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The deadline for submitting SPIN change requests coincides with the deadline
for submitting applicant BEAR or vendor SPI invoices. For most FY 2002
recurring service FRNs, this deadline is October 28, 2003. It is critical,
therefore, to focus immediately on FRNs that will require SPIN changes,
particularly those that require preliminary BEAR filings.
Here are several examples of problems you may need to address to fully utilize
FY 2002 funding:
Example #1 – You were awarded $10,000 in discounts for telephone service from
Carrier A, but switched service to Carrier B in February 2003. If Carrier A did
not discount its bills, you will first need to file a BEAR to be reimbursed for
all Carrier A service discounts (say, $6,000). Once this BEAR has been
approved, (which normally takes at least 20 days) you must file an operational
SPIN change to switch the remaining $4,000 in funding to Carrier B. Once the
SPIN change is approved, you will have an additional 120 days to file a BEAR
covering the remaining service charges for carrier B.
Note that if you wait too long to file the BEAR for Carrier A, you will miss the
deadline for requesting a SPIN change. The only way to recover from this
situation is to file an invoice extension request; wait for extension approval;
file a SPIN change request; wait for change approval; then file a BEAR for
Carrier B services.
SPIN change and invoice extension guidance is available on the SLD Web site at:
SPIN Change Guidance and
Invoice Deadlines.
Example #2 – You were awarded $10,000 in discounts for telephone service from
Carrier A, but actually used an additional provider (that had not been on your
application) throughout the year. Assuming you were using $6,000 in service
discounts from Carrier A and $3,500 in service discounts from Carrier B, you
have two options.
If you had recognized the dual usage pattern earlier in the year, the best
course of action would be to request a FRN Split. This process, which is
initiated just like a SPIN change request, results in the creation of a new FRN
associated with Carrier B, with funding split between the original and new
FRNs. It requires an estimate of the proportion of funding to be assigned to
each vendor’s FRN. (In this case, for example, you might request that the
$6,250 in funding remain with the original FRN and $3,750 be assigned to the
new FRN.) While the FRN split request is pending, a BEAR can be filed for
Carrier A. Once the split is approved, you will receive a new Funding
Commitment Decision Letter with the new FRN identifier. You will then have to
file a Form 486 for the new FRN before filing a BEAR for Carrier B.
At this stage in of the year for FY 2002 FRNs, a better approach may be to treat
this situation just like Example #1 (i.e., file a BEAR for Carrier A, then file
a SPIN change request; and then file a BEAR for Carrier B).
Example #3 – An underlying assumption in the two previous examples is that the
two carriers were providing equivalent services. If the services were
different, a service substitution request may be required. Suppose, for
example, that the original funding request contemplated maintenance service
from Vendor A on Dell servers, but that maintenance was also provided by Vendor
B on Cisco routers. Assuming that the FRN funding was not fully utilized by
Vendor A, the SLD might agree that the router service provided by Vendor B was
an equivalent Internal Connections maintenance function. In this case, a
service substitution request can be combined with either Example #2 option
(i.e., a SPIN change or a FRN split).
Service substitution requests, in combination with SPIN change requests, are
discussed in subsection #4 for the SLD’s guidance on Operational SPIN Changes
at
SPIN Change Guidance.
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A revised Eligible Services List (“ESL”), dated October 10, 2003, is now
available online at
Eligible Services List
. As discussed two weeks ago, the new ESL reflects the following major changes:
(1) Newly Eligible – Alarm lines, cellular and paging service for virtually all
personnel, firewall service or servers, and Web hosting (but not Web creation)
are now eligible. Note, however, that this new eligibility is subject to the
important disclaimer “Effective for Fund Year 2004 and later years.”
(2) Newly Ineligible – Two services that had been funded in the past will be
treated as ineligible, again beginning in FY 2004. The most important one is
dark fiber – defined as “fiber optic cable for which the service provider has
not provided modulating electronics.” Funding for dark fiber services in FY
2003 and earlier years will be honored, but subsequent year funding –
presumably even on multi-year contracts – will not be awarded unless the
systems can be restructured into fully eligible WANs. The other newly
ineligible service is voice over IP (“VoIP”).
(3) Tightened Eligibility and/or Clarifications – The language on “Maintenance
and Technical Support” has been changed to stress that only “[b]asic
maintenance services are eligible.” Clarifications have also been made on the
eligibility of UPS, storage, and file server products.
The revised ESL contains a new section entitled “Special Eligibility Conditions”
(pp. 33-36) that should be reviewed by all applicants. It contains additional
discussions of such topics as cost allocation, eligible users and locations,
WAN leases, network servers, software, and storage, and technical services.
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On September 30, as is done at the end of every quarter, the SLD mailed
Quarterly E-Rate Payment Authorization Reports to every applicant for which
actual payments had been authorized during the period July 1 – September 30,
2003. Reports for this quarter and the next are normally the most critical to
review because they reflect most of the invoicing activity for the preceding
funding year (ending June 30, 2003).
In reviewing these reports, please note the following:
(1) Unlike most other SLD correspondence, the Quarterly E-Rate Payment
Authorization Reports are addressed to the person who signed the associated
Form 471 application, not to the person listed as the E-rate contact.
(2) The “Disbursement Authorization Date” shown is not the actual payment date.
It is the date on which the invoice was approved by the SLD. In the case of a
BEAR reimbursement, the invoice payment to the vendor is usually made about 20
days after the authorization date, and the vendor is then supposed to pass the
payment on to the applicant within 10 days of receiving the payment. Thus, the
applicant should start looking for a BEAR reimbursement payment from the vendor
about one month after the Disbursement Authorization Date.
(3) If the report shows a SPI authorization, it means that the supplier has
submitted an invoice for that FRN and is presumably discounting the applicant’s
service charges. The applicant should check that its bills are actually being
discounted.
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