07/10/2015 - Survey Results and EPC
Hi everyone. Below you will find information on our recent survey and a new online tool being made available by USAC.
Thank-you to those that took a few minutes to respond to the survey. ADS will continue to keep the applicants perspective in front of the FCC, so please respond to future surveys.
As promised, ADS has taken the survey results and filed them with the FCC. Please note our reply comment at: http://apps.fcc.gov/ecfs/comment/confirm?confirmation=201576389419
Survey results can be found at: http://adsadsi.com/results.pdf
If you would like to see more details on the survey results, please contact me at firstname.lastname@example.org.
E-Rate Prodcutivity Center ("EPC")
EPC is the account and application management portal for the Schools and Libraries (E-rate) Program. This system will eventually be the point of entry for all applicant, service provider, or consultant transactions. EPC will be where program participants complete and certify forms, obtain the status of their applications, submit requests, receive timely reminders and notifications, respond to PIA review questions, and ask program-related questions.
What You May Need To Do:
If you are the Authorized Person listed on an FY2015 FCC Form 471 follow the instructions in USAC's Account Creation email (sent to you from email@example.com). After you log in to the account as the account administrator, you can then designate another employee at your organization to be the account administrator if you wish to do so.
If you are the Contact Person listed on an FY2015 FCC Form 471 ask the authorized person to set up your account. The authorized person must follow the instructions in USAC's Account Creation email. After the authorized person logs in to the account as the account administrator, he or she can then set you up as a user.
It is important to note that EPC must be used by all applicants seeking to file Form 470s for FY 2016. We are working to setup ADS client access and will reach out to the primary of point contact concerning access to EPC. If you are not an ADS client, please don’t hesitate to contact me with questions on EPC, or anything E-Rate. I am happy to assist.
06/25/2015 - ADS EBinder || www.mye-binder.com
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05/22/2015 - FCC Issues Public Notice on Draft ESL for FY2016
The FCC released Public Notice (DA 15-615) establishing the comment period for the Funding Year (FY) 2016 Eligible Services List (ESL). Comments on the draft ESL, which is attached to the Public Notice, are due to the FCC on or before June 22, 2015. Reply comments are due to the FCC on or before July 6, 2015. For information on filing comments with the FCC, please refer to the Public Notice at http://transition.fcc.gov/Daily_Releases/Daily_Business/2015/db0521/DA-15-615A1.pdf.
05/12/2015 - E-rate Program Applicant Trainings
Join USAC at an all-day Applicant Training for schools, libraries, and consortia that apply to the Schools and Libraries (E-rate) Program. Training will be at Washington, DC on Friday, October 2, 2015; Albuquerque, NM on Tuesday, October 13, 2015; New Orleans, LA on Thursday, October 29, 2015; Philadelphia, PA on Tuesday, November 10, 2015 ; Tampa, FL on Thursday, October 8, 2015; Minneapolis, MN on Tuesday, October 20, 2015; Los Angeles, CA on Thursday, November 5, 2015 and Portland, OR on Monday, November 16, 2015. More information is available in the Trainings & Outreach section of the Schools and Libraries Program website.
03/12/2015 - FY2015 Application Filing Window Deadline Extended
The new close date for the FY2015 filing window is April 16, 2015, at 11:59:59 PM EDT. In response to a reasonable request from the nation's largest school districts, USAC, in consultation with the FCC, has extended the FY2015 application filing window for three additional weeks. The application filing window will now close on April 16, 2015, instead of the original date of March 26, 2015. FCC Form 471 applications must be submitted on or before 11:59:59 PM EDT on Thursday, April 16, 2015, to be considered in-window.
02/06/2015 - Planning 471s, FRNs and Items 21s
As you may have realized or have heard, the Item 21s are now imbedded within the 471 and it is more complicated to complete the filing of the 471. Perhaps complicated is the wrong term. Perhaps it’s more accurate to say that it just takes longer to complete an accurate filing of the 471. If filing your own 471s, please start early and have a plan on how to enter information into USAC’s site. Recently, I contemplated some filing strategies and opened a few tickets (reference 22-716950 & 22-716721) with the Client Services Bureau. The goal is to make for quick and easy processing as well as simplifying the management and reporting of FRN details. You know, to file with best practices. Unfortunately there are still some unknowns. Below are a few questions and answers worth thinking about:
Q - If equipment is purchased, placed at a school, connected to the Internet and is then used by the rest of the schools in the district via their WAN (like a firewall connected to the WAN and Internet Access), which school budgets take the financial hit from a Category 2 perspective? Do all of them take a hit consistent with their use or population, or does the one that houses the equipment take the whole liability from a USAC budget perspective?
