I love fall. October is objectively the best month of the year, being the month that I was born. But it also has football. And state fairs. And on one magical day, football at a state fair.
And I get it, you get so wrapped up in your Crunchy Fried Oinkers (yep) that it’s totally easy to forget about E-rate. And that’s a good thing. Matter of fact, if you are thinking about E-rate when you are downing fried pork n’ pickles before crowding into an 80-year-old stadium with 90,000 of your loudest pals, you should move on. This isn’t the article for you.
But. For those of us normals, we’ve got some work to do. E-rate lesson time: every funding request in the E-rate program has what we call a service delivery deadline. That is the date by which services must be delivered (or products purchased) in order to qualify for program discounts via a funding request approved for that funding year. Then we have an invoice deadline, which always comes up 120 days later. That’s the date by which we have to file our BEARs or SPIs in order to get paid. And that deadline has recently become one where the FCC isn’t messing around. You can get a single extension if you ask in time, but that’s it. The FCC has pretty much laid down the law when it comes to extending invoice deadlines out longer than the line for the Tilt-A-Whirl.
Now, here’s the thing. Recurring services (like most of our Category One stuff) always have a service delivery deadline of June 30. No extensions, no exceptions. That means that the invoice deadline for recurring services is always October 28. Right smack dab in the middle of crispy fried football season, and exactly two weeks from today.
Here’s the scary part. For Funding Year 2015, there are over 14,000 FRNs for recurring services which have been funded, have an invoice deadline of October 28, and have not been fully utilized. That’s over $60 million ($63.7M, to be precise.) Now, ultimately we know that not all those funds will be spent – there are always overages from estimated funding requests, projects which are abandoned or come in cheaper than anticipated, and so on – but still, I wager that there is a big chunk of that money that at risk of going undisbursed because folks let the deadline slip through their Oinker-greased fingers.
If you aren’t appropriately scared, that’s okay, because there’s more. Of those funding requests, about $36M (that’s 7,809 FRNs for 4,368 applicants) is for schools or libraries who have not yet completed the process for certifying and verifying their FCC Form 498, the new program Form where applicants supply the bank account number where they want the funds to be deposited. So assuming there are a number of those applicants who are planning on filing last minute BEARs (and there’s gotta be some, because about 94% of them haven’t picked an invoice method yet), they actually can’t get paid until they complete the 498. Yikes.
Now, you might be saying “yeah, but we do SPIs.” Good for you! Your service provider is about to miss a deadline. So while you may not be scrambling to get 498s and BEARs done before the deadline, it might be a good idea to double-check your contract to make sure they can’t try to yank back the discounts they gave you if and when they don’t get around to filing their Forms on time. Or, if you’re more friendly and less jaded than myself, you could send them a kindly-worded reminder that there’s an important deadline looming. Your choice.
So before we rush out to spar with our neighbors over the last box of pumpkin-spice-whatevertheheck, we might do well to double-check our E-rate applications for FY2015:
- If you file (or will ever file) BEARs, make sure the Form 498 has been processed and verified. Remember that filing it is not enough, there is also a separate verification step that has to happen before BEARs can process.
- If you’re good on the 498, make sure that all your invoicing activity is complete for FY2015 recurring services (regardless of payment method.)
- If you’re not good on either of the above and know you aren’t going to make it, or if you just barely squeak by but anything is still pending as of October 28, you need to request an invoice deadline extension. You’ll get another 120 days, but that deadline will be rapidly approaching about the time of the year where we’re all yammering on about old acquaintances being forgotten, so consider it a gift and get moving immediately.
So here’s to fall! And funding! Free fodder from Funds For Learning.