On August 26th, USAC modified FCC Form 470 in the E-rate Productivity Center (“EPC”) that must be used for FY2018 funding and beyond. The new FCC Form 470 includes what USAC is calling “simplified drop-down options” from which the applicant can select eligible services for which they would like to seek bids. Notably, this is the only change to the FCC Form 470; the amount and type of information that applicants are required to submit and certify when completing FCC Form 470 through EPC will not change.
So what does the change to FCC Form 470 mean in practical terms? Generally speaking, it means that the E-rate application process will require the submission of much more granular information on the services for which applicants would like to seek bids. For example, an applicant must formulate the details of its proposed connectivity solution, and then specify each component of the service at the time FCC Form 470 is filed. Unfortunately, by moving away from a process where the applicant was able to identify its desired baseline service metrics and allow bidders to develop connectivity solutions to meet this baseline, the new system puts the burden on the applicant to determine the technical details of how it wants service providers to meet its baseline service metrics and may limit the ability of service providers to suggest more efficient means of achieving the same connectivity goals.
We encourage applicants to review USAC’s new FCC Form 470 user guide that provides detailed information about how the change to the FCC Form 470 impacts the application process going forward.