FCC Form 471 Window Deadline Reminder and PIA Update

Hello Everyone, 

I hope this message finds everyone safe and healthy while trying to keep up with the demands and challenges with education in Idaho. I know we are faced with many demands and E-rate filing may not be at the top of the priority list. Please let me know if I can assist in any way possible. 

Form 471 Filing Deadline:  April 29, 2020 at 11:59 pm EST 

The FCC has not changed the 471 Deadline and will not likely. My hope is that there may be additional relief or flexibility with the two-week Out Of Window filing timeframe for those who miss the initial 471 deadline. I have included the instructions below if needed. 

471 Guide: FCC Form 471 Instructional Guide

PIA Inquiries:

There have been a larger number of PIA requests this year and there have been several questions that are difficult to answer due to the pandemic. I am working with USAC to bring these to their attention as they occur. Please let me know if there is a question that cannot be answered today or may be an unreasonable request.  

Many of you who filed your 471 applications are already in PIA review. Although the FCC granted additional time for applicants to respond to USAC PIA inquiries, the EPC system is hard-coded to automatically send out reminder notices based on the normal program deadlines. In other words, ignore the deadlines stated in EPC and in the reminder notices you receive. Rest assured that USAC is not going to deny any of these forms or requests due to non-response or incomplete responses. They will instead continue their attempts to contact you, and when you are able to respond, they will continue their review.

Please let me know if there is anything I can assist with on your applications or PIA review inquiries. 

Stay Healthy! 

Todd 

FCC Extends Procedural Deadlines

Yesterday, April 1, 2020, the FCC provided additional relief to applicants and service providers by extending several upcoming procedural E-rate deadlines due to the pandemic. However, they did NOT extend the April 29, 2020 deadline to file the Form 471. Please let me know if I can assist you with getting everything filed before the deadline.    

Summary of Relief granted:

• PIA Inquiries:  In addition to the 14-day extension the FCC previously granted, applicants will have an additional 30-days to respond to PIA requests. (I don’t believe the EPC system will update the due-dates due to system limitations). Also, please keep in mind that the sooner you respond to these requests, the sooner you’ll receive your funding commitment decision letter (FCDL). 

• Equipment Installation:  Deadline to purchase/install all FY2019 non-recurring services (equipment) is extended from September 30, 2020 to September 30, 2021. By extension, this will automatically make the invoice deadline for all FY2019 non-recurring FRNs January 28, 2022.

• Special Construction: Deadline to complete special construction of FY2019 Category 1 fiber networks is extended from June 30, 2020 to June 30, 2021. In addition, any FY2018 applicants that had already requested/received a one-year extension also will be granted the additional year to complete the special construction.  

• Appeals/Waivers: Deadline to submit appeals to USAC or the FCC is extended from 60 days to 120 days for all USAC decisions dated January 11, 2020 – August 1, 2020. 

• Reimbursement Forms to USAC:  Deadline is extended an additional 120 days for any Form 472 BEAR Reimbursement Form (or vendor SPI) with a current deadline that falls between March 11, 2020 - October 28, 2020. This applies even if you already received an invoice extension for the FRN in question.

• Form 486:  Deadline is extended an additional 120 days for FY2019 Form 486s that would have been due between March 11, 2020 - September 30, 2020.

• Information Requests for Audits, Form 500’s, Appeals, and Invoices:  Applicants will have an additional 30 days to respond to USAC information requests for BCAP Audits, PQA Audits, Form 500s, Appeals and Invoice Reviews. 

In addition, I think the biggest news stemming from yesterday’s Order is actually in the press release, which provided this quote from FCC Chairman Ajit Pai:

“In light of extended school and library closures, we’re granting an across-the-board, one-year extension of the E-Rate special construction deadline for funding year 2019,” said Chairman Ajit Pai. “By providing this proactive relief, we want to ease burdens on schools and libraries to allow them to focus their time and resources on transitioning their students, patrons, teachers, and staff to remote learning during this crisis. This is yet another step the FCC is taking to offer help to students and teachers in need—and I look forward to continue working with Congress to fund a Remote Learning Initiative so that every child can continue being educated during the pandemic.”

Please let me know if you have any questions or how I can help.

Stay safe and health.

Todd