CDE E-Rate News Flash October 20, 2017 Issue 17-13

E-Rate News Flash

E-rate Funding Year 16 (2016–17) Invoicing Deadline

Monthly recurring services received between July 1, 2016 and June 30, 2017 have an invoicing deadline of October 30, 2017. Invoicing is accomplished using one of two methods.

     1.  The local education agency (LEA) submits the Federal Communications Commission (FCC) Form 472, also known as the Billed Entity Applicant Reimbursement (BEAR) form, to the Schools and Libraries Division (SLD) of the Universal Service Administrative Company (USAC) to receive reimbursement, after each invoice is paid in full.
     2.   The Service Provider submits FCC Form 474, also known as the Service Provider Invoice (SPI) form, to the SLD for reimbursement on the discounted portion of the product or service provided to the LEA.

The LEA may request a one-time invoice deadline extension if either the LEA or the Service Provider need additional time to complete invoicing. A one-time extension of 120 days can be requested, but must be requested prior to the deadline of October 30, 2017.

LEAs that use the BEAR method for reimbursement must also have:

     1.  A Personal Identification Number (PIN) to access the online FCC Form 472.
     2.  An approved FCC Form 498 on file to receive a direct reimbursement from USAC.

A detailed discussion of how to complete the invoicing process can be found in the October 6, 2017 Schools and Libraries Program (SLP) News Brief, which is posted on the SLP's Training and Outreach Web page at http://usac.org/sl/tools/news-briefs/preview.aspx?id=791.

E-rate Funding Year 17 (2017–18) FCC Form 486 Deadline

LEAs that have received a Funding Commitment Decision Letter (FCDL) on or before July 1, 2017 have a deadline of October 30, 2017 to submit the FCC Form 486. The general rule for calculating the deadline for this form is 120 days after the start of services, or 120 days after the date the FCDL was posted. LEAs receiving an FCDL after July 1 can calculate the FCC Form 486 deadline using this general rule.

Missing this deadline can result in a loss of funds. A detailed discussion of how to submit the FCC Form 486 can be found in the October 13, 2017 SLP News Brief, which is posted on the SLP's Training and Outreach Web page at http://usac.org/sl/tools/news-briefs/preview.aspx?id=796.

New guidance for the FCC Form 470

The August 22, 2017 Special Edition News Brief issued by the SLP discussed new drop-down menu options on the FCC Form 470. This simplification was implemented so that LEAs would have a better understanding of what they are required to bid on in the event they were seeking certain fiber options for transport services. The August 22, 2017 Special Edition News Brief can be accessed from the SLP's Training and Outreach Web page at http://usac.org/sl/tools/news-briefs/preview.aspx?id=786.

Although simplification was attained in most instances, the new drop-down menu has created confusion regarding the option of "Internet Access and Transport Bundled". This option has, in the past, been considered technology neutral since the means of transport was not defined. Service Providers could submit proposals containing any method of transport as long as it resulted in a service that delivered Internet access to the LEA.

The new guidance for LEAs seeking technology neutral bids is to select both "Internet Access and Transport Bundled" and "Leased Lit Fiber". LEAs that select only "Internet Access and Transport Bundled" on the FCC Form 470 will be denied funding if the winning Service Provider delivers the bundled internet access over fiber. Service Providers may inadvertently respond with proposals for Wide Area Network (WAN) services, since that is what the "Leased Lit Fiber" selection has meant historically. LEAs are encouraged to use the "Narrative" section of the FCC Form 470 to provide clarification to the Service Provider. Maintain a copy of all proposals received in order to ensure compliance with program rules.

Additionally, the new guidance makes it apparent that LEAs should request that Service Providers include the delivery method and speed of the Internet access in their proposals. LEAs can use the "Narrative" section of the FCC Form 470 to notify Service Providers of this requirement. LEAs have the option of posting a Request for Proposal (RFP) in addition to posting the FCC Form 470. In this case, these requirements can be specified in the RFP to ensure that Service Providers are aware of the requirement.

Detailed definitions for each drop-down menu option in the FCC Form 470 are available in the FCC Form 470 User Guide. Access the Form 470 User Guide from the SLP's Forms Web page at http://usac.org/_res/documents/sl/pdf/e-rate-productivity-center/Filing-FCC-Form-470.pdf.

Additional Information & Support

The SLP, commonly known as E-rate, provides timely information and insight through their Weekly News Brief. If you have not already done so, we encourage you to sign up to receive these communications by visiting the SLP's Web page at http://www.usac.org/sl/tools/news-briefs/Default.aspx .

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