October 9, 2015

TIP OF THE WEEK: To be considered timely filed, an FY2014 FCC Form 472 (BEAR Form) for recurring services that you file online must be approved online by your service provider on or before October 28. A paper FCC Form 470 must include all four pages – with the service provider's approval on page 4 – and be mailed to USAC on or before October 28. If you are not sure you will meet this deadline, request an invoice deadline extension on or before October 28.

Commitments for Funding Years 2015 and 2014

Funding Year 2015. USAC will release Funding Year (FY) 2015 Wave 21 Funding Commitment Decision Letters (FCDLs) on October 16. This wave includes commitments for approved requests for all service types and at all discount levels. As of October 9, FY2015 commitments total over $2.27 billion.

Funding Year 2014. USAC will release Wave 68 FCDLs on October 19. This wave includes commitments for approved Priority 1 (Telecommunications Services and Internet Access) requests at all discount levels. As of October 9, FY2014 commitments total over $2.27 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.

Clarification about Uploading RFP Documents Post-certification

For FY2016, applicants are required to upload their RFP documents to FCC Forms 470 if they indicate on those forms that they are issuing an RFP. As a reminder, we use "RFP" and "RFP document" generically to refer to any bidding document that describes your project and requested services in more detail than that provided in the data entry fields on the FCC Form 470. An RFP document can be any formal bidding document – for example, an Invitation for Bid (IFB) or Request for Quote (RFQ) – or it could be any document issued as part of your competitive bidding process to provide more information to potential bidders.

We described the mechanism for uploading RFP documents before certification in previous SL News Briefs, and clarified the requirement to upload RFP documents in the August 28 SL News Brief. We also indicated that RFP documents can be uploaded to an FCC Form 470 even after it is certified and posted.

Note that, starting with FY2016, RFP documents issued AFTER an FCC Form 470 is certified and posted MUST be uploaded to that certified FCC Form 470. To comply with this requirement, applicants follow the guidance in the September 18 SL News Brief under the heading "Add an RFP Document" to upload RFP documents issued after the FCC Form 470 has been certified and posted. When applicants upload an RFP document, they must also indicate which services on the FCC Form 470 relate to the uploaded RFP document.

In the following cases, you must post a new FCC Form 470. You cannot simply add an RFP document to your existing certified FCC Form 470:

  • You did not indicate that you had an RFP before you certified your form. The option to add RFP documents to a certified form is only available if you already attached at least one RFP document to your form before you certified it.
  • You are making a significant or cardinal change to your service requests. You cannot simply upload an additional RPF document that results in a cardinal change to the scope of the procurement and then wait an additional 28 days.
  • You want to add new products and/or services. To post for new products and/or services, you can (1) file a new FCC Form 470 featuring only the new products and/or services or (2) cancel your existing form and post a new form featuring all of the products and/or services from both forms. In either situation, your 28-day waiting period for the products and/or services featured on the new FCC Form 470 does not start until you post the new form.

More on Entity Numbers

In the October 2 SL News Brief, we covered basic information on entity numbers. This week we will discuss specific situations where new entity numbers may be required.

In general, each separate school or library building should have an entity number. However, you should refer to the guidance below to determine whether to request an entity number.

Buildings located on the same campus

If several school or library buildings are located on the same campus – i.e., no public right-of-way crosses between the buildings – and all of the buildings are considered part of that school or library, you do not need a separate entity number for each building.

  • However, if one of the buildings serves multiple entities – for example, a separate cafeteria facility on a high school campus that functions as a central kitchen for all of the schools in the school district – that entity needs its own entity number regardless of whether the buildings are separated by a public right-of-way.
  • If several schools are located in the same building – for example, if a middle school and a high school share a building and they are considered separate schools by their state – each school should have its own entity number.

Single school with multiple locations

If one school has multiple locations (in other words, a school considered to be a single school by the state consists of multiple buildings separated by one or more public rights of way), each location can be identified as an "annex" in the school's profile in the E-rate Productivity Center (EPC). Annex is a new term for FY2016. Designating locations other than the main location as annexes removes the requirement for applicants to request a separate entity number and confirms that those other locations are not eligible for separate Category Two budgets.

School or library buildings under construction

A school or library building that is under construction can receive discounted services.

  • If the building is located on an existing campus, follow the guidance above.
  • If the state considers a school or library building under construction to be an existing entity (for example, a new building to house a library that now occupies a different building), the entity number from the original building carries over to the new building. You should update the contact information for the school or library in your school or library profile in EPC using the information on the USAC website on Entity Numbers as a guide.
  • If the state considers the building to be a new school or library, you should call the Client Service Bureau at (888) 203-8100 or Submit a Question to request a new entity number for that school or library building.

Non-instructional facilities

A non-instructional facility (NIF) is a school building without classrooms or a library building without public areas. (Some school NIFs contain one or more classrooms – see below for more information.) With some exceptions, every NIF must have an entity number.

  • A school or library NIF located on the same campus and serving only that school or library does not need a separate entity number.
  • An administrative office or wing located in a school or library is not considered a NIF but rather part of that school or library building.
  • Administrative offices that serve multiple schools may be located on the campus of an individual school. However, they are considered NIFs and should have their own entity numbers because they serve more than just the school on whose campus they are located (see above).
  • NIFs can be on property owned by a school district or library, or they may simply be rented space in a building such as a town hall or a commercial building.
  • Examples of school NIFs include – but are not limited to – administrative buildings, school bus barns and garages, cafeteria offices, and facilities associated with athletic activities.
  • Examples of library NIFs include – but are not limited to – administrative buildings, bookmobile garages, interlibrary loan facilities, and library technology centers.

In some cases, a school facility can be considered a NIF even though it has one or more classrooms. For example, a school district administrative building may have a classroom that is used by a specific group of students or by a population of students that changes from day to day. Even if a school NIF has one or more classrooms, it is still considered a NIF and is not eligible for a Category Two budget.


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