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A Blanket Invoice Extension is Needed

Per the FCC’s new rules tied to E-rate 2.0, applicants and service providers may request a one-time invoice extension from USAC. Regardless of the reason USAC must grant the extension. Recurring invoices for FY2015 must be submitted to USAC by October 28, 2016. However, there have been a host of challenges with applicants meeting the upcoming deadline:

  • The EPC system has been working intermittently over the last few weeks and USAC and the FCC are aware of these issues;
  • The reality is that school administrators only have a few hours in a given week to work on E-rate and having EPC system not reliable is something “outside the control” of the applicant and should be taken into consideration by the FCC and USAC;
  • There have been well documented cases that the FCC and USAC are aware that applicants have been waiting weeks and months in order to receive a BEAR PIN and the invoicing deadline is now a couple of weeks away;
  • Based on new E-rate regulations, applicants wishing to receive direct reimbursement must fill out the Form 498 in order for the SLD to complete the direct deposit process. Many applicants have had challenges completing the Form 498 and even more are just now understanding of this new process;

USAC should be focusing their energy on improving EPC for FY2017 and not having to go through the process of possibly approving thousands of individual invoice deadline extension requests. That would be a waste of USAC resources.

We are all praying for those affected by Hurricane Matthew and it is very conceivable that many schools will be flooded and those that are not damaged, may be evacuation sites for those displaced. School administrators should be focusing on helping their local communities and not worrying about the invoice deadline approaching.

While deadlines are very important, we all understand why the FCC and USAC need to enforce the myriad of deadlines in the E-rate program. However, we can all agree that there are extenuating circumstances. For instance: all the issues around EPC, the new process, plus having several states adversely impacted by Hurricane Matthew. I hope the FCC announces soon that they will issue a blanket one-time invoice extension for FY2015 recurring services deadline, coming up on October 28, 2016.

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