A - Per USAC, the cost should be distributed accordingly.
Q - Should applicants file separate FRNs for shared equipment, or for equipment dedicated to a specific site?
A - Per USAC, not necessarily, a large project can be placed all on one FRN via separate line items. Each line item will have the associated locations identified.
Q - How is budget information tracked and reported to the Applicant if the FRNs are not site specific?
A - Per USAC, financial information will be reported on commitment letters and on invoicing documentation. Quarterly Disbursement Reports may or may not reflect budget information. Samples are not available.
Q - Are there any program rules that state that one entity cannot utilize equipment housed at another location?
A - Per USAC, No rules exist prohibiting the use of equipment located at one location by another site, so long as it is district owned equipment being used by an entity within district.
Q - When do the budgets take the financial hit? When funding commitments are awarded or disbursements are made to the applicant?
A - Per USAC, School Budgets are rolling and may go up or down from year to year, as populations change. So if the actual spend is less than the original request the actual spend will be used in calculating budget information.
Please make sure to plan out your FRNs and the associated Item 21s.
As always, if you have any questions, please ask as we are here to help.
01/27/2015 - E-rate Modernization means file early
I want to take a minute and talk about the 471. As you have probably come to realize, E-rate modernization rules contain a few simplifications, and that the new rules create some uncertainties for interpretation and implementation. But thats OK, we just need to plan. Unless you have a pressing need for Category Two products and services, it may be best to wait. Most recently, the FCC stated…
Raising the annual E-rate cap to $3.9 billion allows us to provide certainty to the applicant community, allowing local decision-makers to proceed at the pace that best serves their students and patrons. In doing so, we do not expect that program demand will immediately reach that funding level. Indeed, there is no way to perfectly predict what precisely individual schools and libraries will seek support for or when unserved schools will gather the resources to pay the non-discounted portion of special construction charges. For instance, we have already identified sufficient unspent funds to be confident in funding for category two services in funding years 2015 and 2016.
I believe the point of the statement above is to follow your plan. The budget dollars available for Category Two are limited and need to spent wisely. In addition, it is important to forecast your reimbursement for the coming years.
Now that the 471 filing window is open, it is time to get to work. I want to emphasize this. Do not delay. If you are a full service client we will be working closely over the next couple months, if not, start filing your 471 as soon as you can. It’s going to take more time and data to complete. Especially from an item 21 perspective.
If you plan to file your own 471, it is a good idea to familiarize yourself with the tools and process. Start a FCC Form 471. Note, if you do not have a Form 470 that has passed the 28 day waiting period you will be able to get as far as Block 4. You can also use the FCC Form 471 Templates (note the instructions). Please remember this is a new system, meaning, practice the “how” you intend to use the tool in order to make sure the functionality you expect, works as expected. As always, document everything you do. Trust me, it’ll come in handy later when trying to remember what you did or how you did it. Funding Year 2015 e-binders will be available the 2nd of February.
Please feel free to contact me with any questions.
12/12/2014 - Next Steps for Modernization of E-rate
Next Steps for Modernization of E-rate
The Federal Communications Commission announced further modernization of the E-rate program - steps to ensure that the nation’s schools and libraries have access to robust high-speed broadband connections. Please read the press release made by FCC. The notice announces an additional 1.5 billion in funding (3.9 billion cap), and much more, like the following, taken right from the notice:
• Suspending the requirement that applicants seek funding for large up front construction costs over several years, and allowing applicants to pay their share of one-time, up-front construction costs over multiple years.
• Equalizing the treatment of schools and libraries seeking support for dark fiber with those seeking support for lit fiber.
• Allowing schools and libraries to build high-speed broadband facilities themselves when that is the most cost-effective option, subject to a number of safeguards.
• Providing an incentive for state support of last-mile broadband facilities through a match from E-rate of up to 10% of the cost of construction, with special consideration for Tribal schools.
• Requiring carriers that receive subsidies from the universal service program for rural areas – called the High Cost program – to offer high-speed broadband to schools and libraries located in geographic areas receiving those subsidies at rates reasonably comparable to similar services in urban areas.
• Increasing the certainty and predictability of funding for Wi-Fi by expanding the five-year budget approach to providing more equitable support for internal connections – known as category two – through funding year 2019
If you have any questions, please ask.
