A.

Funding Commitments

We plan to continue to issue funding commitments each week for FY2005 applications.

FY 2005

Wave 030 1/19/2006 $18.3 million
Wave 031 1/25/2006 $28.2 million
Wave 032 2/01/2006 $31.1 million
Wave 033 2/08/2006 $35.7 million

FY 2004

Wave 48A 01/18/2006 $849 thousand
Wave 48B 01/31/2006 $515 thousand
Wave 48C 02/07/2006 $654 thousand

FY2002

Wave 30T 01/24/2006 $ 0

Appeal waves can now be accessed through the updated Data Retrieval Tool (DRT). Appeal waves are designated by the letter "A" and a two-digit number. For example, "A04" is the fourth appeal wave run in a funding year. There is now a separate field for the appeal wave number in the DRT.

B.

Internal Connections Commitments for FY2005

USAC is still making commitments at the 90% discount level. We hope to be able to make commitments below this level soon. Please watch the website and the Schools and Libraries News Briefs for more information.

C.

Form 471 Application Filing Window Close
February 16, 2006 at 11:59 p.m. EST

The Form 471 application filing window closes next Thursday, February 16, 2006 at 11:59 p.m. EST. Applicants are being encouraged to do the following:

• File as early as possible.
• Certify forms online.
• Work with their service providers to prepare Item 21 Attachments, file them as soon as possible, and share the filed attachments with their service providers.
• Maintain documentation.
• Follow program rules.

More details are provided in this week's News Brief and in the various guidance documents on the website.

D.

Invoicing Update

Payments for the month of January totaled $128,478,517.12 against requests for $172M. In total, 5,843 invoices were processed for 1,336 service providers. This represented 24,792 lines in December with 86% being completed within 30 days. Only 5% of the lines paid were in process over 90 days.

There are now 375 in-process lines over 90 days. With only 3,507 lines in process, those over 90 days comprise less than 11% of the total.

A new initiative was launched to improve the invoice process. BEAR Forms that feature incorrect or incomplete information now pass without payment in the same manner as SPI Forms. This initiative has resulted in the processing of over 300 invoices in process without further delay. We are happy to report that there are no BEAR Forms waiting for customer contact because of these types of issues.

We are looking for ways to reduce the decision-making time for invoices to less than 30 days. Support to document claims for reimbursement is available. Another initiative, in this regard, is to reduce the time to wait for information from the applicant and/or service provider after contact has been initiated. We look to utilize two modes of contact, such as email and fax, in our first contact for information. If no response is received within 7 days, we will close the request and process with the available information. All contacts will clearly indicate the time to respond. Extensions for time to respond will be held to a tighter standard with clear times for delivery indicated. We do not plan on more than 14 days interaction before a decision is made with the available documentation. Any invoice denied can be re-invoiced within the normal invoice deadline period after corrections have been made.

E.

Other

We will be doing a survey on the NewsBrief not too long after the window closes in order to find out what has been useful and what can be improved. Please feel free to comment.

F.

General Questions Received by E-mail

Questions are due on the Friday before the Service Provider Call. This gives USAC a chance to do some research and provide accurate answers. There was not a problem with our online system for the last call; all but one of the questions were received the day before the call.

If you have questions on service eligibility issues that are specific to your situation and probably not of general interest, please send them to our services team via Submit a Question. (Choose the topic "Eligible Services" and the subtopic "I have reviewed the SLD website and can't find the answer to my question regarding Eligible Services.")

Q. We have just found out that the new Form 471 online is not allowing applicants to key in a one-time (non-recurring) charge for maintenance. It forces you to enter the maintenance charges as monthly recurring. We presume that this change is in line with the new ESL which, in the introduction to the Basic Maintenance section states: "All requests in this category will be treated as recurring services with services to be delivered within July 1 to June 30 Funding Year."

Since many of these charges -- including Cisco Smartnet fees -- are annual charges, what restrictions, if any, are there on invoicing? For example, if a new service is not installed until midway through the year:

a) Can Smartnet-like fees be included in the purchase price and filed for as a part of Internal Connections (not Basic Maintenance)?

b) If such fees must be filed for separately as Basic Maintenance, can the full year charge be invoiced that year, or must it be allocated?

c) If allocation is required, then what happens the next year? Must the applicant allocate the remaining part of the first year and part of the next year?

A. USAC must treat Basic Maintenance as a recurring service; that is, Basic Maintenance must be received between July 1 and June 30 of the funding year. So, if a one-year Basic Maintenance contract begins January 1, 2007 and extends through December 31, 2007, the applicant would apply for discounts on six months of service in FY2006 and six months of service in FY2007.

Filing for Basic Maintenance as a recurring service does NOT mean that the service must be invoiced monthly. Invoicing will look at the terms of the contract and process invoices appropriately.

Q. We're running into a filed delimiter problem with the 470 download report when we try to convert the downloaded file to Excel. Some of the text fields are spilling over into the adjacent fields, causing offset problems for the rest of the records. this seems to occur on 470 records when the applicant had included commas and/or quotation marks in the original text, most commonly in the large Item 13 fields.

Does the SLD have a fix for this?

A. We will not be able to fix this for the current application cycle, but will put it on our list of system issues to try to fix for next year. The problem, of course, is that the results are returned in comma-delimited format, so commas within fields are a signal to the system to go on to the next field.

Q. Where do I find the column headings for each of the electronic notification files, such as the fsp, isr, 500, 486, etc.

I submitted this question through the general submit a question system, inquiry # 21-342898, 12/7/05 and have not yet received a reply. I even sent in an example of a form 500 electronic notification (1205205_05125404.500).

Can these formats be placed in the reference area?

A. This is a great suggestion. We will review the materials we use internally and adapt them for guidance material to be posted on the website.

Q. What is the purpose of having "submit a question" on the SLD website if questions are never answered? Replies that state "we are awaiting word" or "we have not had a response", over a month after submitting questions just don't cut it!

A. We are working on an escalation process that will identify both the person responsible for finding the answer and the person responsible for communicating the answer. In the short term, if you have waited two weeks without getting an answer, please forward the response email that contains your case number to the ombudsman, and we will find out why you have not gotten an answer. Please remember, though, that some questions go outside existing guidance, and answers may not be readily available.

Q. This is for Telecom WAN service. Today I heard a "telecom provider" at a customer bidding conference announce that his company would install 72 strands (pair) of fiber for a district and light one strand of fiber out of the 72 strands. He stated that, if he lit 1 strand, this would qualify the entire WAN for E-Rate. This is Giga-bit Ethernet speeds. The customer would light the other 71 strands/pairs of fiber, when and if they want. Is this accurate? Please explain.

A. The statement by the service provider is incorrect. In some cases USAC can pay for the up-front capital investment costs of a service provider, but only those costs attributable to the provision of eligible services. In this case, the entire service provided by the service provider would be vastly greater than the small portion attributable to eligible services. An applicant desiring such additional ineligible service can contract for it outside of E-rate, but the costs must be paid by the applicant with no attempt to seek E-rate funding.

In addition, the FCC has indicated that USAC is not to provide funding when an arrangement between applicant and service provider "reaches essentially the same result" as a prohibited WAN purchase by applicants. See the WAN Fact Sheet for more information. The entire arrangement described here may not meet the necessary standard for funding under this provision.

The Free Services Advisory indicates that if there is an attempt to subsidize the procurement of ineligible services through E-rate funds, an entire funding request or even an entire application can be in jeopardy. The arrangement described here appears to violate the guidance in the Free Services Advisory.