FCC Cracks Down on USF Violations


As his tenure as FCC head winds down, Chairman Tom Wheeler’s enforcement priority appears to be universal service.  Over the past five weeks, the Commission has issued four decisions finding apparent violations of the USF rules, and has proposed heavy penalties in the Commission’s first-ever enforcement actions involving the rural health care program and the high-cost program.

FCC Seeks Comment on FY 2017 ESL

The FCC is seeking comment on the proposed eligible services list (ESL) for the E-rate program for funding year 2017.  Anyone may file comments on or before July 5, 2016 and reply comments on or before July 20, 2016. See the Public Notice for further details on filing requirements.

Top 5 Invoice Denial Reasons (and other notes)

In the monthly E-rate service provider call today, USAC reminded stakeholders of the top five denial reasons for invoices:
  1. Possible duplicate invoices
    Keep track of what invoices have already been submitted for particular funding requests.
  2. Total commitment paid
    Make sure that you are not seeking reimbursement for an amount greater than the total commitment.  If the commitment has already been paid in full, you cannot receive additional funding. Again, good recordkeeping is key here.
  3. Service provider not registered
    The service provider must have filed an FCC Form 473 before it can receive reimbursements.
  4. Bill date prior to Form 486 date
    Do not bill USAC before the date on the Form 486 that the service began.
  5. FCC Form 471 doesn't matchCheck to make you are referencing the correct FCC Form 471 and the correct funding request numbers (FRNs) on your invoice.

E-rate Funding Window Dates Announced

USAC announced this week that the Funding Year 2016 application window will open February 3 and close April 29.  If you've already signed up for your account in the new E-rate Productivity Center (EPC or the Portal), good for you!  If not, you should do so as soon as possible.

The Importance of Correctly Filing Your FCC Appeal


The FCC's last streamlined appeal order in 2015 raised the procedural bar for schools, libraries and service providers filing appeals with the FCC.

In its December 2015 Public Notice, the FCC, for the first time, dismissed E-rate appeals that did not follow its procedural filing requirements, even though the requirements are not new. Previously, the only procedural requirements typically enforced for E-rate were the filing deadlines mandated by FCC rules. However, the Commission signaled it might start cracking down on filing requirements when it released a PN in 2014 reminding filers of its filing requirements.
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