11/07/2014 - St Louis E-Rate Training Notes
Hi all. This is not a standard newsletter – just a bullet item list consisting of the notes that I made will at the USAC Training class in St. Louis earlier this week.
• Know the Rules, Read the Order, There are many Changes and More to Do
• You will have a Problem if you don’t Start the application process Early.
o September 1, 2015 – target date for FY2015 decisions Target FY2015 window dates – early to mid January to early to mid-March 2015
o Anticipate more PIA outreach, USAC will add staff to help speed the review process
o The highest Category Two discount rate is now 85% instead of 90%.
o The two-in-five rule is not in effect for FY 2015 and FY 2016.
• School budgets are $150 per student PRE-DISCOUNT based on the count of full time and part time students at that school with a floor of $9,200.
• Library budgets are $2.30 PRE-DISCOUNT timesthe square footage of the library (inside the four walls) with a floor of $9,200.
• Non-instructional facilities (NIFs) – including school NIFs with classrooms and administrative buildings – do not have Category Two budgets.
• The discount rate for all voice services will be reduced by 20 percentage points beginning in FY 2015, and reduced by an additional 20 percentage points each subsequent funding year.
• No more separate Item 21 attachments – now embedded in the FCC Form 471 and FRN line items must list all requested products and services.
• Consortia applications will be given priority during the review process.
• Contracts executed after the effective date of the Order may not contain any restriction barring publication of pricing data.
• Offers must have Lowest Corresponding Price
• Starting in FY 2015, all applicants must file their FCC Form 471 online.
• Discounts are calculated for the organization as a whole. Discount rates do not change based on which entities within a district/system are receiving service.
• Community Eligibility Program, all students eat free, but this does not mean they are counted as eligible for E-rate purposes. Applicant must still determine eligibility percentage.
• Beginning in FY 2016, applicants that pay the full cost of the E-rate supported services to a service provider will be able to receive direct reimbursement from USAC.
• 10 year documentation retention - Any document from a prior year that supports current year must be kept until 10 years from last date to receive service as well. Electronic storage is OK.
• Lots of questions are not answered concerning years 3, 4 and 5 of the FCC plan for Category 2. We hope for immediate clarification on everything from funding considerations to multi-year Managed Service Contracts. Another question that is unknown is what happens if an applicant opts out of the first 2 years of pilot program. Will there be any advantages or disadvantages…
• FCC Form 470 has minimal changes for FY2015
• Program compliance presentation skipped due to so many questions
• FCC directed USAC to “post a tool on its website that will allow schools and libraries to obtain information regarding whether they are classified as urban or rural.”
• I’ll send another message on the Eligible Services List.
Note: Now that the Eligible Services List has been finalized and we have completed USAC training it is time to start filing the 470s/RFPs. The 470 interview process has been updated – it’s all online and super slick! This will greatly automate and simplify the entire E-rate process as the 470 information ultimately drives the funding requests. We’ll be in touch shortly.
09/12/2014 - E-Rate, The Elimination and Phasing Out of Services
Over the next few weeks ADS will continue to send information on the modernization of the E-rate program. As you are reading this information please bear in mind that the following three goals have identified and are the main drivers of the modernization effort:
1. Ensuring affordable access to high-speed broadband sufficient to support digital learning in schools and robust connectivity for all libraries.
2. Maximizing the cost-effectiveness of spending for E-rate supported purchases.
3. Making the E-rate application process and other E-rate processes fast, simple, and efficient.
No Longer Supported by E-Rate – effective 7/1/2015
The modernization of the E-rate program focuses on broadband connectivity both to and within schools and libraries and appears to be funded by rollover dollars and a phase out of support for various services. Starting in the 2015-2016 school year, E-rate support will be completely eliminated for the following services:
• Web hosting
• Voice mail
• Directory assistance
• Text messaging
• Custom calling features
• Direct inward dialing (“DID”)
• 900/976 call blocking
• Inside wire maintenance plans
Telephone Service Support to be Phased Out
Over time, E-rate reimbursements for voice telephone services will be phased out. Voice telephone services are defined to include:
• Local and long distance phone service
• 800 service
• Satellite telephone
• Wireless telephone service
• VoIP telephone service
• Circuits dedicated to providing voice service
• Support for individual cellular data plans will continue to be eligible, but only under narrowly defined conditions in which an applicant can show that a cellular data solution provides a more cost-effective solution for intra-building Wi-Fi coverage than a “robust wireless network.”
