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Denied Centrex Invoices - New Procedures
Message Posted June 11, 2007

In April I was contacted by two PA applicants who explained that their BEARs were rejected because they were for Centrex services and Centrex was not explicitly listed on their Item 21 attachments.  (Centrex is a PBX-like service providing switching at the vendor's central office instead of at the customer's premises.)   Thanks to this inquiry, we discovered that many such invoices were being denied throughout the country and over the past two months, the state E-rate coordinators have worked with USAC to develop a way in which these invoices could be approved. 

Beginning immediately, most of these invoices -- both BEARs and Service Provider Invoices (SPIs) -- will now be approved as long as:

    1. The applicant or service provider can demonstrate that Centrex was not a newly implemented service. The issue here is that, if it was a new service, the applicant should have clearly indicated that in the Item 21 Attachment.  To prove that Centrex was not a new service, USAC may ask for a copy of a bill for the same service from the previous year. 
    2. The applicant did not apply for "basic" telephone service (i.e., had not checked "Basic telephone service only" in Item 14 of its Form 470, or checked 26c of the Form 471 certifications, or stated there was no technology plan on the Form 486 because the services were all "basic" phone services).  Although the rules on this point may change in the future, the FCC does not currently consider Centrex to be a "basic" telephone service.  One issue here is that an applicant does not need an approved technology plan if it is applying only for basic telephone services.

Important: Applicants and service providers whose Centrex invoices were previously denied should resubmit those invoices.  If your invoice was denied in a previous funding year (FY 2005 or earlier), you will first have to request an Invoice Deadline Extension before your invoice can be resubmitted. 

Thanks for bringing these denials to my attention!

-- Julie

Julie Tritt Schell

717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
Penn*link

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