USAC’s Schools and Libraries Division hosts monthly service provider conference calls, providing information and guidance for vendors participating in the E-rate program. Highlights from February 6, 2013 service provider call include:
January 2013 Commitments
FY 2013 Form 471 Window Open
The Funding Year 2013 Form 471 filing window is now open and will continue through 11:59 EST on Thursday, March 14, 2013. The filing window will be open for 93 days. Thursday, February 14, 2013 is the last date on which a Form 470 may be filed in time to be referenced on a Funding Year 2013 request.
Invoicing Update
Payments for the month of January totaled $159.36 million against $241 million in requests. Invoices were submitted by 1,700 service providers, and 96% were processed within 30 days. The top invoice denial reasons for the month include:
Duplicate invoicing
Invoiced after the invoicing deadline
Total commitment paid
SPIN not registered
Billed outside of funding year
Q&A
A question arose about the E-rate eligibility of web hosting. USAC advised that the eligibility of web hosting services is defined in the FY 2013 Eligible Services List.
There was some discussion regarding free end-user devices bundled with Priority One services. To date, there has been no further guidance or clarification issued by the FCC on the topic. However, USAC stated that on a case-by-case basis as a part of funding request review, they will make a determination if the specific offer extended to an applicant satisfies the criteria outlined in the FCC’s Clarification Order (FCC DA 10-2355.) If USAC determines that the offer made to the applicant is in line with the conditions described in the Order, they can fund the application without requiring a cost-allocation of a fair value of the free bundled handsets.
The call referenced the following language in the Order:
Similarly, service providers cannot offer special equipment discounts or equipment with service arrangements to E-rate recipients that are not currently available to some other class of subscribers or segment of the public.25
25 For example, many cell phones are free or available to the general public at a discounted price with the purchase of a two-year service contract. Schools and libraries are free to take advantage of these deals, without cost-allocation, but cannot accept other equipment with service arrangements that are not otherwise available to some segment of the public or class of users. Therefore, a service provider may not offer free iPads to a school with the purchase of telecommunications or Internet access services eligible under E-rate, if such an arrangement is not currently available to the public or a designated class of subscribers.
Note: The information above is not the official minutes from the call, but simply notes from Funds For Learning. The official minutes for this call, as well as call minutes from previous months, can be found here.