The phase-out of voice services will be accomplished by reducing an applicant’s discount rate for those services by 20 percentage points per year. For instance, an applicant with a 90% discount rate will receive a 70% discount on voice services in 2015-16, 50% in 2016-17, 30% in 2017-18, 10% in FY 2018-19, and nothing in FY 2019. A 40% applicant will receive a 20% discount on voice services in FY 2015, and nothing in FY 2016 and beyond.
Applicants must start planning to budget accordingly for services that will not be supported in the future. There is always a chance that program rules will change, but it is obviously prudent to plan accordingly. As usual, ADS will provide clients budget reports and information as the E-rate application process unfolds.
From an applicant’s perspective, the implementation of these changes will require a thorough review of invoices to cost allocate various charges. A typical wireline telephone bill, for example, may include: ineligible components, eligible data circuits and partially eligible voice telephone services (multiple FRNs may be required). Similarly, a cellular or mobile communications invoices is likely to include ineligible charges; voice service, and data services that may be eligible for reimbursement. Invoices will require increased scrutiny to identify legitimate charges eligible for reimbursement.
Next Issue to be Covered Understanding and navigating Category 2.
08/25/2014 - E-rate, Immediate Changes
E-Rate is changing
Lots of information has been published recently. Some of which is true, some of which is not. Are you confused? Do you have questions about current or future E-rate activities? If so, let us be your consultant. Our initial phone consultation is always free. Bring your questions, we’ll guide you to answers. Please submit a request for more information and we’ll call you to schedule your free consultation.
Today we’ll focus on immediate changes to the program.
Once the Report and Order becomes effective, all appeals must be filed with USAC first. Currently, an appeal may be directed to the FCC or USAC. If an unfavorable decision is made by USAC, an appeal to the FCC is still permitted. Remember USAC cannot waive FCC rules and regulations. This can be confusing, so if you have any questions, please ask.
Moving forward, USAC will grant one 120 day extension of the invoicing deadline. In general, this means that February 25th will be the extended deadline (the normal invoice deadline is October 28th). The FCC has directed USAC to deny any requests for review seeking an invoice extension more than twelve months after the last date to invoice. This appears to indicate that an additional 120-day extension may not be granted for 2012-13 invoice extension requests. For 2013-14, the extended deadline for invoicing is February 25, 2015 for reoccurring telephone and Internet type services.
Stay tuned for our next message on the 2 definite changes for the 2014-15 funding year, or if you prefer, sign-up for our E-rate Newsletter. This is the same Newsletter that we make available to our clients and is packed with comprehensive E-rate information!
Who We Are
ADS Advanced Data Services is an E-rate Consulting firm that specializes in providing audit ready and program complaint services. All ADS employees are technology savvy and familiar with School Administration and subject matter E-Rate experts. Recently we have hired Chris Igel as our Chief Technology Officer. His responsibilities include helping E-rate Applicants leverage E-rate dollars with respect to Technology Planning, Broadband Initiatives, and Blended Learning. Chris has worked with E-rate for more than 17 years (from a Vendor, School administrator and consultant perspective) - we are excited to have him on our team and learn from his expertise.
If you prefer you may contact Chris directly at 888.465.8820 x712 or email him at firstname.lastname@example.org.
08/12/2014 - FCC Public Notice - Erate Modernization
The Wireline Competition Bureau seeks comment on a draft eligible services list (ESL) for the schools and libraries universal support mechanism (also known as the E-rate program) for funding year 2015. In the E-rate Modernization Order, among other things, the Commission restructures the ESL into category one and category two services, streamlines the list of eligible internal connections components to focus support on those services and components needed for broadband connectivity within schools and libraries, and eliminates other services and components beginning in funding year 2015.
08/04/2014 - FCC Public Notice - Draft of Eligibile Service List
With this Public Notice, the Wireline Competition Bureau releases two items designed to provide a concise view of a portion of the large amount of data in the E-rate Modernization proceeding. This is consistent with the Commission’s efforts in this proceeding to provide open, user friendly data to all parties.
07/23/2014 - Modernizing the Erate Program for S&L
In this Report and Order the FCC takes major steps to modernize the E-rate program (more formally known as the schools and libraries universal service support mechanism). In so doing, the FCC recognize E-rate’s extraordinary success as the federal government’s largest education technology program. Over the last 17 years, the E-rate program has helped to ensure that our nation’s schools and libraries are connected to the digital world.
