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Procedural Impossibility

On October 31 of this year, USAC released their updated Administrative Procedures for the 2013 Funding Year. This year as I was reviewing the procedures, the following section stood out:

    Applicants may voluntarily extend a contract without posting a new FCC Form 470 if the applicable FCC Form 470 or Request for Proposal (RFP) that initiated the procurement process (resulting in the contract), indicated that the applicant sought to enter into a multi-year contract with extensions.

The problem with this procedure is there is no longer a place to indicate on the Form 470 that an applicant intends to enter into a multi-year contract with extensions. In 2010, the FCC updated the Form 470 in order to eliminate questions that were not useful and streamline the collection of data. As a part of the update, checkboxes for multi-year contracts and contracts with voluntary extensions were removed from the Form.

While the FCC may have removed this box and considered it non-essential information, it is quite possible that a USAC PIA reviewer may still ask. Since an applicant may not be required to release an RFP, they will need some way of indicating on the current Form 470 that a multi-year contract with extensions is an option that they are considering. Currently, the only place available on the Form 470 to add this type of information would be in Block 2, Item 13. As applicants prepare for FY2013 and review contracts and 470s, this is a helpful item to check if the referenced 470 was released within the last couple of years.

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