E-rate applicants preparing for 2017 should prepare for another bumpy ride using the E-rate Portal, EPC. Current users know that struggles with the system have not abated and, in some ways, have only gotten worse during the application review process (PIA). USAC’s attempts at streamlining the E-rate have actually slowed things down and made it harder. Case in point, USAC now is using two systems to process forms from multiple funding years: the new (and under development) EPC system, and the Legacy system, “old Bessie”, for payments and submissions prior to FY2016. It’s no wonder that the pace of E-rate funding commitments is at an historically low level.
To navigate this complex mess, E-rate applicants need to be well-informed and prepared for the challenges that lie ahead. Here are a few important tips that can help:
- Applicant users are reporting 486 “disappearing FRN” issues as they try to submit the Form 486 for FY2016 in the EPC system. To verify if EPC may have eaten your Form 486, it is best to recheck any Form 486 that may not be processed quickly. If pending for more than 24 hours, there is a good chance your form lost its FRNs. Applicants should delete the Form 486 with the disappearing FRNs and resubmit.
- Many applicants have applications with a “Wave Ready” status, but, due to an unresolved EPC system error, USAC has been unable to issue funding commitment letters. Applicants with pending FY2016 applications and/or who have not received any Program Integrity Assurance (PIA) questions may need to request these projects again for FY2017.
- Applicants should be aware that PIA for FY2016 is in EPC and is not received via email as in prior years. PIA in EPC requires applicants to answer questions, upload documents and respond to Item 21 line item changes in USAC generated spreadsheets by site location. Once an applicant answers and submits a PIA response in EPC that PIA Question and Answer is available, but difficult to find. Applicants are advised to maintain copies of any PIA questions and responses.
- Applicants submitting Form 470 applications along with RFPs should also be aware that currently EPC has difficulty allowing users to upload any RFP addendums. USAC has not provided guidance regarding any alternative options other than to try and try again. Eventually, after multiple attempts, you may get to upload the addendum. Applicants should follow their local competitive rules and procedures for distributing RFPS addendums and updates.
- USAC will be overriding applicant portal entity information sometime in the very near future. When this occurs, any changes made during PIA will override the current data in EPC. If you have made any updates to your applicant entity portal, these will be lost. USAC has advised that notification will occur before the Entity Override and that USAC will conduct a reach out effort to applicants who have made changes.
- At this time, it is unclear whether the FY2016 site and entity data will be maintained by USAC for invoicing and audit purposes. For any applicant with site moves, additions and mergers, it is a best practice to maintain a list of those changes, outside of the EPC portal. It is also best to document the date of any site changes.
- It is unclear if the Form 471 funding request portal will still require applicants to adjust funding requests to meet the C2 budget allotment for a site location. Many applicants have struggled with USAC’s requirement that they remove eligible line items, adjust units, adjust quantities and/or change the price of items simply to reduce the funding request to the C2 budget allotment. Not only does this make the Form 471 process more difficult, but it also complicates invoicing and auditing.
- If using a multi-year service agreement that included contract extensions, the current EPC system does not allow applicants to update the existing contract information. You can adjust the contract end date as you prepare the funding request, but you should continue to reference the original EPC assigned contract number. If you create a new contract in order to include the extension documentation, the SLD may view this as a new contract and not as a contract that was reviewed in a prior year.
