Wednesday, April 3, 2019

How to Navigate the Form 471 PIA Review Process

Hello Everyone, 


The Program Integrity Assurance (PIA) process is a detailed USAC review of each Form 471 to determine whether the products and services requested are eligible for E-rate funding, whether your requested discount rate is valid, whether you have stayed within your Category 2 budget, and whether you are an eligible entity. This year we also are seeing a major emphasis on substantiation of requested dollar amounts, including taxes. All PIA inquiries are done in EPC, and all applicant responses to these inquiries must be submitted via EPC.   

The PIA review process will be identical to last year, which is that the Form 471 contact will receive an e-mail indicating that a PIA reviewer has questions related to the application. The e-mail will contain a link to the actual PIA inquiry(s) in EPC (you must be logged-in to EPC to see it). To see the questions, click on "Respond to Inquiries" at the top right corner of the page, which will then turn the Inquiry Name into an active blue hyperlink. Click on the hyperlink and the list of questions will appear. You must respond to all of the questions in an inquiry at the same time. If a question is not applicable, but the text box will not allow you to proceed without an answer, simply list N/A.

If you are unclear about the questions being asked, you may e-mail the PIA reviewer to request clarifications.  Use the e-mail address that was listed on the original PIA reviewer’s message.

Deadline to Reply:  
These are serious inquires that must be addressed in a timely fashion. PIA inquiries typically provide 15-day deadlines for responses but I encourage you to respond as soon as you receive the e-mail. The sooner you respond, the sooner you'll receive your E-rate FCDL. If you haven’t responded to the PIA inquiry within 7 days of the initial request, PIA will send you a reminder. If you haven’t responded after 15 days, USAC may act on the information they already have to make a funding decision (which typically means denial).

Need an Extension? 
You can request a 7-day extension of the original deadline if you need more time. To do so, access your PIA Inquiry in EPC, choose Related Actions, then Request Extension. The first extension request will be automatically granted. If you still need more time, you may request an additional extension if absolutely needed. 

A easy diagram is attach below showing the overall process and where we are currently. 

I can assist with student validation or any questions on how to proceed. If you have any questions about your PIA inquiries, please don't hesitate to contact me at tlawrence@sde.idaho.gov  

Thanks, 
Todd 


Monday, March 25, 2019

FCC Form 471 Deadline is March 27, 2019

A friendly reminder that the FCC Form 471 filing deadline is this Wednesday, March 27, 2019 at 9:59 p.m. MST and 8:59 p.m. PST. 


FCC Form 471
  • Closes: Wednesday, March 27, 2019, at 11:59 p.m. EDT
  • ***This is 9:59 p.m. MST and 8:59 p.m. PST***

If there is any assistance I can provide on your 471 filing please call or email me. 

Happy Filing! 

Thanks, 

Todd Lawrence 
208-332-6959


Monday, March 18, 2019

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


Wednesday, February 27, 2019

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

Tuesday, February 19, 2019

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


Thursday, January 17, 2019

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

Monday, January 7, 2019

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