-----Original Message-----
From: Julie Tritt Schell [mailto:jtschell@comcast.net]
Sent: Thursday, October 14, 2004 2:51 PM
To: E-rate Listserve - PA
Subject: New E-rate Identification Number Needed
All E-rate Applicants Must Get New FCC ID Number
As a result of the new accounting standards required to be adopted by the Universal Service Administrative Company (USAC), a provision included in the federal Anti-Deficiency Act called the Red Light Rule now pertains to the E-rate program. Simply put, if any applicant or service provider owes the FCC or other cooperating federal agency a debt, no E-Rate funds can be committed or paid until that debt is cleared. So if service provider X is late on paying a fine completely unrelated to E-rate, or is
negligent in submitting its quarterly contribution to USAC, NO invoices with that service provider's SPIN will be paid to any applicant. And visa versa.
In order for the FCC to track who owes funds to the FCC and to monitor who is compliant with the Red Light Rule, the FCC is requiring entities to obtain an FCC Registration Number (FCCRN). Although applicants have E-rate Entity Numbers and use those on all E-rate forms, the FCC apparently can't use those numbers to track entities within their FCC computer system to determine whether entities have outstanding debts. Therefore, the FCC is now requiring all E-rate applicants, service providers and consultants to obtain an FCCRN -- a 10-digit number that is used by all FCC systems that handle financial, service authorization, and enforcement activities.
FCCRNs will not be blanketly assigned; rather, applicants are required to obtain FCCRNs via the FCC website (instructions below).
WHO MUST OBTAIN AN FCCRN?
The FCC initially told us that every single school building, including every non-instructional facility (NIF) in a district must obtain an FCCRN. We have been trying to convince them that, in general, schools do not pay bills or have budgets -- districts do -- and therefore the FCC wouldn't be able to collect money from an individual school anyway. Until we hear otherwise, I am suggesting you only apply for an FCCRN for the entity that pays the bills. In most cases, this is the main District or library office. I'll let you know if they tell us unequivocally that all entities must have get an FCCRN.
WHAT IS THE DEADLINE TO OBTAIN AN FCCRN?
The FCC has set a November 1, 2004, deadline to obtain Registration Numbers. While there is no penalty for missing this deadline, when the SLD contacts you after this date regarding any issues associated with your applications, you will be asked for your Registration Number. Thus it is advisable to get your number(s) as soon as possible. Forms for 2005 (not yet available) do not contain a space for the FCCRN, but you will be required to submit it with your Item 21 attachment after you submit your Form 471. I'm assuming the 471 will then be revised for 2006 and will actually contain a field for the FCCRN.
WILL FCCRN'S REPLACE E-RATE ENTITY NUMBERS?
It has been stated that this is the goal in future years, although if the FCC adopts our recommendation to only require billed entities to obtain the FCCRN, then the E-rate entity numbers for individual buildings would remain.
HOW DO I APPLY FOR AN FCCRN?
The Registration Number application process is done via the Web and is not difficult. It will take approximately 3 minutes to complete the information for each entity. Keep in mind that this FCCRN system was not created for the E-rate program and so the questions asked will seem odd.
Note: Before you can obtain an FCC Registration Number you will need your school or library’s Employer Identification Number (EIN) or Tax Identification Number (TIN). The EIN/TIN is a nine-digit number that the Internal Revenue Service requires of all employers for tax purposes. If you do not have this number, contact your business office or business manager.
To obtain an FCC Registration Number, go to the FCC’s Website at https://svartifoss2.fcc.gov/cores/CoresHome.html and do the following:
1) Select the “Register” option.
2) For Registration Type, accept the defaults of “Business” and “Yes”, and click “continue.”
3) On the next screen, enter the information requested.
For Business Type, on the drop down box:
Public Libraries: Select “State or Local Agency.” On the right, select the closest subtype, which is probably “County,” “Township,” or “State or Local Commission”.
Public Schools: Select “State or Local Agency.” On the right, select the closest subtype, which is probably “State or Local Commission.”
Non-public Schools: Select “Private Sector.” Select the closest subtype, which is probably “Non-Profit/Exempt Organization.”
Enter your Employer Identification Number (EIN or TIN).
For Business Name: Enter the name of the library/school district. If you're feeling eager and want to apply for an FCCRN for all of your buildings, I suggest you enter the name of the district, then the name of the individual school behind it. For example: Appleton School District, North High.
For Contact Information, enter the address of the district or library, and then for the contact, I recommend you list "E-rate Contact" instead of an individual person's name. This way you won't have to update it if your E-rate contact changes.
FRN Password: You can either make up a password or the system will generate one for you.
4) When you are finished, carefully review your information. When every data element is correct, press the “submit” button. A new screen will appear containing all of your information, along with your FCCRN and password. Be certain to print off the verification page and save the information in an electronic file.
Note: If you choose to obtain an entity number for each of your branches or individual schools, you should know that most school districts and libraries have only one EIN. When you press the “submit” button after already having filed for a Registration Number for a school or library branch, the system will warn you that you will be creating another Registration Number for the same EIN. Since each school/branch needs a separate Registration Number, just select the “Continue” option.
-- Julie
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