May 11th News & Tips from SLD

 TIP OF THE WEEK: Remember that June 30, 2012 is the last date to receive FY2011 recurring services. If you are planning to file only one invoice with USAC for the entire funding year, read the information below carefully.

Commitments for Funding Year 2011

Funding Year 2011. USAC will release FY2011 Wave 45 Funding Commitment Decision Letters (FCDLs) May 16. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90% and denials at 79% and below. As of May 11, FY2011 commitments total over $2.16 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.

Invoicing for FY2011 Recurring Services

June 30, 2012 is the last day to receive recurring services for FY2011. Recurring services are those that are delivered on a regular basis, e.g., monthly telephone services or monthly Internet access. (See also the special note on Basic Maintenance of Internal Connections below.) For those applicants and service providers that have not already started the invoicing process for FY2011, now would be a good time to plan for how and when you will be invoicing USAC in advance of the October 29, 2012 invoicing deadline.

Applicants and service providers should be mindful of the following issues relating to invoicing, especially if they intend to submit one invoice to USAC that covers the entire funding year. Also, if you need to request one or more of the changes discussed below, be sure to submit your request(s) in a timely manner.

Invoices for recurring services

There are two methods that can be used to invoice USAC:

• FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form, is filed by the applicant and approved by the service provider AFTER the applicant has paid for the eligible services in full. BEAR Forms can be filed online or on paper.
• FCC Form 474, Service Provider Invoice (SPI) Form, is filed by the service provider AFTER billing the applicant for the non-discount portion of the eligible services. SPI Forms can be filed online, electronically, or on paper.

Once a BEAR Form or SPI Form has been successfully processed for a Funding Request Number (FRN) – even if that successful processing does not result in a payment – you must continue to use that method for that Funding Request Number (FRN). In other words, you cannot use a mixture of SPI and BEAR Forms for a single FRN.

Invoices must be based on eligible costs and supported by customer bills for those costs. Although recurring services are often billed to a customer on a monthly basis, applicants and service providers are not required to submit monthly invoices to USAC but can combine one or more months of service on a single invoice.

For an FRN that covers 12 months of monthly service, USAC will look for 12 months of service in that funding year whether the bills are calculated in advance or in arrears. It is not necessary to prorate the costs for monthly service on (1) the first bill of the year for a month that included July 1 or (2) the last bill of the year for a month that included June 30. However, USAC will check to be sure that there is no overlap in payments – that is, that we did not already pay the discount in the previous funding year for the entire customer bill for the same month of service.

Treating Basic Maintenance as a recurring service

Services in the Basic Maintenance of Internal Connections category of service are considered recurring services. As such, they cannot be delivered after June 30 of a funding year.

If an applicant cannot start an eligible Basic Maintenance service until USAC has issued a funding decision, USAC can process invoices for that service only from the date that the service actually started through the date that the service ended in that funding year (on or before June 30). Note that applicants in this situation should have already applied for these Basic Maintenance services for the following funding year (i.e., starting July 1 of the following funding year) under a new FRN if they want to request discounts on these services after June 30 of the current funding year.

Requesting service delivery deadline extensions

The deadline for delivery and installation of services can be extended for non-recurring services only. USAC cannot consider requests for extensions for the receipt of recurring services.

• Extension requests: Service delivery deadline extension requests for non-recurring services must be submitted on or before the last day to receive those services, which is generally the September 30 following the close of the funding year. USAC cannot process requests submitted after that deadline.
• Automatic extensions: If USAC issues certain decisions (e.g., an FCDL, an operational SPIN change approval, or a service substitution approval) on or after March 1 of a funding year, the service delivery deadline for that non-recurring services FRN is automatically extended.

Requesting SPIN changes

Service Provider Identification Number (SPIN) changes may be necessary before USAC can pay invoices. Below are some examples of corrective SPIN changes that can and should be made before invoices are submitted:

• An applicant cited an incorrect SPIN – either because of a typographical error or because the service provider has more than one SPIN – and the error was not caught before USAC issued a commitment.
• The SPIN has been affected by a merger or acquisition.
• The applicant filed an FRN using the state replacement contract SPIN and the replacement contract went into effect before or during the funding year.

