FCC Clarifies Rules on Existing Category 2 Budget Cycles

Responding to a request for clarification in a letter from the Schools, Health & Libraries Broadband Coalition (“SHLB”) the FCC confirmed the rolling five-year nature of the current Category 2 budget cycle.  Five-year budget cycles were first established as a two-year trial in the First E-rate Modernization Order (FCC 14-99).  The FCC subsequently extended the trial to five years in the Second E‑rate Modernization Order (FCC 14-189).  The implementing language in the First Order appeared to clearly indicate that an applicant’s five-year budget would begin the first year an applicant was funded and extend over the next four years.  On the other hand, the Orders indicated that the Category 2 budget trial would expire after FY 2019.  This suggested that all “five-year” budgets, begun after FY 2015 might be truncated as of FY 2019.  Recognizing that the FCC was planning to address Category 2 budgets in a new order to take effect in FY 2020, USAC has studiously avoided requests to clarify the post-FY 2019 status of budgets initiated in or after FY 2016.

The FCC’s response to SHLB’s request for a definitive clarification, albeit verbally, confirms that a five-year budget with an initial commitment in FY 2016 extends through FY 2020.  More generally:

This is a welcome clarification, but one that does not fully establish Category 2 funding rules post-FY 2019.  For that we must await a new FCC order, hopefully issued before July 2019, perhaps preceded by an NPRM (public comment period).  What we do know from an interim report (DA 19-71) released last month (see our newsletter of February 18th) is that the FCC staff is recommending a continuation of the Category 2 budgeting process, possibly with “targeted changes.”

What we believe this means for applicants with existing Category 2 budgets extending into FY 2020 or beyond— including those with first commitments in FY 2019 — is that new rules will leave them no worse off for the remainder of their existing budget cycles.  We would also hope that any improvement to the Category 2 budget rules would, at least as an option, accrue to all applicants.

Please let me know if you have questions specific to your school.

Happy Filing!

Todd Lawrence
tlawrence@sde.idaho.gov

Form 470 Deadline is TODAY!!!

Reminder: E-Rate Funding Year 2019 Form 470 Deadline!!!

****Absolute last day to file a FCC Form 470 is TODAY, February 27. 

FY 2019 Form 471 "Window" 

~ Form 471 Deadline is March 27, 2019 ~
~ Post 470’s NOW if you haven’t done so already! ~

FCC Form 471

• Closes: Wednesday, March 27, 2019, at 11:59 p.m. EDT

Please let me know if you have any questions. 

Happy Filing! 

Thank you, 

Todd

Reminder: E-Rate Funding Year 2019 Form 471 Deadlines.

FY 2019 Form 471 "Window" Now Open!

~ Form 471 Deadline is March 27, 2019 ~
~ Post 470’s NOW if you haven’t done so already! ~

FCC Form 471

• Opens: Wednesday, January 16, 2019, at 12:00 noon EST
• Closes: Wednesday, March 27, 2019, at 11:59 p.m. EDT

*****Absolute last day to file a FCC Form 470 is February 27. That is only 9 days away!!!

As a reminder regarding the FY2019 Form 471 Application Window deadline. 

The absolute final day to post a Form 470 and still have enough time to submit a Form 471 is February 27, but PLEASE DO NOT WAIT THIS LONG as it will only give you a single day to negotiate a contract, obtain board approval (if required), create the EPC Contract Record, and complete the Form 471. 

Please let me know if you have any questions. 

Happy Filing! 

Thank you, 

Todd

tlawrence@sde.idaho.gov

E-Rate Funding Year 2019 Form 471 Application Filing Window is Open!!!

FY 2019 Form 471 "Window" Now Open!

~ Form 471 Deadline is March 27, 2019 ~
~ Post 470’s NOW if you haven’t done so already! ~

The FY 2019 Form 471 Application Window officially opened yesterday. The absolute final day to post a Form 470 and still have enough time to submit a Form 471 is February 27, but PLEASE DO NOT WAIT THIS LONG as it will only give you a single day to negotiate a contract, obtain board approval (if required), create the EPC Contract Record, and complete the Form 471. For public schools, I recommend that you file all 470s at least 40 days before your February board voting meeting. For nonpublic schools, libraries and other entities that don’t require board approval, I recommend that you have all 470s filed no later than February 1. 

FCC Form 471

• Opens: Wednesday, January 16, 2019, at 12:00 noon EST
• Closes: Wednesday, March 27, 2019, at 11:59 p.m. EDT

*****Absolute last day to file a FCC Form 470 is February 27. 

Please let me know if you have any questions. 

Happy Filing! 

Thank you, 

Todd

tlawrence@sde.idaho.gov

E-Rate Funding Year 2019 Form 471 Window Dates Announced!!!

E-Rate Funding Year 2019 Application Filing Window Opens January 16, 2019

The funding window dates have been announced for the FCC Form 471. Below is an outline of the dates: 


FCC Form 471

• Opens: Wednesday, January 16, 2019, at 12:00 noon EST
• Closes: Wednesday, March 27, 2019, at 11:59 p.m. EDT

ADMIN Window

• Currently open
• Closes: January 15, 2019, at 11:59 pm EST
• You will not be able to make changes to your EPC profile after that date. So, please log in to your EPC account now to make any necessary changes to your profile. The December 7 SL News Brief includes important reminders for updating your profile.

