Applicants Have Option of Discounted Bills in Year 7
Message Posted July 15, 2004
In what was seen as a major victory for applicants, in April 2003, the FCC issued an Order (http://www.sl.universalservice.org/data/pdf/FCC-03-101.pdf) which requires service providers to give applicants the choice of receiving discounted bills or paying the full price and then receive reimbursement through the BEAR process. Although this rule was adopted in April 2003 (15 months ago), the FCC deliberately did not make this rule take effect until July 1, 2004, Funding Year 7 (2004-2005) in order to give service providers time to adjust their billing systems and prepare to provide applicants this this option.
I have received numerous questions regarding implementation of this new rule, and below is a Q & A that will hopefully provide answers for all PA applicants.
1) How do I notify my service providers that I would like discounted bills?
A. Currently, there is no space on an SLD form that allows/requires you to indicate which method of discounting you would like. Many service providers, such as Verizon, Nextel and Verizon Wireless, contact applicants directly to ask which option they prefer. Applicants should contact service providers as soon as possible if they would like to receive discounted billing for Year 7. The safe assumption is that if you don't tell your service provider that you want discounted billing, you will continue to receive full bills and have to file a BEAR form to seek reimbursement.
NOTE: The application process for Funding Year 8 (2005-2006) begins in a few months, and I strongly advise applicants to list in their 470 or RFP whether they would like discounted billing, and if require service providers to indicate to you what, if any, additional fees or paperwork will be imposed in order to receive discounted bills. In addition, if contracts are signed, be sure to memorialize that payment method in the contract (even standard contracts can be amended!). There is no such rule that you do so, but it will strengthen your case later if there are compliance failures.
2) Can service providers discount bills before the 486 Approval Letter is received?
A. Service providers, in almost all cases, will not start discounting bills until the Form 486 Approval Letter is received from the SLD. Therefore, applicants are strongly encouraged to file the Form 486 immediately after receiving the FCDL for Year 7. The SLD has been taking about 30 days to process the 486 and mail the approval letter.
2a) For internal connections, can service providers require that I file the Form 486 before they ship the equipment?
A. No, the 486 cannot be filed until the equipment has been delivered. Several companies -- including 2 large, well-known, computer companies -- have been indicating otherwise to their applicants and stating that they will not ship the equipment until the 486 approval letter has been received. I have spoken with the SLD on this issue and they agree that service providers cannot impose such a requirement on applicants.
3) After I decide on a choice of payment method, can I switch from one option to another?
A. No, once an applicant has made its choice for a funding year, and a BEAR or SPIF (service provider invoice) has been submitted to the SLD, the applicant may not switch from one form of payment to the other within that funding year.
4) What if my service provider refuses to provide discounted billing?
We have posed this question to the FCC, and their response was that they were still looking into it, but wanted to know which providers are refusing. If you know of any providers who are refusing, please let me know.
AT&T has stated that they will not provide discounted billing due to sheer number of customers and they have met with the FCC at least three times in the last six months, requesting a waiver of this rule in order to allow them to continue their current method of reimbursement. The FCC, so far, has refused to grant them the waiver, although no applicant has yet challenged AT&T's non-compliance before the Commission. I believe that by granting a waiver to AT&T, all other companies will immediately request waivers and it will be downhill from there.
5) Are service providers permitted to add on an extra fee if I choose the discounted billing option?
A. Some service providers have argued that providing discounted billing will result in significant administrative costs to them, and they will begin adding a surcharge to discounted bills. We have posed this question to the FCC, but haven't heard a response. Based on our reading of the FCC Order, there is nothing prohibiting them from doing so, at least for now. We would like to report to the FCC the companies adding extra fees for discounted billing, so if you have encountered one, please let me know.
I have been contacted by several schools about a letter they received from Commonwealth Telephone Company, indicating that they may impose fees on customers that choose discounted billing. I have spoken with their attorneys and have been told that they do not expect to impose a fee for Funding Year 7 (2004-2005), and will determine based on actual costs and demand, what, if any, fees should be imposed for Year 8. They would not indicate what these fees may be.
6) If I choose discounted billing, is there anything else I need to do?
A. After you receive your Funding Commitment Letter, you should file your 486 immediately, and notify your service provider which payment option you choose. If you have not yet received your FCDL, you may contact your service provider now so they can be preparing to discount your bills. Other than that, simply monitor your monthly bills to make certain that you are receiving the proper discount. If your discounts exceed your funding cap at the end of the funding year, you will be expected to pay any full, undiscounted bills that are received after the cap has been reached.
As always, if you have any questions, please let me know!
-- Julie
jtschell@comcast.net
(717) 730.7133 (voice)
(717) 730.9060 (fax)
| 
Back to 2004 Archives Main