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FCC Receives Comments on Proposed Form Changes

On March 8, 2013, the FCC released a Public Notice seeking comment on proposed revisions to the Form 472, Form 473 and Form 474 and their associated instructions.  It would appear from the feedback provided by commenters that several of the potential changes were not popular.

Numerous commenters raised concern about the new certification on the draft Form 473 (Service Provider Annual Certification) related to the Lowest Corresponding Price rule.  Commenters argued that the LCP rule can be unclear at times, and that the Commission has not provided a reasonable explanation of the “scope of [service providers’] obligation under this certification requirement.”  As such, commenters generally suggested that the new certification be removed until further guidance is given on the LCP requirement.

Commenters also proposed additional changes to the FCC Form 474 (Billed Entity Applicant Reimbursement), suggesting that additional fields be added to provide remittance information for reimbursement payments channeled through the service provider.  The change would, according to the comments, simplify and expedite the reimbursement process.

Comments submitted to the Commission regarding the Form changes include:

The State E-rate Coordinators’ Alliance (SECA)

CSM Consulting, Inc.

Sprint Nextel Corporation

United States Telecom Association

The Schultz Group, PLLC

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