The link to the USAC SL News Brief is below for more details: 

https://www.usac.org/sl/tools/news-briefs/preview.aspx?id=870

Please let me know if there are any questions regarding these dates, updating your EPC profile, and the competitive bidding process.

Thanks,
Todd Lawrence
tlawrence@sde.idaho.gov

FY2018 Funding Wave 28-34 Released!!!

Hello Everyone,

Congratulations to the following list of Idaho entities. This is a list of those Idaho applicants whose Funding Requests (FRN) are included in Funding Wave #28 through 34 for FY2018. Below is the list of the funding breakdown:

Total Commitment Waves (Idaho):  $1,597,343.36

To complete the Form 486, please follow the directions listed here:

Log into EPC to file the Form 486. The Form 486 is NOW available in EPC. As with FY2016 and 17, no paper FCDL forms are being mailed for FY2018.

Steps to take and items to pay close attention to on the 486:

1. Go to your landing page
2. Look for the “Form 486” listed in the upper right corner.
3. Choose only the FRNs that are ready for filing.
4. Modify the service start date(s) as appropriate. Typically, this is July 1, 2018.
5. Choose the correct CIPA certification based on your situation. Be careful here to ONLY select the one that applies...not all three.
6. Review your form carefully before you certify it.

A funding wave will be released each week until all funds are exhausted.

If you were NOT included in this wave or any previous wave, it only means your application hasn't yet been reviewed. Continue watching for an email for notification that your PIA questions are available in EPC. As soon as the questions are answered, you'll likely be in an upcoming funding wave. If there are concerns with your funding requests, send me an email and I can looking into it and see if I can get more information.

FRN	BEN	Billed Entity Name	FRN $
1899058792	142666	FREMONT COUNTY JOINT DIST 215	$101,825.98
1899058797	142666	FREMONT COUNTY JOINT DIST 215	$14,208.30
1899012964	142684	KAMIAH JOINT SCHOOL DISTRICT	$6,720.00
1899073039	222670	MOSCOW CHARTER SCHOOL	$11,375.00
1899073043	222670	MOSCOW CHARTER SCHOOL	$7,106.40
1899084606	222670	MOSCOW CHARTER SCHOOL	$465.00
1899076396	142691	OROFINO JT SCHOOL DISTRICT 171	$58,500.00
1899076585	142691	OROFINO JT SCHOOL DISTRICT 171	$3,360.00
1899077353	142691	OROFINO JT SCHOOL DISTRICT 171	$419,140.80
1899077686	142691	OROFINO JT SCHOOL DISTRICT 171	$8,640.00
1899063790	142602	PRESTON SCHOOL DISTRICT 201	$2,520.00
1899063886	142602	PRESTON SCHOOL DISTRICT 201	$16,800.00
1899061865	142781	PRIEST LAKE COMMUNITY PUB LIBRARY	$74,992.28
1899022375	142695	VALLIVUE SCHOOL DISTRICT 139	$47,520.00
1899022865	142695	VALLIVUE SCHOOL DISTRICT 139	$785,289.60
1899078682	142670	WEST JEFFERSON SCHOOL DIST 253	$31,680.00
1899078755	142670	WEST JEFFERSON SCHOOL DIST 253	$7,200.00

Please let me know if there are any questions on your funding of Form 486.

Thanks,

Todd

tlawrence@sde.idaho.gov

FCC Approves FY 2019 Eligible Services List

FCC Approves FY 2019 Eligible Services List

The FCC recently adopted the final Eligible Services List for FY 2019 in which they declined to make any major changes. They did, however, provide the following clarifications, some of which are quite helpful. Due to the mandatory span of time between the adoption of the ESL and the Form 471 window, we know that the FY 2019 Form 471 application window will not open before January 15, 2019. As soon as the exact window opening and closing dates are known, I’ll let you know. 

Category 1:

1. Clarified that Category 1 network equipment necessary to make broadband service “functional” is eligible even if leased or rented from the service provider. 
2. Clarified that Category 1 network equipment applies to all Category 1 services, not just fiber.
3. Reaffirmed that “redundant” Category 1 services are not eligible.
4. Removed voice services from the ESL due to the phase out.

Category 2:

1. Clarified that Category 2 equipment can be leased or rented from vendors, in addition to being purchased.  (In other words, leased or rented equipment does not have to be requested under the MIBS category.)
2. Revised Form 470 to include “Cabling” as an independent item in the Internal Connections category to match the 471.
3. Reaffirmed that software upgrades and patches, including bug fixes and security patches, are considered Basic Maintenance of Internal Connections and must be sought as BMIC on both the Form 470 and 471.  (Remember that bug fixes, software upgrades and security patches are 100% eligible, but next day replacement support services/contracts are NOT E-rate eligible.) 
4. Clarified that applicants may request both equipment and related licenses/operating system software on the Form 470, or request just the equipment on the Form 470, and still request funding on the Form 471 for both the equipment and related licenses/operating system software.

The entire FY 2019 Eligible Services List can be found at:  https://docs.fcc.gov/public/attachments/DA-18-1173A1.pdf.  

If you have any questions, don’t hesitate to contact me. 

-Todd Lawrence

tlawrence@sde.idaho.gov