04/22/2014 - Program Demand
The Universal Service Administrative Company (USAC) estimate of demand for the Schools and Libraries Universal Service Support Mechanism discounts for Funding Year (FY) 2014 (July 1, 2014 to June 30, 2015) is $4.825 billion. This estimate is based on total funds requested in 45,731 FCC Form 471 applications received or postmarked on or before March 26, 2014. Details can be found at (http://apps.fcc.gov/ecfs/document/view?id=7521098604)
It is still too early to know if there will be priority 2 funding awards. I remain hopefully optimistic, but we should prepare in case a second year is not funded.
04/17/2014 - FCC Workshop
The FCC is holding an E-rate Modernization Workshop on May 6, 2014, to discuss the challenge of delivering high-speed connectivity to and within schools and libraries. The free workshop will be held at the FCC and is open to the public. It is also provided as a live streamed event at http://www.fcc.gov/live.
03/11/2014 - E-rate Notice of Public Rulemaking
The FCCs Public Notice on E-rate modernization (DA 14-308) was released for public comment last Thursday. Comments are due April 7th and reply comments are due April 21st.
Please note: http://www.ofr.gov/%28S%28nkjul5wr0bawnbhr5pvynqy1%29%29/OFRUpload/OFRData/2014-05433_PI.pdf
Per DA 14-308: In light of the themes that emerge from the record, as the Commission seeks to modernize the E-rate program, there are three issues raised in the E-rate Modernization NPRM that merit further focused inquiry at this time:
- How best to focus E-rate funds on high-capacity broadband, especially high-speed Wi-Fi and internal connections;
- Whether and how the Commission should begin to phase down or phase out support for traditional voice services in order to focus more funding on broadband; and
- Whether there are demonstration projects or experiments that the Commission should authorize as part of the E-rate program that would help the Commission test new, innovative ways to maximize cost-effective purchasing in the E-rate program.
If you have any comments that you would like to share, or have me reference please let me know, especially if they apply to relevant statutory requirements.
The FCC is aiming to issue an order on E-rate modernization before the start of the next school year with new rules to become effective as of FY 2015. It is really hard to determine what will happen. There are many different opinions (http://transition.fcc.gov/Daily_Releases/Daily_Business/2014/db0307/DOC-325937A1.pdf). If you have a thought, now is the time to speak up as the program could change significantly.
One other thing to mention is that it looks like the FCC has a plan to free up 2 billion in USF funds on a one time basis and it appears these funds will be used to support broadband deployment.
02/03/2014 - NY Times: Double Spending
An interesting article: http://www.nytimes.com/2014/02/02/us/fcc-says-it-will-double-spending-on-high-speed-internet-in-schools-and-libraries.html?emc=eta1&_r=0
Hoping for some good news on the 5th of February. On Wednesday, FCC Chairman Wheeler is scheduled to make an E-rate presentation at Digital Learning Day. There is reason to believe that the Chairmans remarks will provide some details to the recent hints of additional and/or redirected E-rate funding.
01/30/2014 - More E-rate Funding?
Last week in an article by FCC Chairman Wheeler the FCCs commitment to President Obamas ConnectEd initiative was reinforced. Note the following statement from the article titled: Helping Students Compete in a Digital World:
As part of our top to bottom review of E-Rate, the opportunity has opened to use existing funds to immediately begin to expand E-Rate funding targeted to high-speed connectivity to students in schools and libraries. These additionally available funds will begin to be put to work this year for schools and libraries. This will be done without affecting the programs existing structures and the 2014 program application process that is now underway.
A I have maintained, it is really hard to predict how and when funding changes will be made available. It is still not clear if a new source of E-rate funding has been identified or additional roll-over funding has been identified for release. I hope to learn more next week, and will keep you informed.
11/21/2013 - Application Window Announced
First off, the FY2014 Application Filing Window Dates Announced The FCC Form 471 application filing window for Funding Year 2014 will open at noon EST on Thursday, January 9, 2014 and will close at 11:59 pm EDT on Wednesday, March 26, 2014. The filing window will be open for 77 days. We hope to have all 470s filed before Christmas. Ideally, we will have all 471 filed by the 1st of March.
Please note that a revamped Form 471 is to be used for FY 2014 which includes a new a request for information involving broadband or other connectivity services. I expect this information to be fairly straight forward in capturing and will provide details after the Thanksgiving holiday.