USAC’s Schools and Libraries Division hosts monthly service provider conference calls, providing information and guidance for vendors participating in the E-rate program. Highlights from the November 13, 2013 service provider call include:
October 2013 Funding Commitments
Update on FY2014 Eligible Services List
On October 22, 2013, the FCC released an Order finalizing the Eligible Services List for Funding Year 2014 and authorizing USAC to open the Funding Year 2014 Form 471 filing window no earlier than December 23, 2013. In the Order, the FCC adopted “the proposals made in the 2014 ESL Public Notice, with some minor modifications.”
Changes to the Funding Year 2014 version of the Eligible Services List include updated eligibility criteria for lit and dark fiber services, as well as updates to the eligibility of web hosting and e-mail services. For web hosting services, the FCC states that, “Interactive communications features that may be eligible as part of a web hosting package are not eligible for support as standalone services and that applicants may not request E-rate funding for web hosting services from multiple providers.”
Payments in the last 30 days totaled over $292 million against $350 million in requests. 95% of the invoices were processed within 30 days.
Top Denial Explanations:
- Total Commitment Paid
- SPIN Not Registered
- Billed Before Form 486 Date
- Billed After Funding Year
- No Form 486
Funding Year 2012 invoice deadlines will be automatically extended for one year. The invoice deadline for FY2012 recurring services will be moved from October 28, 2013 to October 28, 2014, and the deadline for non-recurring services will be extended from January 28, 2014 to January 28, 2015. While extensions will be automatically granted for invoice deadlines, installation and service delivery deadlines will not receive an extension.
Form 471 Window: The SLD may send out an announcement regarding the window dates as early as next week
Question: If an applicant is requesting only POTS on their Form 470, do they need to consider VoIP if bid responses are received?
Answer: Yes, applicants will need to evaluate the VoIP bid response and can use any selection criterion that meets their state and local procurement regulations; however, price must be weighted the most.
Question: The Eligible Services List indicates that an eligible Wide Area Network must have at least one of its connection points at an eligible location. However, the proposed revision for FCC Form 471 regarding "last mile" connections appears to indicate that this requirement does not apply for state networks and consortia. Are state networks and consortia provided wider eligibility for WANs than other applicants such as large school districts? If so, please indicate the rule or Order that confirms this.
Answer: No, there are no special requirements for state networks or consortia.
Question: On Nov 1, 2013 USAC released the quarterly report indicating that there is $400 Million that can be rolled over for the 2013 P2 funding. Can you confirm that these funds will be used for P2 and when any funding commitments will be released?
Answer: The SLD indicated they currently have $400 million available for rollover, but it is the FCC that must determine if and when that announcement will be made.
Question: If an applicant has a 5 year multi-year agreement that was competitively bid through the E-rate process and then skips a year of funding, would the applicant need to file another Form 470 during the third year of the contract?
Answer: No, the applicant would not need to go through the E-rate competitive bidding cycle and post a Form 470 to the SLD website.
Question: Can a school website be E-rate eligible?
Answer: Yes, however the FY 2014 Eligible Service list clarifies that, “Interactive communications features that may be eligible as part of a web hosting package are not eligible for support as standalone services and that applicants may not request E-rate funding for web hosting services from multiple providers.”
Question: Can vendors provide technology planning advice?
Answer: Technically yes, vendors can provide neutral advice, however, the SLD stated they would recommend that vendors do not engage in this activity because in the event of an audit or investigation it is very difficult to prove a competitive bidding violation did not occur.
Note: The information above is not the official minutes from the call, but simply notes from Funds For Learning.