USAC New Briefs and Tip of the Week from Nov. 19, 2010

TIP OF THE WEEK: If you are filing your Form 470 certification on paper, be sure to include all of the Block 5 certification pages, not just the signature page. Your submission should include Items 19 through 31e.

Please note that USAC will not issue a News Brief next Friday, November 26, due to the Thanksgiving holiday. Also, the Client Service Bureau will be closed Thursday, November 25 and Friday, November 26.

Commitments for Funding Years 2010 and 2009

Funding Year 2010. USAC will release FY2010 Wave 27 Funding Commitment Decision Letters (FCDLs) November 23. This wave will include commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 85% and above. As of November 19, FY2010 commitments total over $1.67 billion.

Funding Year 2009. USAC will release FY2009 Wave 74 FCDLs November 24. This wave will include commitments for approved Priority 2 requests at 77% and above and denials at 76% and below. As of November 19, FY2009 commitments total over $2.78 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.

Guidance for FY2011 Form 470 Online Filers

Applicants that are filing Forms 470 now may benefit from some specific guidance for FY2011. In addition to the three topics below, current filers should review the information about Form 470 on the USAC website, including the Form 471 Instructions, Form 470 Filing Information, and the various documents linked to Step 3. Open a Competitive Bidding Process.

1. Select a technology plan certification for FY2011 even if you will not be required to have a technology plan.

According to the FCC’s Sixth Report and Order (FCC 10-175, released September 28, 2010), technology plans will not be required for Priority 1 services (Telecommunications Services and Internet Access) for FY2011 and future funding years. However, the current version of the online Form 470 does not allow applicants to select the “no technology plan needed” certification in Item 20 (indicated below with red arrows) if they have requested more than basic telephone service. These applicants filing the current form – online or on paper – must choose either the first or second technology plan certification (indicated below with green arrows) to file their forms.

USAC is aware of this limitation in the online system and offers the following guidance:

  • Applicants that will not be required to have a technology plan in FY2011 can check either the first or the second technology plan certification with the understanding that USAC will read these certifications to mean that they apply “if required by Commission rules.”

NOTE: The system USAC uses to enter data from Forms 470 filed on paper is essentially the same system used by online filers. If you file on paper and check a certification box that cannot be checked online, we must still reach out to you to get a “correction” before we can complete the data entry of your form. In other words, you cannot avoid this issue by filing on paper.

When the revised Form 470 becomes available, applicants will be able to select a technology plan certification that is consistent with the new technology plan rules.

Item 20 screen shot from Form 470 Interview version:

 Item 20 screen shot from Form 470 Expert version:

 

2. Applicants: Certify your filed Form 470 before the revised form becomes available.

Because USAC can only feature one version of a form, the current Form 470 – both online and paper – will be taken down from the USAC website when the revised Form 470 becomes available. This means that it will be very difficult for applicants to certify a Form 470 filed with the current form once that change has been effected.

Applicants filing the current version of the Form 470 are STRONGLY advised to certify the form immediately after it is filed:

  • If you file a Form 470 on paper, the certifications are part of the paper form. After your form has undergone any necessary problem resolution and data entry is successful, your form will be certified.
  • If you file a Form 470 online and you have a PIN, choose the “Certify Online” option at the bottom of the resulting screen and use your PIN to certify the form online. You should print the page that appears after you certify your form (or make a note of your CertID – a unique number issued by the online system) as proof of certification.
  • If you file a Form 470 online but you do not have a PIN, choose the “Certify On Paper” option at the bottom of the resulting screen. This option allows you to print a copy of your certification page to sign and submit to USAC in order to complete the certification process. Be sure to keep a copy of your signed page together with proof of submission.
  • If you already filed your form and need to certify it, choose the “Certify Complete” option at the bottom of the Form 470 column on the Apply Online page. Enter your 15-digit Form 470 application number and your security code (the first five digits of your 15-digit number), and then choose “Electronic Certification” if you have a PIN or “Paper Certification” if you don’t.

Applicants cannot cite an uncertified Form 470 on a Form 471 Block 5 funding request. In the past, lack of certification could be corrected during PIA review. This will be difficult for uncertified Forms 470 filed online using the current Form 470 after the revised form becomes available.

To help applicants remember to certify their Forms 470, USAC will be reminding to applicants that have not completed the certification process. The notifications will go out by email, or by fax or telephone if no email address is available.

3. Applicants: Designate a contact person who is knowledgeable about your Form 470 and/or RFP and able to respond to questions from potential bidders.

Applicants are reminded that they must be able to provide clear and accurate information about their needs to potential service providers so that these providers can prepare responsive bids. Generic or “encyclopedic” lists of products and services that do not reflect accurate information about the particular services requested violate program rules. Moreover, the contact person, technical contact person, or authorized person identified on the Form 470 must be available to provide more specific information if requested. Applicants are not relieved of this responsibility if they hire a consultant to run their competitive bidding process.

Service providers: If you have made repeated attempts to gather information necessary to prepare a responsive bid and have been unsuccessful (e.g., you received a statement that the applicant was happy with its current provider or you were unable to make a successful contact with the applicant representative identified on the Form 470), you can make a “Code 9” or “Whistleblower” call to USAC. Although USAC does not provide any status updates to the caller, USAC will investigate the information provided on the Whistleblower call and take appropriate action.

To make a Code 9 call: Call CSB at               1-888-203-8100        and press “9” at any time after the menu options start. You can also use the Submit a Question feature on the USAC website by choosing “Whistleblower/Code 9 Hotline” from the Topic Inquiry menu and providing the requested information. You can remain anonymous; however, keep in mind that USAC may need more information during the course of its investigation.