Archive for April 2013

SLD News 4/19/13 Focus: Form 471 & item 21 attachments

April 19, 2013

TIP OF THE WEEK: If you have not certified your FCC Form 471 for FY2013 and/or submitted all of your associated Item 21 attachments, do so on or before May 15, 2013 (see below). You can certify your FCC Form 471 online or on paper, and you can use any of the four submission options (online, email, fax, or paper) to submit missing Item 21 attachments.

Commitments for Funding Years 2012 and 2011

Funding Year 2012. USAC will release Funding Year (FY) 2012 Wave 40 Funding Commitment Decision Letters (FCDLs) April 23. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of April 19, FY2012 commitments total over $2.10 billion.

Funding Year 2011. USAC will release FY2011 Wave 89 FCDLs April 24. This wave includes commitments for approved Priority 2 requests at 88 percent and above and denials at 87 percent and below. As of April 19, FY2011 commitments total over $2.56 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

FY2013 Extended Deadline for FCC Form 471 Certifications and Item 21 Attachments

USAC will issue two sets of letters next week – one to applicants that filed an FCC Form 471 online before the close of the filing window but did not complete the certification process, the other to remind applicants to submit their Item 21 attachments. Both sets of letters will be issued on Thursday, April 25; appropriate actions must be taken on or before Wednesday, May 15.

  • If you do not certify your FCC Form 471 on or before May 15, it will be considered out-of-window. You can certify an FCC Form 471 online or on paper.
  • If you do not submit an Item 21 attachment on or before May 15, the Block 5 Funding Request Number (FRN) associated with that Item 21 attachment will be considered out-of-window. You can submit an Item 21 attachment online, by email, by fax, or by mail or delivery service.

Each letter is discussed below.

Notification of FCC Form 471 With No Certification

USAC will issue 930 letters to applicants that filed an FY2013 FCC Form 471 online on or before 11:59 pm EDT March 14, 2013 but that have not yet certified that form. These letters notify applicants that they must certify their forms online or on paper on or before May 15 for those forms to be considered in-window.

Remember that Federal Communications Commission (FCC) rules require USAC to consider all in-window funding requests first and, except for FY1999, funding has not been sufficient to fund out-of-window requests.

You can certify your form online or on paper.

To certify online, you must have a PIN and the security code for the FCC Form 471 you filed online:

  • Go to the Apply Online page and click the Certify Complete button in the Form 471 column.
  • Enter your FCC Form 471 application number and security code and click Electronic Certification.
  • You will see your Block 6 certification page with the information you entered when you submitted your form online. You must enter your PIN and check the box to affirm that you understand that the use of your PIN is the same as your written signature.
  • When you click the Done button at the bottom of the page, the system will return a CertID, a unique number that confirms your successful certification. We suggest that you click OK on the popup box and then print a copy of the resulting certification page, which will feature your CertID in the signature line as proof of your successful online certification.

To certify on paper:

  • Go to the Apply Online page and click the Certify Complete button in the Form 471 column.
  • Enter your FCC Form 471 application number and security code and click Paper Certification.
  • You will see your Block 6 certification page with the information you entered when you submitted your form online. Print out a copy of the page, sign and date it, and send it to the address at the bottom of the page. You are advised to keep proof of postmark or delivery.
  • NOTE: If you do not have your security code, you can print out a copy of the certification pages (pages 6, 7, and 8 of the paper FCC Form 471); provide the same information you provided online; and sign, date and submit it as described above. Keep in mind that USAC may need to contact you to request a correction if any information on this paper certification does not match the information you submitted online.

After your FCC Form 471 has been successfully certified, the status of that form will change to “Certified – Out Of Window” on the View 471 Status tool. After all of the paper certifications postmarked on or before the extended deadline have been processed, USAC will move all applications with timely filed certifications (both online and on paper) in-window.

