On April 17, 2017 the FCC sent revised guidance to USAC regarding their Quarterly Filings and how to calculate their reserves for possibly carrying forward unused funding. The FCC is now instructing USAC to maintain reserves for all pending applications, funding that has been committed, but not yet disbursed to stakeholders and all pending USAC and FCC appeals.
USAC had been instructed to generally not reserve funding for pending application and appeals that were older than three years, per the 2014 Letter.
However, USAC has been reserving some funds for older appeals on an ad hoc basis. In addition, the Second E-rate Modernization Order
required USAC to review and update its processes for evaluating and recommending reserve amounts to fund pending applications, undisbursed funding commitments, and pending appeals.
FCC has stated that the current letter seeks to clarify the different instructions that came in the 2014 Letter and the Second
E-rate Modernization Order.
The current FCC letter to USAC can be viewed here