Oct. 5, 2012 Weekly SLD News Briefs

TIP OF THE WEEK: Plan to submit invoices (BEAR Forms and SPI Forms) for FY2011 recurring services by the invoice deadline of October 29. You can get information on invoicing from the September 28 SL News Brief and from the invoicing guidance (Applicant Step 7 and Service Provider Step 5) on the USAC website.

Commitments for Funding Years 2012 and 2011

Funding Year 2012. USAC will release FY2012 Wave 14 Funding Commitment Decision Letters (FCDLs) October 9. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90% and denials at 89% and below. As of October 5, FY2012 commitments total over $1.28 billion.

Funding Year 2011. USAC will release FY2011 Wave 64 FCDLs October 10. This wave includes commitments for approved Priority 2 requests at 88% and above and denials at 87% and below. As of October 5, FY2011 commitments total over $2.40 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. 

SERVICE PROVIDERS: Getting Ready For FY2013

Although we are a few months away from the FY2013 application filing window, applicants and service providers should be working on any remaining issues from earlier funding years. Below are some tips for service providers; in the September 14 SL News Brief we provided tips for applicants.

File FCC Forms 473 for FY2011 and FY2012 if you have not already done so.

FCC Form 473, Service Provider Annual Certification (SPAC) Form, must be filed each funding year before invoices for that funding year can be paid.

If you have not yet filed this form for one or more funding years, you should do so as soon as possible. If you have more than one Service Provider Identification Number (SPIN), remember that you must file a separate SPAC Form for each SPIN. If you have filed the form but you are not sure if USAC has successfully processed it, search for your SPIN in the SPIN Contact Search tool and review the list of funding years in the “SPAC Filed” (far right-hand) column of the search results.

SPAC Forms must be filed on paper using the version dated April 2007.

Verify that USAC has your current information on FCC Form 498.

Service providers file FCC Form 498, Service Provider Identification Number (SPIN) and General Contact Information Form, to get a SPIN and to provide USAC with correct contact and remittance information. The original FCC Form 498 must be filed on paper but you can update the form using the E-file System.

It is important to keep the information on this form current.

  • To review the contact information on your FCC Form 498 that is available to applicants, go to the SPIN Contact Search tool.
  • To review other information on your form, you will have to log in to the E-file System with your E-cert ID and password. If you need help, call the USAC Operations Center at 1-888-641-8722 (choose the “FCC Form 498” option) for assistance.

Note that in some cases you may have to file a revision to your FCC Form 498 on paper before USAC can issue an E-cert ID and password. Once you are able to log in to the E-file System, your company officer of record can update your information online.

Finish filing FCC Forms 474 (SPIs) for FY2011 recurring services.

The invoicing deadline for FY2011 recurring services is October 29, 2012 – just a few weeks away. We generally receive a large number of invoices – both FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form, and FCC Form 474, Service Provider Invoice (SPI) Form – close to the invoicing deadline, which results in longer processing times and may necessitate filing an invoice deadline extension request if an invoice is rejected.

All service providers can file SPI Forms online. Service providers that invoice USAC frequently and would like to file invoices electronically can follow the instructions for setting up electronic invoicing. Service providers that file SPI Forms on paper must use the April 2007 version of the form.

Finish approving FCC Forms 472 (BEARs) for FY2011 recurring services.

Whether applicants file BEAR Forms online or on paper, you must approve those forms before USAC can review them. Following are some tips to assist you in the approval process:

  • Tell your customers how long it will take you to review and approve BEAR Forms. Applicants that file BEAR Forms often wait until close to the USAC invoicing deadline to file online or to send paper BEAR Forms to service providers for approval. If you clearly communicate to your customers how much lead time you need to review and approve the forms before the deadline, both you and your customers will have a much better chance of meeting the invoicing deadline and avoid having to request an invoice deadline extension.
  • Approve BEAR Forms online. Service providers with an E-cert ID and a password can approve BEAR Forms online. If you don’t know your E-cert ID and password, call the USAC Operations Center (see above) for assistance.
  • If you are approving BEAR Forms online, log in to the E-file System once each week to see if any forms are awaiting your approval. USAC sends an email to the service provider when a BEAR Form is filed online, but service providers are not required to wait for an email to arrive before approving a BEAR Form. If you log in to the E-file System once a week, you will be able to review BEAR Forms in a timely manner.
  • If the applicant files on paper, check the footer date on your signature page. If the applicant does not submit all four pages using the April 2007 version of the form, USAC will request a new submission and the processing of the form can be delayed.
  • Use your current contact information and update where necessary. If USAC has questions about your invoice, we will use the contact information on the invoice to get in touch with you. If we can’t get answers to our questions, your invoice may be denied and you will have to resubmit.
  • Don’t file duplicate invoices or line items. First check your customer bills (the bills sent by the service provider to the customer) and any previous invoices so that you invoice USAC only for amounts that have not yet been invoiced.

Check the status of FY2011 non-recurring services.

September 30 following the funding year is generally the deadline for delivery and installation of non-recurring services. While September 30, 2012 is the deadline for most FY2011 non-recurring services, it can also be the extended deadline for services from other funding years.

Again, here are some tips:

  • Check the expiration date on your contract and, if necessary, (1) work with your customer to extend your contract and (2) ask your customer to notify USAC of the new contract expiration date using an FCC Form 500. USAC will not pay for services delivered after the contract expiration date on file or after the original (or extended) service delivery deadline. Note, however, that if September 30 was your service delivery deadline and you or your customer did not request an extension of this deadline by that date, it is too late to do so.
  • If September 30, 2012 was the last date to receive non-recurring services, then January 28, 2013 is the last day to invoice USAC for those services. Don’t wait until the last minute to gather customer bills and prepare SPI Forms or approve BEAR Forms.

Verify that your customers have submitted FCC Forms 486 for FY2012.

In general, if an FCDL featuring a funded Funding Request Number (FRN) is dated on or before July 1 and the service start date is July 1, the deadline to file FCC Form 486 for that FRN is October 29. (For FY2012, because the first wave of FCDLs was issued July 10, 2012, the earliest deadline for filing an FCC Form 486 for FY2012 is November 7.) Applicants that wait until the last minute to file an FCC Form 486 may cause delays in processing and review at USAC.

Applicants that wait until the last minute are also likely to get confused by USAC’s Form 486 Urgent Reminder Letter. USAC now sends out reminder letters to applicants that miss the FCC Form 486 deadline because they either:

  • fail to file an FCC Form 486 by the deadline, or
  • file an FCC Form 486 online and then fail to certify it by the deadline.

USAC uses (1) the service start date reported in Item 19 of the FCC Form 471 and (2) the FCDL date to determine when a reminder letter should be sent. USAC tries to identify late filers as soon as possible after the calculated FCC Form 486 filing deadline date so that these forms can be filed or certified promptly. Applicants that wait until the last minute to file or certify a form will probably receive one of these letters and become concerned that USAC has not received their form or their certification.

Because USAC will not pay invoices until an FCC Form 486 is on file, it is important to check with your customers to make sure that they have filed the form. Once USAC has reviewed and approved the form, USAC will issue a Form 486 Notification Letter to the service provider and the applicant.