Item 21 Attachment Urgent Reminder Letter

USAC will issue just over 3,980 letters to applicants that filed an FY2013 FCC Form 471 but did not file an Item 21 attachment for one or more of the Funding Request Numbers (FRNs) featured on that form. These letters remind applicants that they must submit their Item 21 attachments on or before May 15 for the associated FRNs to be considered in-window.

USAC issued a letter for each FCC Form 471 that was missing one or more Item 21 attachments. Letters were issued for the following situations:

  • An Item 21 attachment was not submitted.
  • An Item 21 attachment was started online but the Submit button on the last page was not clicked. You must click the Submit button on the last page of the online Item 21 attachment to complete your submission.
  • An Item 21 attachment was submitted by email, by fax, or by mail or delivery service but the FRN and/or FCC Form 471 application number associated with the Item 21 attachment was not clearly or correctly identified.

In addition to issuing letters, USAC will post a list of FY2013 FRNs missing Item 21 attachments to the main page of the USAC website for reference. Note that in many cases USAC issued this letter because we received and were able to locate and identify some but not all of the FRNs associated with your submission.

If you have already filed your Item 21 attachments by email, fax, or on paper, you can Submit a Question or call the Client Service Bureau (CSB) to verify that we have received them.

  • You should first review your copy of the submission to verify that Item 21 attachments are included for ALL of the FRNs from the FCC Form 471 and that you correctly identified both the FRNs and the FCC Form 471 application number.
  • If you contact CSB, be prepared to provide your Form 471 application number, the method of submission (email, fax, or paper), and the date of your submission.

If you have not yet submitted your Item 21 attachments, you must do so on or before May 15 for your FRNs to be considered in-window. The Item 21 Attachments guidance document has information on what to include in your Item 21 attachment(s) and how to file them online, by email, by fax, or on paper.

Remember that the View 471 Status tool shows the status of an FCC Form 471, not the status of each FRN on that form.

 

SLD News 4/12/13 – Focus: Eligible Services List

April 12, 2013

TIP OF THE WEEK: If you have not certified your FCC Form 471 for FY2013 and/or submitted all of your associated Item 21 attachments, do so as soon as possible. More information – including the deadline for responses – will be provided shortly.

Commitments for Funding Years 2012 and 2011

Funding Year 2012. USAC will release Funding Year (FY) 2012 Wave 39 Funding Commitment Decision Letters (FCDLs) April 16. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of April 12, FY2012 commitments total over $2.09 billion.

Funding Year 2011. USAC will release FY2011 Wave 88 FCDLs April 17. This wave includes commitments for approved Priority 2 requests at 88 percent and above and denials at 87 percent and below. As of April 12, FY2011 commitments total over $2.56 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

More Information on the PIA Review Process

In the April 5 SL News Brief, we covered the two main components of the Program Integrity Assurance (PIA) review process – Initial Review and Final Review. In this issue we cover in more detail some of the PIA questions about services asked during Initial Review.

Products and services in the funding request

In your Item 21 attachment, you describe the specific products and services that are part of your funding request. Your attachment should include a narrative description of each product or service. You can also add details – a product specification, a sample bill, a copy of the contract you have with your service provider, or other documentation – that will help your reviewer understand exactly what you have included.

The initial reviewer may need to ask you questions to clarify the specific type of services being received, the quantity and function of those services, and/or planned use(s) or users of the services in order to make a determination of eligibility.

Eligibility of the products and services in the funding request

In general, the products and services will fall into one of four categories as a result of Initial Review: eligible, conditionally eligible, partially eligible, or ineligible.

Eligible products and services. The initial reviewer determines whether the products and services in a funding request are eligible for discounts based on entries in the Eligible Services List for the funding year and other program guidance. Eligible products and services also must be used by eligible entities in eligible locations for eligible purposes. These determinations are first made during Initial Review.

