8/3 SLD News & Tips – Note: Using consultants

TIP OF THE WEEK: The Client Service Bureau will only discuss specific FCC Form 471 information with the contact person or the authorized person identified on that form if the information is not publicly available. If you are not the contact person in Item 6a or the authorized person in Item 40 of the FCC Form 471, be prepared to provide evidence of your authorization to discuss the information on the form.

Final P2 Funding Thresholds Set for FY2012 and FY2011

The Federal Communications Commission (FCC) and the USAC Board have reviewed and approved USAC’s proposed funding thresholds for FY2012 and FY2011 Priority 2 (Internal Connections and Basic Maintenance of Internal Connections) funding requests. The FCC and the USAC Board have directed USAC to take the following actions:

  • Set the final funding threshold for approved FY2012 Priority 2 (P2) funding requests at 90 percent. P2 funding requests at 89 percent and below will be denied for lack of funds.
  • Set the final funding threshold for approved FY2011 P2 funding requests at 88 percent. P2 funding requests at 87 percent and below will be denied for lack of funds.

USAC will target issuing commitments and denials using these thresholds next week.

Please note, however, that Program Integrity Assurance (PIA) reviews are ongoing, and USAC cannot issue funding decisions on an application until the reviews for all funding requests at all discount levels on that application are complete. For example, if an FCC Form 471 for FY2012 has one P2 funding request at 90 percent and another P2 funding request at 85 percent, USAC must wait until the review of the funding request at 90 percent has been completed before issuing a Funding Commitment Decision Letter for that application. Note further that the PIA review process may result in a change to the discount level(s) originally requested.

As a reminder, approved Priority 1 (Telecommunications Services and Internet Access) funding requests continue to be funded at all discount levels for both funding years.

Commitments for Funding Year 2011

Funding Year 2011. USAC will release FY2011 Wave 55 FCDLs August 8. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 88% and above and denials at 87% and below. As of August 3, FY2011 commitments total over $2.31 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. 

Fall 2012 Applicant Training Sessions

The training session in Minneapolis still has space available; the other sessions have gone to waiting lists. To register with USAC for the training or to make a room reservation at a conference hotel, refer to the Trainings and Outreach page on the USAC website.

Please email USAC Training with questions or to cancel your registration if your plans change. We are actively working the waiting lists for all training sessions, so your cancellation will open a space for someone else. 

Consultant Registration Numbers

Now that applicants are starting to file FCC Forms 470 for FY2013, we are providing the information below for those applicants that are using consultants and need more information on Consultant Registration Numbers to complete Item 7 of the form.

What is the definition of a consultant?

A consultant is any non-employee of the entity applying for funding that assists in filling out the application materials for a fee. Consultants may be organizations with one or more employees or they may be individuals.

The term “consultant” below refers to the name – whether an organization or an individual – linked to the Consultant Registration Number and entered in the “Consultant Name” field on the FCC Form 470.

What is a Consultant Registration Number?

A Consultant Registration Number (CRN) is a unique eight-digit identification number assigned by USAC to a specific consultant. Employees of a consultant will not be required to obtain individual CRNs but will use the CRN of the consultant.

If a consultant is assisting an applicant with the application process, the consultant’s CRN is entered in Block 1, Item 7 of the Form 470 and/or Block 1, Item 6g of the Form 471.

How does a consultant obtain a CRN?

To get a CRN, a consultant should call the Client Service Bureau (CSB) at 1-888-203-8100 and be prepared to provide the following consultant information:

  • Consultant Name
  • Consultant Street Address, City, State, and Zip Code
  • Consultant Telephone Number
  • Consultant Fax Number
  • Consultant Email Address

If the consultant has one or more employees, the following information is required for each employee:

  • Employee Name
  • Employee Telephone Number
  • Employee Email Address

CSB will first search by zip code, then by street address, to find out if USAC already has a CRN on file. If so – and if there are no changes to any of the contact information – CSB can provide the CRN over the phone.

If CSB must create a new record, or if there are changes required to an existing record, CSB will request that the changes be sent by fax to 1-888-276-8736 or by email. After the record has been created or updated, CSB can reply to the fax or email and provide the CRN.

How does an applicant find the CRN for its consultant?

If the consultant is completing a form on behalf of the applicant, the consultant can enter the CRN. If the applicant is completing a form, the applicant can obtain the CRN from the consultant or call CSB. CSB can provide the CRN over the telephone as long as the applicant provides enough information for CSB to identify a specific consultant.

  • Consultants and applicants filing online should check after entering the CRN to verify that the correct consultant information is populated in the form.

Where is consultant information located on Form 470 and Form 471?

Consultant information is entered in Block 1, Item 7 of the Form 470 and Block 1, Item 6g of the Form 471. Applicants filing online will enter the CRN, and consultant contact information will populate automatically. If the consultant has employees, those employee names will be populated in a drop-down menu and the applicant can choose the appropriate employee.

Applicants filing on paper must complete all relevant fields. 

NOTE: The FCC recently released an Order (DA 12-1189, released July 25, 2012) affirming USAC’s denial of funding where the E-rate consultant had a financial relationship with the selected service provider, which constituted a prohibited conflict of interest in the competitive bidding process. To quote directly from the order, “A consultant, acting on behalf of the applicant, exerts great influence on an applicant’s bidding process and thus, should not have a financial relationship with a service provider which it selects (or recommends) on behalf of the applicant.” 

Consultants – and applicants using the services of a consultant – should review and take note of the information contained in this order.