USAC Fall Applicant Training – Albuquerque, New Mexico October 13, 2015

“Change is Happening” was printed on the banner that was on stage with the speakers. Change was the
not-so-subtle topic of every song played prior to the start of the training. The theme of change was driven home in every presentation.

Are there changes? Yes. Things are different specifically EPC and some of the other attempts at streamlining. 

Are the changes as program-altering as say, the changes implemented last year? No, but things are different.

However, I concede that “Different is Happening” wouldn’t be a good slogan for the on stage banner. 

“Different” happens and it is important to discuss the differences as they occur. However it is equally important to understand what is not different in the midst of changes. To paraphrase one of the training presenters, the “building blocks of E-rate remain.” This is an important item to note.

Different – all forms and correspondence come through EPC

EPC will serve as a single location for our program activities. Applicants will use EPC to complete and certify forms, submit requests, receive notifications, review and respond to PIA questions, etc. 

Applicants will also have the opportunity to ask questions and receive answers in real time and effort to streamline applicant requests and questions. 

Surprisingly not mentioned were the abilities to add a profile picture to your account and also the opportunity to give other EPC users kudos.

Not Different – All The forms and correspondence.

All the forms you have grown to know and love are still there. All forms and applications (and their individual requirements/certifications) remain. The Forms 470, 471, 486, 500, etc. will still be required as applicable and there was no mention of any change to the existing forms. 

Applicants will still receive notifications for the items they received in the past. Applicants are still required to retain copies of all E-rate correspondence. When asked of uploading the right documents to EPC and having notification letters in the news section of EPC would satisfy the document retention requirements, the response was “your best bet is to keep everything.”

Different – further expanding access to broadband.

There are new options for E-rate funded special construction for new fiber. This was previously only available for the services but now also available for dark fiber and self-provisioned fiber. 

Also E-rate will now pay the full discount share of upfront special construction chargers in the first year. Applicants are allowed to pay their share of those upfront cost and installment payments for up to four years. 

If an applicant is seeking bids for dark fiber service they have to seek bids for lit fiber service also in order to compare the two and select the most cost-effective solution. 

Not different – cost-effective solutions.

Regardless of the services sought including the new fiber options, E-rate rules still require that applicants conduct fair and open competitive bidding process and select the most cost-effective bid. 

The fair and open competitive bidding process is a hallmark of the E-rate program and will remain something that USAC continues to validate via PIA, SRIR, and audits. 

Different – ACH payment of BEARs

Starting July 1, 2016 all BEARs will be paid via direct deposit into the applicants’ banking accounts. Payment will be issued twice-weekly and payment should be in the applicants bank account the next business day. This will greatly decrease the amount of time spent between approval of the bear form and the applicant receiving funds. However this will also increase the likelihood of receiving an invoice review.

Not different – BEAR submission requirements

You still cannot seek reimbursement on services not yet delivered, services that are not eligible, services billed to a party not on the Form 471, services delivered outside the funding year, etc. 

The sites listed as receiving services will still need to be listed on the Form 471 in the services will still need to be listed on the application and the Item 21.