If one or more of the products and/or services in a funding request appear to be conditionally eligible, partially eligible, or ineligible, the initial reviewer must perform additional review work. For example:

  • Certain charges on telephone bills are eligible and others are not. PIA may ask for a breakdown of a line item on a telephone bill labeled “Miscellaneous Charges” or “Other Charges and Credits.” In this case, you should provide only the relevant portion of a telephone bill that itemizes those charges and credits.

Conditionally eligible products and services. Products and services are conditionally eligible if they are eligible only when used under certain conditions – that is to say, in specific circumstances or for specific purposes. For example:

  • File servers are conditionally eligible depending on their use(s). PIA will ask what function(s) a file server will perform if this information is not readily available on the Item 21 attachment.
  • Basic maintenance is only eligible if it is for eligible products and services. PIA will ask for a list of the equipment being maintained – including make and model number – if this information is not readily available on the Item 21 attachment.

If a product or service is conditionally eligible, the initial reviewer must determine the conditions under which the product or service will be used. The reviewer will pay attention to Special Eligibility Conditions and any other information in the Eligible Services List that may affect eligibility.

Partially eligible products and services. In some cases, products and services may be partially eligible for discounts. For example, a file server may be used both as an email server (an eligible use) and an archive server (an ineligible use).

Generally, if a product or service has both eligible and ineligible uses or components, applicants must provide a cost allocation. A cost allocation is easiest to perform when the separation between eligible and ineligible components is clear – e.g., when your service provider prices each component of the product or service separately. In some cases, your service provider may be able to provide the cost allocation for you. For example, web hosting vendors work directly with USAC so that USAC can determine the eligible portions or percentages of their web hosting services.

Cost allocations must be based on tangible criteria that reach realistic results. There is not a single prescribed method to accomplish this. Below are some examples of cost allocations that USAC has accepted in the past:

  • For products that have multiple purposes, you can assume that each purpose represents an equal share of the cost. For example, if a file server is used as an email server (eligible), a web hosting server (eligible), and an archive server (ineligible), you can allocate two-thirds of the cost for eligible uses and one-third for ineligible uses.
  • Products and services that support equipment that is partially eligible should reflect that partial eligibility. For example, if the equipment supported by an Uninterruptible Power Supply (UPS) is 60% eligible, the UPS can be considered 60% eligible as well.
  • You can produce usage statistics to allocate services that are accessible from both eligible and ineligible locations. For example, say that a telecommunications service is accessible from both a school administrative office and an ineligible facility. You can allocate costs for the percentage of the usage for the school administrative office (eligible) and the ineligible facility (ineligible) based on documentation of current usage.
  • Check with your service provider to see if USAC has already made a determination about cost allocation for a product or service based on information previously submitted to USAC by the service provider. Providing the SKU for that product or service to your reviewer can speed up the review process.

Sometimes the components that are ineligible cannot be easily separated from the eligible components. For example, a Private Branch Exchange (PBX) is a telephone switching system that often includes an ineligible intercom feature. If such a product or service meets both of the following conditions, USAC can consider this to be an ancillary use of ineligible components and a cost allocation is not required:

  • A separate price for the ineligible component(s) cannot be determined, and
  • The product or service is the most cost-effective means of obtaining the eligible functionality without regard to the value of the ineligible functionality.

Ineligible products and services. USAC may determine that one or more of the products and services included in your funding request are not eligible for discounts. Your reviewer will contact you if your request must be modified or denied. You will have an opportunity to respond and your response will be included in the review of your application.

You generally have three options if PIA determines a product or service to be ineligible:

  • USAC can remove the ineligible product or service from the original Funding Request Number (FRN).
  • USAC can create a new FRN and move the ineligible product or service to that FRN.
  • In certain cases, USAC can move the product or service (or the entire funding request) to another category of service. For example, if on-premise Priority 1 equipment fails to meet the appropriate eligibility conditions as Telecommunications Services or Internet Access, it may still be eligible as Internal Connections.