If the SPIN that appears on the FRN is incorrect, it must be corrected before an invoice can be processed. If you are not sure which SPIN is cited on an FRN, you can submit a question or call the Client Service Bureau at 1-888-203-8100 for assistance.

Returning unused funds with an FCC Form 500

After the final invoice for an FRN has been paid by USAC, the applicant should check to see if any funds remain on the FRN. If so, the applicant should reduce the commitment amount on the FRN to the amount actually paid so that the unneeded funds become available for new commitments for other applicants.

To reduce a commitment amount, the applicant files an FCC Form 500, Adjustment to Funding Commitment and Modification to Receipt of Service Confirmation Form. On the second page of the paper form, the applicant enters the FRN in Item 5B and the reduced commitment amount (the total amount actually invoiced to and paid by USAC for that FRN) in Item 5I. After USAC processes the form, the committed amount is reduced to the amount actually disbursed and the unused funds become available for new funding commitments.

However, do not reduce a funding commitment until you are absolutely sure that all funds have been correctly disbursed. Reductions and cancellations submitted on an FCC Form 500 cannot be reversed after they are processed. If the service provider is filing SPI Forms for an FRN, the applicant should verify with the service provider that all invoices to USAC have been submitted and paid before filing an FCC Form 500 to reduce the committed amount.

Returning funds disbursed in error

During the preparation of BEAR Forms or SPI Forms, the applicant and/or service provider may notice that funds have been disbursed in error. Here are some examples of how this could occur:

• The applicant or the service provider made a typographical error on a previous invoice.
• A piece of equipment was returned by the applicant for a refund after USAC paid an invoice for the equipment.
• USAC was invoiced in full but a rebate or discount was provided to the applicant and USAC did not receive its proportional share of the rebate or discount.

Funds disbursed in error must be returned to USAC. If you can correct the original error (for example, if your invoice to USAC for the first month was too high but you still have other eligible charges to invoice on that FRN), you can submit an accurate invoice to USAC after the funds have been returned.

May 4, 2012 SLD News Briefs – Fall Training Schedule

Save These Dates for Fall 2012 Applicant Training

Registration and hotel reservation information will be available within the next several weeks for the applicant training sessions to be held during fall 2012. For planning purposes, here are the cities and dates where training sessions will be held:

Service Provider Training Update

The presentations for the service provider training sessions in Atlanta on May 10 and Los Angeles on May 15 have been posted to the Service Provider Training Resources page on the USAC website. If you are attending a training session, please download or print the presentations and bring them with you to the training.

May 9 Deadline for FY2012 Item 21 Attachments and FCC Form 471 Certifications

The May 9 deadline for submitting FY2012 Item 21 attachments and FCC Form 471 certifications is fast approaching. We have included information below for those applicants that have not completed one or both of these important steps in the FY2012 application process.

• If you do not submit an Item 21 attachment on or before May 9, 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, or by fax on or before May 9; you can also postmark a paper Item 21 attachment on or before May 9.
• If you do not certify your FCC Form 471 on or before May 9, your form will be considered out-of-window. You can certify an FCC Form 471 online on or before May 9 if you have a PIN; you can also postmark a paper certification on or before May 9.

- ITEM 21 ATTACHMENTS

The Item 21 attachment contains a detailed description of the products and services you are requesting. You provide an attachment number in Item 21 of each FCC Form 471 Block 5 funding request that will correspond with your Item 21 attachment, and then you submit that Item 21 attachment separately from the application.

NOTE: You must provide an Item 21 attachment for EACH FRN on your FCC Form 471. Also, if you are filing your Item 21 attachment online, you MUST click on the Submit button on the last page for your Item 21 attachment to be considered submitted.

• Clicking “Save” allows you to save your work and return later.
• Clicking “Submit” submits your Item 21 attachment to USAC and returns a time-stampled confirmation page.

Following are some specific tips for Item 21 attachments for each of the four categories of service – Telecommunications Services, Internet Access, Internal Connections, and Basic Maintenance of Internal Connections. If you include the information suggested in the tips, your PIA reviewer will be able to more easily make determinations of the eligibility of the components of each of your funding requests. For details on each of these tips, refer to the February 24 SL News Brief and the Item 21 Attachments guidance document on the USAC website.

