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Minutes for January 12, 2005 Service Provider Call

A.

FUNDING COMMITMENTS

The President signed HR 5419 on December 23, 2004, which is the bill temporarily suspending the Antideficiency Act as it applies to the Universal Service Fund until next December.

FY2003
FY2003 – Letters in Wave 36 were issued on December 27, 2004; commitments on this Wave totaled $23.1 million.

FY2004
FY2004 – Letters in Wave 11 were issued on January 11, 2005; commitments on this Wave totaled $510.0 million.

 

 

B.

CLOSING OF THE FORM 471 FILING WINDOW [February 18th at 11:59 P.M. EST]

  • Contracts need to be signed by both parties prior to the filing of a completed Form 471 and by the close of the filing window.
  • The Item 21 Attachment needs to be filed in order to process a Form 471 application. Although SLD encourages applicants to file the Item 21 Attachment with their Form 471 application, the rules do not require that an Item 21 Attachment be received by the close of the funding window in order to complete the application.
  • Form 470 Certification has to be in by the close of the window if the Form 471 relies on Form 470.
C.

APPROVED FY2004 INTERNAL CONNECTIONS REQUESTS TO BE FUNDED TO 81%

Wave 11 for Funding Year 2004 was issued on Tuesday, January 11, 2005. This wave included funding for approved Internal Connections requests down to the 81% discount level. With this wave, the SLD expects to resume issuing biweekly funding commitment decisions on FY2004 applications.

There is no decision yet on whether funds will be sufficient to fully fund Internal Connections requests with discount percentages below 81%. Further information on funding requests for Internal Connections below 81% will be posted to this web site as it becomes available.

The issuance of this wave is consistent with HR 5419, which President Bush has signed into law. Among other things, this law provides a temporary suspension (through December 31, 2005) of the Antideficiency Act as applied to the Universal Service Fund.

We won’t commit over $2.4 billion for FY2004 as far as we know now.

 

 

D.  

FORM 474.ASP UPDATE

1. Changing Versions—

SLD anticipates that the Form 474.asp replacement of the Form 474 Online PDF will take place in the next week. We received positive feedback from the service provider test group and we thank you for your participation. We have made some changes to reflect various comments and we will be providing an informational page to users of this new format.


2. Feedback for Applicant Certifications on SPIs

SLD appreciates your feedback. We are recommending that these certifications not be required on the Form 474. More information will be available after the January 2005 USAC Board meeting.

 

 

E. 

FORMS 472/473/474 UPDATE

SLD is finalizing the certifications for the Forms 472 and 473 and anticipates providing the final revisions to the FCC this week.

 

 

F.

ONLINE ITEM 21

We have added an Item 21 Attachment prototype system to the features available as a part of the Eligible Products Database pilot program, and have provided two training sessions about this prototype. We are encouraging applicants to work closely with the service provider they have selected during the competitive bidding process to submit an Item 21 Attachment that is as complete as possible. (Yes, we not only allow, but expect and encourage applicants and the competitively selected service provider to work closely together in providing the Item 21 Attachment. Some service providers might even wish to provide an Item 21 Attachment using the online prototype system as a customer service for their applicants.)

We have recently updated information on our web site about the Item 21 Attachment to provide specific wording that applicants can include if their funding request includes components for which we typically require further information. Examples include remote access equipment, equipment that can be used to set up a virtual private network, and file servers (i.e., obtaining the specific use for the file server).

Our prototype Item 21 Attachment system implements a similar approach. We advise applicants that they may wish to provide this type of information as part of their Item 21 Attachment, and provide a feature so that applicants are able to easily provide this information when they use the online prototype system.

   

G.

OTHER

SERVICE PROVIDER CONFERENCE CALL SCHEDULE

The 2005 Service Provider Conference Call Schedule is posted to the website. At this time, no training schedule has been established for this year.

ELIGIBLE PRODUCTS DATABASE

Twenty-some manufacturers are participating in our pilot program for the Eligible Products Database, and SLD has about 3,000 entries in the database at this time. Our initial review of manufacturer submissions was in most cases based only the information submitted to us. We have attempted to review some of these entries more thoroughly over the past month, and in some cases have been in contact (or will be in contact) with manufacturers with questions or suggestions about some of the data records. For example, we might feel that a description is not sufficiently complete for users of the database to understand what a product is. In addition, the system relies on manufacturers specifying a Product Type for each record, such as file server, switch, PBX, etc. In some cases, we are suggesting that the product might be better described with a different Product Type than that originally indicated by the manufacturer. Finally, we are asking for assistance in understanding whether a product has some of the features we are highlighting as part of our online Item 21 Attachment prototype, such as remote access and virtual private network capability.

 

 

H.

GENERAL QUESTIONS RECEIVED BY E-MAIL

Q.

