rules." The FCC issued similar guidance for FY2019 and FY2018 applications (see DA 19-985 and DA 18-444 for more information).

Last year, the FCC sought comment on improving the FCC Form 470 drop-down options (see Public Notice DA 19-986, released October 1, 2019). To mitigate potential confusion stemming from use of a modified FCC Form 470, and to reduce the administrative burden on schools and libraries impacted by COVID-19, the FCC Form 470 changes will be deferred until FY2022.

FCC Form 486 Deadlines Updated

FCC Order DA 20-364, released April 1, 2020, temporarily waived and extended several E-rate filing and service implementation deadlines. One of these extensions affects program participants whose FCC Form 486 deadline falls between March 11, 2020 and September 30, 2020. These participants will have an additional 120 days to submit these forms without penalty.

We have now extended the filing deadline in EPC for the individual funding request numbers (FRNs) covered by this order. This means that, if the original deadline to certify the FCC Form 486 featuring one or more of these FRNs fell or falls between March 11, 2020 and September 30, 2020, the deadline has been extended an additional 120 days. This includes forms which have not yet reached their original deadline, forms which have already received an FCC Form 486 Urgent Reminder Letter, and forms which have already received an FCC Form 486 Notification Letter modifying their service start date due to a late filing.

Remember that the customary deadline calculation for certifying the FCC Form 486 is 120 days after the FCDL (or Revised FCDL, if that is the first notification that funding was committed) or 120 days after the service start date featured on the form, whichever is later. This means that we have already updated all of the FCC Form 486 deadlines covered by the order.

  • For any new funding decisions USAC issues for funding years before FY2020, the calculated deadline for the FCC Form 486 will fall after September 30, 2020.
  • For FY2020 funding decisions, the earliest FY2020 FCC Form 486 deadline is October 29, 2020.

Updates Deployed to EPC

Summer/winter deferral status tab added

During the summer deferral period — which this year runs from May 22, 2020 to September 11, 2020 — USAC will put the review of your FCC Form 471 on hold if we attempt to contact you during this period and we do not receive a response. This deferral also applies to our reviews of other program forms.

We have added a new Deferral History tab in EPC to provide more information about the deferral status of your application.

To view the status, navigate to the appropriate FCC Form 471 in EPC. Click the Deferral History tab at the top of the page. The resulting page will provide not only the summer deferral status, but the history of the status, including when the application was placed on summer deferral and who requested the status change.

  • Please note: EPC will continue to update the review status on the Summary tab based on any automated notifications. You should refer to the Deferral History tab for the current deferral status of your application.

This update will also provide information on winter deferral status when we enter the winter deferral period later this year.

Save Draft button removed

One of the features of the Appian platform (the platform that houses EPC) is a Save Draft button. This button appears in the top left-hand corner of each page of a program form or request created in EPC.

However, this button never worked correctly and confused program participants, so we removed it from all program forms and requests filed in EPC.

As a reminder, if you exit a program form or request before completing it, EPC automatically saves the information you have provided up to that point and creates a task in your Tasks menu to allow you to pick up where you left off.

 

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