On Thursday, October 8, 2015, USAC held it’s second training session for E-rate applicants in Tampa, Florida. The training focused on program rules, updates, and best practices. Here are some of the highlights from the applicant training in Tampa, Florida:
Staff Introductions: Mel Blackwell, Catriona Ayer, John Noran, Eric Flock, Mick Kraft, Denise Samuel & Joe Freddoso
- SLD has added and trained new staff to handle PIA to meet the September deadline to issue funding commitments
- USAC will be implementing field testing by users in the ‘field’ to test the new EPC portal
- Targeting opening of the Form 471 filing window in January 2016
- FCC 471 is a work in progress – USAC is working day and night on developing and adding new features to the form
- In Funding Year 2015 less than 500 applications were considered ‘complete’ (requiring no additional review to issue an FCDL)
Goals for FY2016:
- Meet or exceed the FY15 deadline to fund all ‘workable’ application – targeting August 2016 to issue commitments. This will be dependent on the speed and completion of the applications received (the earlier the applications are filed in the funding window, the quicker FCDL’s can be issued)
- More information will be on the ‘front end’ of the applications to minimize mistakes
- Developing ‘automated’ application reviews to minimize PIA questions and speed up the review process. This is also dependent on how quickly an applicant responds to PIA questions.
EPC Portal Updates – John Noran
- The EPC portal is taking advantage of the technology advances over the past few years
- Real time question/answers through the EPC portal to help expedite applicant’s questions
- RAL changes can be made within the portal system – no paper RALs for FY16
- USAC will be rolling out an APP that can be used on mobile devices to access the EPC system and will not be limited to a specific browsers – still in development stage
- To add a new entity applicants will still need to contact Client Service Bureau (CSB). Applicants can update an entity information through the EPC portal
- Fields in the EPC portal identified with red asterisks are required fields on all forms
- Applicants can attach supporting documents rather than using current Submit a Question and sending the attachments separately. Applicants can also assign a case contact, rather than the person submitting the question if they want someone else designated. The case record ‘thread ‘remains in portal indefinitely for future use
- Profile picture! Applicants can attach a profile picture. Word of caution, if you do, everyone that ‘follows’ you will get notifications, and the notifications will include your picture.
Fiber Service – Eric Flock
- Construction now eligible beyond the applicants property lines
- Comparison of dark to lit fiber– most cost effective solution must be supported. Applicants must account for modulating equipment and cost of maintenance for dark fiber service when comparing against lit fiber service, and make the comparison over a set period of time.
- RFPs should be tailored to be specific about the tier of bandwidth speeds that the applicant is seeking, taking into consideration that a multi-year contract could result from the solicitation and the RFPs should account for the potential increase in bandwidth over the term of the contract.
- Cost effectiveness will be closely scrutinized by USAC, this will include the RFPs and evaluation to determine cost effectiveness. Special circumstances will be taken into consideration.
- Do not expect that the FCC will be designating any preferred master contracts to be used for Funding Year 2016
- Monitoring is considered eligible in the managed broadband services category
- Budgets are entity specific (no sharing) – no changes expected
- Category 2 five year ‘span’ begins the first year that applicants use the C2 funds. Example: if 2016 is the first year C2 funds are used, then the five year begins in 2016 and ends in 2020.
Invoicing – Mick Kraft
- Changes to Form 472; beginning July 1, 2016 all BEARs will be direct pay. This includes all previous years, and all paper BEAR will be discontinued. Applicants should expect more invoice review.
- Applicants will be paid by ACH (Automated Clearing House).
- Payments will be issued twice weekly, and paid when the BEARs are approved on Mondays and Thursdays and should be in the applicant’s bank account the next business day. Targeting six days total from submission to payment.
- Applicants will need to submit an FCC Form 498 and designate a company officer
- Bank account cannot be owned by a consultant, the account must be the institutions account
- Form 498 will require the applicants Federal Employer Identification Number (EIN/Tax ID)
- Form 498 will require a DUN & Bradstreet Number (DUNS) – will need to get one. Go to federal documents to obtain a DUNS number for the institution. New Form 498 will be available in January – required to be completed before July. Six months to gather necessary information.
Audits – Denise Samuel
- USAC is preparing to roll out more limited scope audits -risk based approach
- Most common finding is lack of documentation – example relying on state to maintain NSLP. Applicants should retain state posted NSLP/CEP data and not rely on the state. If the state cannot produce the information, the applicant can be liable.
Question: BYOB devices – who is responsible for filtering?
Answer: still awaiting guidance from the FCC
Question: What will happen with the current DRT tool?
Answer: USAC is limiting the data available by state, BEN or SPIN. They are looking at ways to make this information more available to general public.
Question: What if an applicant overestimated the enrollment for a new school, when will it need to be paid back?
Answer: the funds will need to be returned in the next funding year (following the submission of the application).
Question: Are cloud based licenses services eligible
Answer: Yes, if the licenses are supporting eligible wireless controllers (for example). If the licenses are supporting other hardware that is not eligible, a cost allocation would be required.
Question: A school on a military base is being charged a federal easement charge, is this an eligible charge?
Answer: USAC did not have an answer to this question, and was taken offline for discussion. This is the first time they have been asked this question
Question: Will applicants receive email notifications outside of the portal for PIA?
Answer: for ‘key’ things applicants will receive an email but it will not include the question. The questions or task will be in the EPC portal.
Question: Will the portal communications be from 16 moving forward?
Answer: Initially it will be for FY2016, but all funding years will move there eventually
Question: can a consultant add information for her clients (example student counts, etc.)?
Answer: Coming soon to the EPC portal anyone with partial or full administrative rights will be able to make updates and actions on behalf of an applicant.
Question: Are Consortia’s still required to collect Letters of Agency since authority is being granted in the portal?
Answer: Yes, LOA’s are still required.
Question: The new form 470 application does not display the 28 day Allowable Contract Date.
Answer: John Noran confirmed that this date will be in the EPC portal shortly. It will appear in three places on the EPC site/form (currently not on Form 470’s posted).
Question: Will there be a more robust search tools?
Answer: Yes, it’s still in development. The search tool will be on the USAC site, not in the EPC portal.
Question: Applicants uploaded Excel docs (Item 21b) for FY15 but will the new EPC portal allow for the upload of various file types?
Answer: Yes, and they have tested it with zip files up to 100Mg
Question: – can documents be ‘shared’ in the EPC portal?
Answer: If one person is viewing the document, another person cannot access it at the same time. Example was ‘passing the baton’.