Finishing Internal Connections Projects
On May 4, Funds For Learning stressed the importance of filing the Form 486 in a timely manner, but it is important for applicants and service providers to understand the myriad of dates and deadlines which apply to E-rate projects in order to be successful. One such date is the service delivery deadline, also commonly referred to as an “installation deadline.”
The service delivery deadline for recurring services such as telecommunications, internet access, and basic maintenance services is always June 30th of the funding year, and this deadline may not be extended. The deadline for non-recurring services such as internal connections projects is September 30th of the funding year, which is designed to provide a bit of extra time for larger internal connections projects to be completed.
That is easy enough to understand, right? However, there are many circumstances where the installation deadline of an internal connections projects gets extended even further:
- If an applicant receives a FCDL after March 1st of the funding year then the SLD automatically extends the installation deadline until September 30th of the following year.
- In many cases where there is a delay in receiving a FCDL, the project scope may experience slight changes which require a service substitution request. If a service substitution gets approved on or after March 1 of the funding year, the SLD will extend the project an additional year.
- If certain conditions are met, an applicant can change vendors. If the SLD approves a SPIN change after March 1 of the funding year, the service delivery deadline will be extended an additional year.
- If an applicant is denied funds and successfully appeals their decision to the SLD or the FCC, they are also given additional time to complete the project.
- Finally, applicants may request a service delivery deadline extension for a variety of reasons, including construction delays, out-of-stock products, and other circumstances which are out of their service providers’ control.
Unfortunately, many applicants and service providers fail to adequately track and monitor the deadlines associated with their funding requests. Staff turnover, funding delays, and changes in organizational objectives can easily contribute to a funded project being “forgotten” until the service delivery deadline expires and it is too late to request an extension.
FFL has prepared a summary of funding requests in Funding Years 2000-2009 where the installation deadline has been extended to September 30, 2011. There is currently $930 million of approved funding which is available for use by that deadline. If the service delivery deadline has been extended for your project, it is important to review the applicable contracts to determine if contract term extensions or service substitutions will be required. If the contract is extended, the applicant will need to file the FCC Form 500 to inform USAC of the updated contract expiration date. If this is not done, the SLD will not approve BEAR or SPI payments for any work done after the original contract expiration date.
Funds For Learning will continue to release regular analysis of E-rate deadlines and trends that are critical to understanding the E-rate program.