E-Rate Central News for the Week
August 30, 2010
The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.
Funding Status
Wave 15 for FY 2010 will be released on Tuesday, August 31st, for $26.7 million. Funding is being provided for Priority 2 services at the 90% discount level. Cumulative funding for FY 2010 will be $1.16 billion. No funding for FY 2009 is scheduled.
E-Rate Updates and Reminders
SLD Update on the PQA Program:
The SLD issued a Special Edition News Brief last Friday formally announcing the Payment Quality Assurance ("PQA") Program that had been initiated the first week in August. As discussed in our newsletter of August 16th, this is a revised assessment program — that the SLD is careful not to label as an "audit," but should be treated as such — required under the Improper Payments Information Act ("IPIA"). Over the course of a year, the program will review approximately 720 randomly selected invoice payments.
The announcement was sent to the SLD's News Brief e-mail distribution list but, as of last weekend, was not posted on the SLD's Web site. The PQA News Brief is available on the E-Rate Central site. Earlier, and somewhat briefer, information on the PQA program is posted in the Latest News section on the SLD's Web site.
Service Provider EFT Deadline:
As of Tuesday, August 31st, all USAC payments to service providers will be made by electronic funds transfer ("EFT"). USAC has been actively contacting providers whose SPIN information has not been updated to accept electronic payments; those who haven't won't get paid. Applicants who have filed BEARs associated with these vendors are unlikely to be paid until the vendors' Form 498s are updated.
Status of FCC E-Rate Program Revisions:
Comments and reply comments on the FCC's broad E-rate NPRM, on eligible services, on updated CIPA regulations, on community use of school Internet facilities, and on proposed revisions to the Form 470 and 471 have all been filed. If any E-rate changes are to be made effective for FY 2011, the most likely date for an FCC order would correspond with the FCC's next open meeting rescheduled for September 23rd.
SLD E-Rate Training for Applicants:
This fall, the SLD will again be holding training sessions around the country. The schedule is as follows:
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Washington, DC |
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September 30, 2010 (closed) |
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Newark, NJ |
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October 7, 2010 |
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Minneapolis, MN |
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October 12, 2010 |
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Los Angeles, CA |
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October 14, 2010 (closed) |
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Kansas City, MO |
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October 19, 2010 |
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Jacksonville, FL |
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October 21, 2010 |
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Portland, OR |
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October 28, 2010 |
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Dallas/Fort Worth, TX |
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November 2, 2010 |
Workshop and hotel registration information is available on the SLD Web site.
The SLD's August 27th News Brief is Part 1 of a series on service substitutions.
An applicant should request a service substitution whenever the product or service the applicant wants to utilize is different from the one that was approved for funding as described in the applicant's original Item 21 attachment (perhaps as modified or expanded during the PIA review process).
Two basic principles apply to service substitutions, namely:
- The new product or service must provide the same functionality as the old one. It must fall into the same category of service and must be descriptively covered by a valid Form 470. This News Brief (and a portion of the next) provides examples of acceptable service substitutions.
- Although the new service may cost more than the originally funded service, funding is limited to the amount of the original award.
Technically, USAC will initiate its own service substitution analysis whenever it finds that an invoice has been submitted for an unapproved product or service, and will approve that invoice if the change meets all substitution requirements.
Any service change made without formally requesting and receiving approval for a service substitution, however, places an applicant at risk that a subsequent invoice will be rejected (or, perhaps worse, will be approved but be subjected to a future COMAD and a demand for repayment).
While it is tempting not to file a service substitution request for a simple change (e.g., when a Model 100 has been phased out and replaced by a Model 110), the safest course of action is to always file a substitution request.
Additional information can be found on the SLD Web site under Service Substitutions.
