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RFCDL Guidance Cause for Concern

Applicants that received revised funding commitment decision letters (RFCDL) should check the last day to invoice (LDI) before submitting for reimbursement. 

Several applicants that have received RFCDL notifications have found that FRNs that were listed as approved (or otherwise revised) were not being added to the FRN extension table. When they reached out to the CSB for clarification, they were advised to resubmit the invoice as the “30 days started from when you received the RFCDL”. The representative went on to state that they were unsure about what their concerns were as “the RFCDL tells you the information. Please read and follow the information listed in the RFCDL.”

While the RFCDL does state (on the very last line of the very last page) that a specific applicant has “30 days from the date of this letter to submit an invoice”, this does not rectify the greater concern of the FRNs not appearing on the extension table. If a reimbursement request is filed after the original LDI as shown in USAC’s system, it will be automatically denied. 

And this will lead to more appeals, more delays, and an easy target for critics of the administrators desire to “modernize and streamline” the program. 
For applicants that received RFCDLs to avoid any unnecessary delays in reimbursement, they should first check to see if the FRNs in question have been added to the extension table. If they have, make certain that you file the reimbursement requests within 30 days of the date of the RFCDL. 
However, if the FRNs do not appear on the extension table, reach out to USAC via opening a case in EPC and state your concerns. Until enough applicants bring this issue to their attention, it is likely going to be met with the same generic “read the letter and do what it says” response. And if this instruction is followed before the FRNs are added to the extension table, it will only perpetuate the cycle of denials, appeals, waiting, waiting, waiting, etc. 
That being said, if you are approaching the end deadline for reimbursement submission and the FRNs are still not listed on the extension table, you should submit, even if it is only going to end in denial, to demonstrate your compliance with the rules. This will make any subsequent appeals you may have to file stronger by demonstrating your compliance with the guidance received. 
If we receive any updates or see any changes as to how the FRNs are added to the extension table in the event of an RFCDL, we will provide an update. But in the meantime, be vigilant in your review of any RFCDLs and notify USAC of any FRNs that are not appearing on the extension table. 
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