“In the interest of efficient program administration,” on April 25, 2016, the FCC released an Order denying invoice extension requests for 125 applicants. The FCC declared that it “is generally not … in the public interest to waive the invoice deadline rules” unless there are extraordinary circumstances.

  • The applicants directly impacted by the decision were primarily small schools.
  • The median applicant denied payment supports 2 sites and serves 985 students.
  • The average discount rate involved in the denials is 71.5%.
  • 80% of the applicants did not list a consultant on their Form 471 application.
  • The sum total of undisbursed funds for the applications in question is $2.1 million.
  • The undisbursed funds represent, on average, $31.79 per student.

Each E-rate funding request has an invoice deadline associated with it. This is the last date for submitting payment paperwork, such as reimbursement forms, to USAC.  As a part of its reform of the E-rate program, the FCC codified invoice extension rules. Stakeholders who request an extension before the filing deadline may receive an additional 120 days to submit their forms.

In the denials released this week, the applicants filed their extensions after the invoicing deadline had passed. The FCC expressed that “…applicants and vendors are responsible for knowing and following our rules, and for submitting their E-rate filings in a timely manner…” The FCC specifically stated that employee confusion, lack of understanding of the many E-rate rules, and staff turnover are not valid reasons for the FCC to grant a waiver of the deadlines. The FCC also reminded stakeholders that they are ultimately responsible for knowing and following the rules and regulations regardless of whether or not they receive “alleged” inconsistent or incorrect advice from USAC concerning rules or procedures.