Happy Back-To-School, E-raters!
September 7, 2016
I hope everyone had a wonderful summer! Below is an update on several E-rate current topics and a reminder of where we are in the E-rate filing process for FY 2015, FY 2016 and FY 2017. It’s a little long, but worth it…
FUNDING YEAR 2015…
FY 2015 ended on June 30, 2016 and thus it is time to submit the BEAR form if you did not receive discounted bills. The deadline to submit the BEAR is October 28, 2016. This year is a bit different than previous years, and a bit the same. Please read this section carefully if you need to submit a BEAR.
Form 498: If you will be filing a BEAR Reimbursement Form (Form 472), you first must have a Form 498 submitted and approved by USAC. Why? Beginning immediately, no paper reimbursement checks will be mailed; all payments will be electronically transferred from USAC to the applicant’s bank account. In order for USAC to know where to transfer the funds, all BEAR-users must complete the Form 498 in order to provide USAC with their bank account and bank routing information. The 498 must be submitted in EPC by a “school or library official.” About 2-3 days after submission, they will receive an e-mail asking them to upload a voided check or bank statement. Within a week after that, they will receive an e-mail stating the 498 has been approved. After they receive the 498 approval, THEN you can file the Form 472 BEAR. For more information on filing the 498, see: http://e-ratepa.org/?p=13701.
Form 472 BEAR: BEAR Reimbursement Forms will NOT be filed in the new EPC Portal. Instead, you must use the legacy system/method of applying at: https://www2.sl.universalservice.org/bear/login.aspx. To get into the old system, you must use your old E-rate PIN — not your EPC credentials (if you don’t have an old E-rate PIN or can’t find it, call the Client Service Bureau at 888-203-8100 and they can either help you regenerate your PIN, or assist you in obtaining a new BEAR PIN). All BEARs must be filed online – no paper BEARs will be accepted. Because vendors no longer certify BEARs, your BEAR will be submitted directly to USAC for processing. And because reimbursement payments will be directly deposited to the bank account that was listed on the Form 498, most applicants are receiving their reimbursement payments within 5 days of the BEAR submission! This is amazing considering it used to take 45+ days to get reimbursed. For more information on filing the BEAR, see: http://e-ratepa.org/?p=13851.
Unused FY 2015 Category 2 Funding? If you were approved for Category 2 (internal connections) funding in FY 2015 and you did not spend (or will not be spending) the full committed amount, be sure to submit a Form 500 and return the remaining funds to USAC. Why is this important? Your Category 2 budget is considered “depleted” when your funding commitment letter is issued, not when you invoice USAC. So if you are funded for C2 and never use the money, your C2 budget will be reduced. In order to have the benefit of using that “unused” C2 budget funding in future years, it’s important that you submit a Form 500 to “decommit” the unused funding. If you do this, be sure to explain exactly which school or library building the funding should be restored to.
FUNDING YEAR 2016…
Where Is My FY 2016 FCDL? This is a very popular question these days. Although 60% of Pennsylvania’s 471s have been funded, only 22% of the requested dollars have been funded ($18M/$82M). The intention of USAC’s new EPC portal was to streamline application submissions, PIA reviews and funding commitments but unfortunately the system hasn’t turned out quite the way they planned. I know USAC are working hard to review applications as quickly as possible and would like to have most funded by the end of October. There is no pattern to which applications get reviewed first, except that the smaller applications seemed to get approved more quickly this year, so please don’t think that your aren’t being funded just because you haven’t heard anything yet. When you do receive an e-mail with your PIA inquiry, please log into EPC, and then click on the link in the e-mail to respond promptly to the inquiry (see helpful PIA Review Guide at http://e-ratepa.org/?p=13451). If you’re unsure of how to answer a PIA question, please don’t hesitate to e-mail me.
Purchasing Equipment Prior to Receiving E-rate Funding: Because FCDLs have been delayed this year, many applicants have asked if they can purchase the equipment and pay in full, and then submit a BEAR to seek reimbursement after the E-rate funding is committed. Yes! You can absolutely do this. There is some risk that you won’t be funded, obviously, but if you followed all of the rules and met the timelines, the risk should be very minimal.
Requesting Discounted Bills – FY 2016: If you would like to receive discounted bills for FY 2016, be sure to request these of your vendors as soon as possible. For more information on requesting discounted bills, see: http://e-ratepa.org/?p=14131.
Generating FCDLs: Don’t forget! After you receive the e-mail stating that you’ve been funded, you must log into EPC and “generate” your FCDL (see: http://e-ratepa.org/?p=13411) — paper FCDLs are no longer mailed. You must generate your FCDL before you can file your Form 486.
FY 2016 Form 486s – If you HAVE been funded for FY 2016, please don’t forget to file your Form 486 to ‘turn-on’ funding with USAC. I will send a list of applicants with 486 due dates in early October. If you have NOT yet been funded for FY 2016, you can’t file the Form 486 until you receive your FCDL. The new Form 486 is extremely simple! See: http://e-ratepa.org/?p=13591.
Category 2 Equipment Labeling/Tracking Reminder - After your C2 equipment arrives, it’s extremely important that you label your equipment with “FY 2016, FRN # XXX” because future E-rate audits will require such documentation to be provided/shown. In addition, you must record each piece of equipment in your school’s Asset (Inventory) Register or create your own E-rate Asset Register (recommended). The Asset Register should contain the following information: Make & model, serial number (if available), physical location of equipment (building and room number), date installed, Funding Year 2016 and FRN #, and Purchase Order #. Attached to this message is the USAC Sample Asset Inventory Worksheet in an Excel file. You can see that it shows more than is required, but I think it’s very helpful to maintain such a detailed record of the payments and POs so that you can easily show this to the auditors. See: http://e-ratepa.org/?p=13311
FUNDING YEAR 2017…
Form 470 / Form 471: The Form 470 for FY 2017 is now available in EPC and can be filed at any time. The form has not changed from last year. The FY 2017 Form 471 filing window dates haven’t yet been established but I do NOT expect that the deadline will be in May again this year. My guess is that they will try to return to a March 471 deadline. Also, I know they are working to avoid having a separate window again for consortia and libraries.
Fall Trainings: The E-rate for Beginners Trainings will be announced in the next week and will again be held in three locations at the end of October and early November. There also will be separate webinars scheduled on specific topics as well as one for E-rate veterans.
Submit the Online PEPPM LOA by Sept. 23: If you haven’t yet done so, please submit the PEPPM Letter of Agency at https://www.peppm.org/ErateLOA. E-rate now requires that consortia leads obtain a signed LOA (Letter of Agency) from their participating members before the Form 470 is posted. PEPPM will be issuing a supplemental bid at the end of September to add a few additional E-rate eligible product lines to the current large manufacturer list and therefore the new LOA requirement will kick in so we must obtain the signed LOA prior to issuing the Form 470. By signing this LOA, you are not obligating yourself whatsoever to purchase from the PEPPM contract. You are merely stating that the PEPPM administrators have the authorization to issue the Form 470 on your behalf. However, if you do not sign the PEPPM LOA, you will NOT be able to use the PEPPM contract for E-rate eligible purchases. The online LOA is very simple to complete and should take about 20 seconds. You do not need to print, sign and mail the LOA — the online submission is sufficient. https://www.peppm.org/ErateLOA
If you have any questions about any of these issues, please don’t hesitate to contact me at firstname.lastname@example.org.
Julie Tritt Schell
PA E-rate Coordinator