In the above situations, you can still appeal USAC’s decision after you receive your FCDL. However, if the category of service is changed, an FCC Form 470 must have been posted for those services in that category of service for USAC to be able to approve your funding request. (There is one exception: Starting with FY2013, applicants can post for Priority 1 services on an FCC Form 470 in either Telecommunication Services or Internet Access.) Remember also that, if you do not agree to move or remove ineligible products and services and they comprise 30% or more of the funding request, USAC will deny the funding request following the 30% Rule.

Cost of the eligible products and services

The initial reviewer will also review both the total and the breakdown of the amounts in your funding request(s). If your reviewer cannot determine how the products and services requested relate to the dollars requested, you will be contacted and asked to provide or explain your calculations.

Here are some additional suggestions:

  • APPLICANTS: Involve your service provider in the process. Your service provider may be able to answer review questions, supply network diagrams, prepare cost allocations, and provide other helpful information. Be sure that both you and your service provider share copies of any information provided to USAC.
  • SERVICE PROVIDERS: If you know or suspect that a product or service you offer is conditionally or partially eligible, contact USAC by email to provide details for USAC’s review. In this way PIA will have information on eligibility for that product or service available for all reviews.
  • Submit only as much of a single telephone bill as the initial reviewer needs. For example, if the initial reviewer asks for details about “Miscellaneous” or “Other” charges, submit only that part of the bill that itemizes or explains those charges.
  • If you need more time to complete a response, ask for it.
  • If you feel you are not communicating successfully with your reviewer, ask to speak with a manager.
 

SLD News 4/5/13 – Focus: Application Review Process

April 5, 2013

TIP OF THE WEEK: Monitor the preferred mode of contact (telephone, fax, or email) you indicated in Item 6 of your FCC Form 471 in case USAC has questions about your application. The review of your application can proceed much more quickly with prompt responses to our questions.

Commitments for Funding Years 2012, 2011, and 2010

Funding Year 2012. USAC will release Funding Year (FY) 2012 Wave 38 Funding Commitment Decision Letters (FCDLs) April 9. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of April 5, FY2012 commitments total over $2.07 billion.

Funding Year 2011. USAC will release FY2011 Wave 87 FCDLs April 10. This wave includes commitments for approved Priority 2 requests at 88 percent and above and denials at 87 percent and below. As of April 5, FY2011 commitments total over $2.56 billion.

Funding Year 2010. USAC will release FY2010 Wave 111 FCDLs April 11. This wave can include commitments for approved Priority 2 requests at all discount levels. As of April 5, FY2010 commitments total over $3.07 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

Overview of the PIA Review Process

Program Integrity Assurance (PIA) is the process used by USAC to review applications for compliance with program rules and policies. During this process, USAC reviews the information on your FCC Form 471 and may contact you with additional questions on specific items.

The review process has two components:

  • Initial Review
  • Final Review, a quality assurance review process on the work done during Initial Review

Initial Review

After your FCC Form 471 has been assigned to an initial reviewer, the initial reviewer prepares the questions that USAC must ask based on the information you provided (or did not provide) on your application. The questions can cover a wide range of issues on your application, including but not limited to:

  • the eligibility of the schools and libraries listed on your application
  • the eligibility of the products and services listed on your Item 21 attachment
  • the discount rate on your Block 4 worksheet(s)
  • your competitive bidding process, including your adherence to the 28-day posting requirement
  • discrepancies between the funding request and the Item 21 attachment and/or supporting documentation.

The information on the FCC Form 471 may be sufficient to complete the review without applicant contact. If not, USAC must request more information.

Once the appropriate questions have been prepared, the initial reviewer contacts you using your preferred mode of contact.

  • If your preferred mode of contact is email or fax, the initial reviewer’s first contact is the email message or fax containing the list of questions that require a response.
  • If your preferred mode is telephone, the initial reviewer will call you and then email or fax you the list of questions.
  • In all cases, USAC provides written questions and asks for written responses to those questions.