Telecommunications Services

• Provide the specific type(s) of service requested.
• Provide the number of lines, including the number of extensions.
• For digital transmission services, provide the bandwidth.
• If you are submitting a copy of your bill as all or part of your Item 21 attachment:
  • Pick a bill that represents your typical monthly costs. One month is generally sufficient.
  • Make sure the dollar amount of the bill is typical of your monthly costs and supports your request.
  • Include the page(s) that detail any miscellaneous charges and/or credits.
  • Identify any ineligible charges.

Internet Access

• For digital transmission circuit(s) for basic conduit access to the Internet, provide the bandwidth of the services you are requesting.
• If you are requesting web hosting services, ask your service provider for a cost allocation and include it with your attachment.
• Clearly identify the total cost of the service as well the percentage of the total cost for which you are seeking funding.

Internal Connections

• For all Internal Connections requests, provide the make and model number and the quantity of any equipment included in your funding request.
• For bundled products, in addition to the make and model numbers, provide the SKU (stock-keeping unit, a unique identifying number assigned by a company to each of its products and/or services).
• Equipment that can be used in both eligible and ineligible ways should have its function or functions clearly identified with an appropriate cost allocation.
• If you are requesting discounts on equipment such as cabinets, racks, and UPSs, identify the equipment they are supporting.
  • If only eligible equipment will be supported or housed, you should state that and provide the make and model numbers of the eligible equipment.
  • If both eligible and ineligible equipment will be supported or housed, you should provide that information together with an appropriate cost allocation.

Basic Maintenance of Internal Connections

• Provide a list of all of the equipment being supported by the basic maintenance.
• State the basic maintenance tasks that you estimate will be performed and the costs associated with those tasks.
• If your basic maintenance contract includes both eligible and ineligible equipment, be sure you can provide a clearly identifiable price for the ineligible equipment.

Your service provider(s) can assist you with creating your Item 21 attachment. Your service provider may have specific details that USAC needs, which may include network diagrams, SKUs, or other information not readily available to you. Be sure also to share with your service provider a copy of the Item 21 attachment you submit to USAC.

Submitting your Item 21 attachment(s)

Here are your options for submitting your Item 21 attachment(s):

1. File online using the Item 21 Attachment button on the Apply Online page. You will need your Billed Entity Number, your application number, and your security code. (You cannot file your attachment online if you submitted your FCC Form 471 on paper.)

2. Attach your submission to an email message and email it to USAC.

3. Fax your submission to: (973) 599-6511.

4. Mail your submission to:

SLD Forms
Form 471 – Item 21 Attachment
P.O. Box 7026
Lawrence, KS 66044-7026

5. Send your submission by delivery service to:

SLD Forms
ATTN: Form 471 – Item 21 Attachment
3833 Greenway Drive
Lawrence, KS 66046
TELEPHONE: 1-888-203-8100

If you are using the View 471 Status tool to check your status, remember that the tool will only show the status of an FCC Form 471, not the status of each FRN on that form.

- FCC FORM 471 CERTIFICATIONS

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 on the Certify Complete button in the Form 471 column.
• Enter your application number and security code and click on 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 on 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 on the Certify Complete button in the Form 471 column.
• Enter your application number and security code and click on 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.
• If you cannot access the certification function online (if, for example, you cannot find your security code), you can print pages 6, 7, and 8 of a paper FCC Form 471, fill them out with the information you provided when you filed online, and sign, date, and submit them as above. Note that USAC may contact you to request corrections if the information on your paper certification is inconsistent with the information you provided when you filed online.

After you successfully certify your FCC Form 471, the status of that form will change to “Certified – Out Of Window” on the View 471 Status tool. Once all of the paper certifications postmarked on or before May 9 have been processed, USAC will move all applications with timely filed certifications (both online and on paper) in-window.

4/27/12 SLD Latest News

FY2012 Demand Estimate

Each year, about a month after the close of the filing window, USAC prepares a demand estimate for the upcoming funding year and submits it to the Federal Communications Commission (FCC). The demand estimate summarizes the dollar amounts for all funding requests submitted on timely filed FCC Forms 471. These totals are also broken down by category of service and by discount band (90%, 80-89%, 70-79%, etc.)

