Have You Filed Your FY 2014 BEARs?
October 12, 2015
* PA has 1534 FRNs – worth $19,891,290.49 – that need BEARs submitted
* Attached spreadsheet shows all affected entities and FRNs
* Strict new invoicing deadlines
* Sample Invoice Deadline Extension Request is attached – due by Invoice Deadline
* Guide to filing Online BEARs is attached
The deadline to submit FY 2014 Form 472 BEARs for recurring services is October 28, 2015. This means that both the applicant and service provider must certify the BEAR before this date (you can’t just hit submit online by this deadline — your vendor also must certify the online BEAR on their end). Under the new FCC rules, if you cannot make the October 28 deadline, you MUST request an invoice deadline with USAC on or before October 28. USAC will then grant a single, 120-day extension. USAC IS NO LONGER PERMITTED TO APPROVE EXTENSIONS REQUESTS SUBMITTED AFTER THE INVOICE DEADLINE, NOR ARE THEY PERMITTED TO APPROVE A SECOND EXTENSION REQUEST. If you cannot make the October 28 deadline, an invoice deadline extension request form is attached for you to complete and submit (on or before October 28).
Attached to this message is a spreadsheet containing a list of all PA entities that, as of October 12, have either not submitted a BEAR or have had their BEAR $0-funded. The spreadsheet contains the service provider’s name, the amount that was committed, and the actual invoice deadline date for each FRN.
Who should submit a BEAR? Unless your vendor provided you with discounted bills, you must file a Form 472 BEAR to seek reimbursement. If you have a PIN, this form can be filed online at: http://www.sl.universalservice.org/menu.asp. Or it can be filed manually (print and mail it) and is available at: http://www.sl.universalservice.org/form. A guide to filing the online BEAR is attached.
IF YOU SUBMITTED YOUR BEAR ONLINE MORE THAN 2-3 WEEKS AGO AND YOUR NAME IS STILL ON THE ATTACHED LIST, CALL YOUR VENDOR AND MAKE SURE THEY CERTIFIED THE ONLINE BEAR. Some vendors can’t certify online BEARs, and others have difficulties getting the USAC notices that a BEAR is waiting to be certified. If your vendor can’t certify the online BEAR, then you must file a paper BEAR (with the vendor’s signature on page 4).
Please keep in mind that the SLD’s website only provides information on what disbursements have been authorized, not whether a BEAR has been submitted yet. So if you submitted a BEAR in the last 2 weeks and your name is still on the list, it is likely due to the fact that the funding disbursement hasn’t shown up yet in the USAC database.
After the SLD has reviewed and approved your BEAR, they will mail to you a BEAR Approval Letter, listing the amount of your check. Your check is mailed to your service provider within 20 days after the mailing of the approval letter. Service providers are required to mail you a check for the same amount within 20 days of receiving the check from the SLD.
A few important Q & A’s:
1) Can I complete the BEAR online?
A. Yes! The BEAR Form — 472 — can be submitted electronically to the SLD — if your service provider is accepting Online BEARs and if you have an E-rate PIN. If you cannot file online or choose not to, you can complete the Form 472 online using the PDF format, fax or e-mail it to your service provider for their signature on page 4, then mail the completed 5 pages to the SLD. The paper BEAR is located at: http://www.universalservice.org/sl/tools/forms.aspx under Form 472. The Online BEAR can be filed at https://www2.sl.universalservice.org/bear/login.aspx.
2) Can I put all of my reimbursement requests on a single BEAR?
A. No, a separate BEAR must be completed for each provider. For example, if you have 2 FRNs that list Comcast, and one FRN that is for AT&T, you can submit both Verizon FRN reimbursement requests on a single BEAR, and submit the AT&T reimbursement request on a separate BEAR.
3) Am I required to have the provider sign the BEAR?
A. Yes and No. You need the service provider’s signature on the PAPER BEAR Form before you submit it to the SLD. For the Online BEAR, the completed form will automatically be transmitted to the service provider for their electronic signature and then automatically filed with USAC. No separate signature is needed. To find the fax number of your service provider to have them sign the PAPER BEAR, use the SLD’s SPIN search database (http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp) and call the number listed.
Also, make sure the service provider signs the last page — the Service Provider Certification Page — and not the Applicant Certification Page which looks very similar. Also make certain that the provider includes the date beside their signature; dates are considered a minimum processing standard.
4) I was committed more funding than I actually spent. Can I request reimbursement for the full amount that was originally committed?
A. No. Applicants may only seek reimbursement for the exact amount paid for the service instead of just listing the full funding cap (for example, if you were committed $10,000, but then only spent $6,000, you can only request E-rate reimbursements based on the $6000). Please know that the SLD has increasingly been requesting copies of invoices when they review the BEARs as proof that you are requesting the accurate amount. Don’t send the invoices with the BEAR, but know they might be requested.
5) I spent more than what was committed on my funding commitment letter (my cap). What should I list on my BEAR — the cap or the actual amount spent?
The SLD would like you to complete the BEAR with the actual figures of what you spent for the service, and not just list your funding cap amount. For example, if you spent $10,000, and had a 50% discount, you would list $10,000 in Column 14 and $5,000 in Column 15, even if you were only committed $4,000. The reason is that the SLD would like to show how much applicants are actually spending on services and also so they know that you are not just listing the funding commitment amount (the cap), but have actually added up how much was actually spent in each of the 12 months using the actual vendor bills. Unfortunately, they will only reimburse you up to the amount that you were committed.
6) When will I receive my BEAR reimbursement check?
A. After the SLD has reviewed and approved your BEAR, they will mail to you a BEAR Approval Letter, listing the amount of your check. Your check is mailed to your service provider within 20 calendar days of the date of the approval letter. Service providers are required to mail you a check for the same amount within 20 calendar days of receiving the check from the SLD. And if the past is any indication, the BEAR Approval Letters are mostly being issued within 10-20 days of their receipt at the SLD.
7) What if I receive my BEAR Approval Letter and it lists that $0 was approved?
A. This typically means that there was an error made on the BEAR Form and the applicant must correct the error and resubmit to the SLD. Many years ago, the SLD reached out to the applicant to correct the Form over the phone, but no longer. Now the SLD will “pass zero” the BEAR (meaning they won’t fund it), but it doesn’t mean the E-rate funding is gone. It simply means that the applicant must resubmit the BEAR with corrected information and typically there is an explanation on the BEAR explaining what was incorrect to help identify the error.
8) What if I actually received a slightly different service than what was originally listed on my Item 21 attachments?
A. The SLD has increased scrutiny of the BEARs to make sure that reimbursement requests are for exactly what services were approved for on the FCDLs and Item 21 attachments. If you changed services during the 2012-2013 funding year from what you originally listed on your Item 21 attachments, you should first seek a “correcting service substitution request” from the SLD. The instructions for submitting a service substitution can be found at: http://www.sl.universalservice.org/reference/ServiceSub.asp
9) What should I do if I didn’t use the service?
A. File a Form 500 and cancel the FRN. The easiest version to use is available at: http://www.e-ratecentral.com/formsRack/app/Form500.asp.
If you have any questions about the FY 2014 Invoice Deadlines or completing the BEAR, please contact me at email@example.com.
Julie Tritt Schell
PA E-rate Coordinator