February 2021 E-rate Update

February 17, 2021

Happy snowy February, E-raters!  Below are a few E-rate reminders and helpful hints.  If you have any questions, please don’t hesitate to reach out to me over the next five weeks!

Time Running Out to Post 470s

If you haven’t done so already, it’s time to post any last-minute Category 2 Form 470s or PEPPM mini-bids for new equipment, or Category 1 Form 470’s for services needing a new contract or MTM services (MTM must be filed annually).  The very last day that you can post a 470 is February 25, but this only leaves the final day of the Form 471 window – March 25 — to evaluate your bids, obtain local approvals, sign contracts, upload contracts and complete the 471.  Please don’t wait another minute to file your Form 470!

Helpful docs:  When filing for Internet, be sure to refer to this guide as the 470 drop downs are confusing again this year:  http://e-ratepa.org/?p=32828.  For assistance with RFP and Form 470 narrative development, use this helpful guide:  http://e-ratepa.org/?p=32871.   If you’re using the PEPPM Mini-bid procurement option for your Category 2 requests, be sure to review and follow the detailed PEPPM Guide and templates available at:  http://e-ratepa.org/?page_id=6121.

Congrats to the 211 PA Entities Who Have Submitted 471s!

I’m so pleased that 211 PA schools and libraries have already submitted their FY 2021 Form 471s, and I’m even more excited to report that 138 FRNs are already in Wave Ready Status (and another 27 are in Final or QA Review Status).  If your competitive bidding is complete and you have obtained signed contracts – or if you’re in a multi-year contract that was signed in a previous year – you should proceed with the Form 471 filing as soon as you can to be virtually assured of receiving an early funding commitment decision.  Here are links to a few guides that will come in handy over the next 5 weeks:

Category 2 FY 2021 Form 471 Will NOT Require Equipment Listed by Building

One of the true bright spots of the FY 2021 Category 2 filing season is that E-rate rules no longer require applicants to identify on the Form 471 which school/library buildings are receiving the equipment.  When the system asks, “Is every building receiving the equipment/service?” you just answer Yes.  What a time saver!  Likewise, the Internal Connections Bulk Upload Template now only requires a single tab, making it incredibly simple to create/use.  I encourage you to try it if you’ve never done so before (a helpful Bulk Upload Template Guide is available at:  http://e-ratepa.org/?p=33043.)  Even though USAC won’t track which buildings are receiving which equipment, applicants will still be required to maintain an asset inventory to track where every piece of equipment is located (by room).

Reminder to Include Up-to-Date Vendor Tax/Fees

Although it’s tempting to use the Copy FRN feature in the Category 1 Form 471 for your services that haven’t changed from last year, please make sure those amounts are accurate.  Since last year, many Category 1 service providers have increased their taxes and fees so it’s important that you check your vendor’s current invoice and use the correct amounts.  Those taxes/fees are all E-rate eligible (unless it’s an “administrative fee” or a “property tax fee”) and should be included on your E-rate application as a separate FRN Line Item (same FRN) using à Miscellaneous à Taxes/USF Fees (quantity = 1).

February 25 BEAR Filing Deadline for FY 2019
Due to the pandemic, the FCC extended the FY 2019 BEAR invoice deadline for recurring services from October 28, 2020 to February 25, 2021 – at date that is fast approaching.  How do you know if you should submit a BEAR?  The easiest way is to review the spreadsheet I sent to the listserve on 2/10/2021: http://e-ratepa.org/?p=33049.  If you are on the list and don’t yet have a BEAR PIN (they’re person specific, not organization specific), follow this guide to request a BEAR PIN.  http://e-ratepa.org/wp-content/uploads/2021/02/Form-472-BEAR-PIN-Request-Guide.pdf.   PINs typically take 7-14 days to process/receive, so if you’re requesting a BEAR PIN now, it’s important that you simultaneously request a BEAR extension and here’s a guide to walk you through that process:  http://e-ratepa.org/wp-content/uploads/2021/02/Invoice-Deadline-Extension-Request-IDER-Guide.pdf.

EBB – Emergency Broadband Benefit Program Update

The new $3.2 billion Emergency Broadband Benefit Program (EBB) will provide $50/month subsidies for Internet access services to the homes of low-income families (and a small subsidy for a laptop/tablet) during the pandemic.  In short, a household that would like the EBB subsidy will contact a participating provider that will then verify the household’s income eligibility to participate and install/turn on service.  The provider will then seek reimbursement from USAC.  Schools and libraries will play a huge role in getting out the word to eligible families and encouraging their local service providers to become participating providers.  USAC will be administering the EBB program on behalf of the FCC.  To sign up for their EBB updates, go to:  https://survey.alchemer.com/s3/6194379/Emergency-Broadband-Benefit-Program.  USAC also is conducting 2 trainings for service providers over the next few weeks (2/23 and 3/2) and you may wish to forward the training webinar info to your local providers - https://www.usac.org/about/emergency-broadband-benefit-program/.

FCC Corrects Invoicing Deadline for Late RFCDLs

The FCC recently issued an Order giving applicants and service providers up to 120 days to submit invoices after the receipt of a Revised Funding Commitment Decision Letter (RFCDL) or the successful appeal of a previously denied or reduced funding request.  This is welcome news for applicants that previously found themselves not being able to obtain E-rate reimbursement because of a nuance in an existing FCC rule.  The new invoice deadlines are as follows:  Invoices (BEARs or SPIs) must be submitted to USAC…

1) 120 days after the last day to receive service (which is typically Oct 28 for recurring services and Jan 28 for one-time purchases), or

2) 120 days after the date of the FCC Form 486 Notification Letter, or

3) 120 days after the date of the Revised Funding Commitment Decision Letter approving a post-commitment request made by the applicant or service provider or a successful appeal of a previously denied or reduced funding request.

…whichever is latest.

If you have any questions, please contact me at jtschell@comcast.net!

– Julie

Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o

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