For FY2012, the total estimated demand is $5.237 billion, which includes approximately $2.444 billion in Priority 1 requests (Telecommunications Services and Internet Access) and approximately $2.793 billion in Priority 2 requests (Internal Connections and Basic Maintenance of Internal Connections). The demand estimate is based on the funding requests in the 46,838 applications received or postmarked on or before March 20, 2012, the close of the FCC Form 471 application filing window.

More Information on the PIA Review Process

In the April 13 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 functions 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. 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 – 4/20/12 Focus: Item 21 Attachments

Commitments for Funding Year 2011

Funding Year 2011. USAC will release FY2011 Wave 44 Funding Commitment Decision Letters (FCDLs) April 24. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90% and denials at 79% and below. As of April 20, FY2011 commitments total over $2.15 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.

Network Maintenance Reminder

The USAC website was taken down for maintenance at 8:00 pm EDT Thursday, April 19 and will be unavailable until 8:00 am EDT Monday, April 23. Both the static pages and the Apply Online and search functions will be unavailable.

We apologize in advance for any inconvenience.

Service Provider Training Reminder

We have started waiting lists for both service provider training sessions; we will admit additional attendees from those lists as space becomes available. If you find that you cannot attend a session, please cancel your registration by sending USAC an email. This will allow us to open a space for someone else.

To register for a training session and/or to find information on hotel reservations, refer to the Upcoming Events section of the Trainings and Outreach page on the USAC website.

FY2012 Extended Deadline for FCC Form 471 Certifications and Item 21 Attachments

USAC has issued two sets of letters this 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 were issued on Thursday, April 19; appropriate actions must be taken on or before Wednesday, May 9.

• If you do not certify your FCC Form 471 on or before May 9, 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 9, 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 Form 471 With No Certification

USAC issued just under 990 letters to applicants that filed an FY2012 FCC Form 471 online on or before 11:59 pm EDT March 20, 2012 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 9 for those forms to be considered in-window.

Remember that 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.

Remember that 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 on the Certify Complete button in the Form 471 column.
• Enter your FCC Form 471 application number and security code and click on 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 on 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 on the Certify Complete button in the Form 471 column.
• Enter your FCC Form 471 application number and security code and click on 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 Form 471 Application Status tool. Once 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 issued just under 7,600 letters to applicants that filed an FCC Form 471 received or postmarked on or before 11:59 pm EDT on March 20 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 9 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 associated with the Item 21 attachment was not clearly identified.

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 to verify that we have received them. However, you should check your submission to make sure it includes Item 21 attachments for ALL the FRNs on your Form 471 and that all the associated FRNs are clearly identified.

If you have not yet submitted your Item 21 attachments, you must do so on or before May 9 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 Form 471 Application Status tool shows the status of an FCC Form 471, not the status of each FRN on that form.

News Briefs from SLD – 4/13/2012

Commitments for Funding Years 2011 and 2010

Funding Year 2011. USAC will release FY2011 Wave 43 Funding Commitment Decision Letters (FCDLs) April 17. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90% and denials at 79% and below. As of April 13, FY2011 commitments total over $2.14 billion.

Funding Year 2010. USAC will release FY2010 Wave 94 FCDLs April 18. This wave can include commitments for approved Priority 2 services at all discount levels. As of April 13, FY2010 commitments total just over $3.05 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.

Network Maintenance Update

The USAC website will be taken down for maintenance from 8:00 am EDT on Friday, April 20 to 8:00 am EDT on Monday, April 23. Both the static pages and the Apply Online and search functions will be unavailable. Users should plan to finish any online activities on Thursday, April 19 or wait until Monday, April 23 to start them.

We apologize in advance for any inconvenience.

Service Provider Training Reminder

The service provider training session in Atlanta is full; we have started a waiting list and will admit additional attendees from that list as spaces become available. If you find that you cannot attend this session, please cancel your registration by sending USAC an email. This will allow us to open a space for someone else.

There is still space available in Los Angeles and we continue to confirm registrations for that session.

To register for a training session and/or to find information on hotel reservations, refer to the Training Sessions and Presentations page on the USAC website.

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 ask for your email address or fax number, and will 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 Deadlines for Information Requests 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 Form 470 application number
• Changing category of service.

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 Form 471 Application 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, 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.