In reviewing the guidance on the SLD website regarding providing service before July 1 of the funding year it reads:

"If Priority 1 services (Telecommunications Services and Internet Access) will begin on or shortly after July 1 of a funding year, the service provider in some cases may need to undertake some construction and installation prior to the beginning of that funding year.

Within the limitations indicated below, the infrastructure costs of a service provider can be deemed to be delivered at the same time that the associated Priority 1 services begin. That is, if services begin on July 1, then the delivery of service provider infrastructure necessary for those services can be considered as also delivered on July 1.

There are four principal conditions that must be met in order for the SLD to provide discounts in a funding year for Priority 1 infrastructure costs incurred prior to that funding year.

1. Initiation of installation cannot take place before selection of the service provider pursuant to a posted Form 470 and in any event no earlier than six months prior to July 1 of the funding year.

2. The Priority 1 service must depend on the installation of the infrastructure.

3. The underlying Priority 1 service cannot have a service start date prior to July 1 of the funding year.

4. No invoices can be dated prior to July 1 of the funding year."

This information however, doesn't mention training at all. If we are to follow the above rules and install the system early so it is ready for use on July 1, are we permitted to do basic system admin training prior to July 1 as well--assuming that the 4 conditions above are met? According to the Eligible Services list, the training needs to be coincident with installation. Please advise. Thanks! Meghan Clark, EChalk.

R. The FCC decision with respect to this question did not include training within its scope; therefore, SLD cannot provide any further guidance at this time. In order to seek guidance on this issue, it would be helpful to receive further information on the type of training services being provided, for what purposes, and to whom.

 

Q.

1. SLD's website states that SP Invoices will be paid within 60 days of submission to SLD. When I call to check on invoices I am told that the timeline is 90 days. Which is it?

R. SLD is committed to processing invoices as promptly as possible. We will be working on improving the information provided to customers.

2. Does the SLD have a policy of paying invoices on a timely basis (at 60 or 90 days) or is the policy that invoices will only be paid once the review process is complete, regardless of how long it takes.

R. SLD is committed to paying invoices promptly on a first-in/first-out basis. The invoicing department has been backlogged and is working on decreasing the backlog and improving the payment of invoices as well as the information made available to service providers and applicants.

3. All of the invoices that we have submitted to the SLD are for recurring monthly charges for the same services each month. Every time we submit an invoice the SLD flags the invoice as "Requires Review" and then asks us the same questions each month for the same services? This seems like a waste of the SLD and SP's time and results in a backlog of invoices under review.

R. Thank you for your comments. This issue is currently under consideration.

4. What is the SLD doing to streamline the invoice review process. We are rarely paid our invoices in less then 90 days and in most cases payment is made over 100+ days after submission and only have much follow-up.

R. SLD is committed to improving its invoice review and approval process. Various initiatives are under review to streamline and improve the communication and approval of invoices.

5. I can never get a live person when calling the invoice Hot Line and when I leave a message it can take them up to 5 days to call me back, even on the most basic questions. When I do talk with someone, they say they swapped with calls and backlogged on callbacks. What is being done to address this issue. John Day, PDS Guam

R. The SLD is slated to review the escalation procedures for handling of invoicing calls and responses. SLD will keep you apprised of progress and changes made to this process.

 

Q. Regarding Applicant Form 470 or RFP information, what is the position of the FCC or USAC that an applicant that calls for a specific manufacture (no equals) is limiting the competitive bidding process?

Example:

Applicant Form 470 asks for bids only from Brand X, even though there are other equivalent brands available.

Applicant RFP indicates a specific manufacture certification, "service provider must be DDJF certified".

Obviously, there are many valid reasons for an applicant to desire a specific product or service. The question here is does that specific (limiting) demand, limit the competitive bidding process? Robert Rivera, Spectrum

R. An applicant may request a specific brand product depending on its network infrastructure and technology plan and require certain certifications as long as they are vendor-neutral and industry-standard and comply with local and state procurement laws.

   

REMINDER: PLEASE E-MAIL YOUR QUESTIONS FOR THE SERVICE PROVIDER CALL TO SUBMIT A QUESTION BY COB ON FRIDAY, February 4, 2005. PLEASE REMEMBER TO CHOOSE THE TOPIC “SERVICE PROVIDER CONFERENCE CALL” SO THAT YOUR QUESTION IS ROUTED CORRECTLY. ALSO, PLEASE WATCH THE SLD WEBSITE FOR ANY PROGRAM UPDATES.

IF YOUR QUESTION IS RELATED TO INVOICING, PLEASE HIGHLIGHT THAT SUBQUESTION SO THAT IT IS ROUTED DIRECTLY TO OUR INVOICING TEAM. ALSO, PLEASE WATCH THESLD WEBSITE FOR ANY PROGRAM UPDATES.

Content Last Modified: March 8, 2005