In general, you have 15 days from the date of the email or fax to provide responses to USAC’s questions. (For more information on the specific summer and winter periods when this procedure is modified, refer to the Missing Information guidance on the USAC website.)

  • If USAC has not received a response – or receives only a partial response – after seven days, USAC sends you a reminder and forwards a copy of the reminder to your state school or library E-rate coordinator.
  • If USAC does not receive a response after 15 days, USAC will continue to process your application with the information on hand, which may lead to a modification or denial of funding.

During all review processes, you always have the following options:

  • You can ask for clarification. If you don’t understand one or more questions, ask your initial reviewer what the question means or what information USAC expects in your response.
  • You can ask for more time to respond. USAC can grant a limited extension of time to respond to questions. However, if you ask for more time, your initial reviewer will set aside your application and start other reviews while you work on your response, so he or she may not be able to return to your application quickly once you provide the information.
  • You can ask to speak with a manager. If you feel that you are not communicating successfully with your initial reviewer, please ask to speak to a manager. You will not be penalized if you make this request, and the manager can help you understand the questions USAC is asking and the responses USAC expects to receive.

Initial Review modifications and denials

Once Initial Review has been completed, the initial reviewer may recommend that a funding request be modified or denied based on the information supplied during the review. Some examples of modifications are:

  • Removal of ineligible products and services
  • Removal of ineligible recipients of service
  • Addition of eligible recipients of service
  • Reduction in number of months of service
  • Reduction in amount of funding based on additional documentation you provided
  • Changing contract start or end dates
  • Changing from month-to-month services to contracted services
  • Changing the establishing FCC Form 470 application number.

If the initial reviewer concludes that a funding request should be modified or denied, you will be contacted before USAC issues your FCDL. The initial reviewer will inform you of the result of the review and give you an opportunity to provide additional information if you disagree with the conclusion. (If you agree with the initial reviewer’s determination, you do not have to provide a response.) USAC will review any additional information provided.

Final Review

Final Review is a review by USAC of the work done during Initial Review. Each step of the Initial Review process is itself reviewed by a final reviewer to verify that the correct procedures were followed, the appropriate questions were asked, and complete answers were received. If the final reviewer has a concern about any part of the Initial Review process, the application is returned to the initial reviewer for follow-up work.

The result of this process is that you may be contacted after your Initial Review with what may appear to be additional or repetitive questions. If the questions you are being asked seem new or repetitive, it is likely that USAC needs additional information that was not gathered during Initial Review. Make sure you understand what information is being requested and provide the information as quickly and accurately as possible.

Some applications go through a third level of review called Quality Assurance (QA). Quality Assurance is an additional check to verify that all parts of the review were done correctly. As with Final Review, applications may be returned to the initial reviewer for follow-up.

It is important to understand that the review process is not linear. At any point during the process, an application can be returned to an earlier stage because of work that was not completed correctly or information that is missing. If you are following the progress of your application using the View 471 Status tool, do not be alarmed if your application seems to move “backward” – that is, to an earlier status. If you do see such a movement, monitor your preferred mode of contact carefully in case an initial reviewer attempts to contact you.

In summary, to be prepared for PIA review, be sure to do the following:

  • Check your FCC Form 471 and your Receipt Acknowledgment Letter (RAL) to make sure all of your entries are correct. If you find a mistake, submit a RAL correction by following the instructions in the RAL. If your review has already started, you can submit your corrections directly to your reviewer using the reviewer’s contact information provided on the PIA fax/email.
  • Organize all of the documentation related to your application and have it readily available to assist you in answering any questions.
  • Monitor your preferred mode of contact so that you will know when PIA attempts to contact you.
  • Answer all questions promptly and completely.
  • Ask for more time to respond if you need it.
  • If you are having problems, ask to speak to a manager.