COVID-19: FCC Order Extends Certain Program Deadlines Due to Coronovirus Pandemic

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In response to COVID-19, on April 1, the FCC released an Order (DA 20-364) that temporarily waives and extends several E-rate filing and service implementation deadlines and provides all program participants an automatic 30-day extension to respond to USAC information requests related to pending appeals, invoices, FCC Form 500 requests, and audits.

Here is a list of the affected program and response deadlines due to COVID-19:

Extending the timeframe for responding to USAC information requests

  • USAC will provide all program participants with an automatic 30-day extension to respond to information requests related to:
    • pending USAC appeals;
    • invoices;
    • pending FCC Form 500 requests, including service substitutions, Service Provider Identification Number (SPIN) changes, or funding request cancellation requests; and
    • audits, including the Beneficiary and Contributor Audit Program (BCAP) and Payment Quality Assurance (PQA).
  • USAC will also provide all program participants with an additional, automatic 30-day extension for PIA requests.
  • This relief will apply to all information requests issued between March 11, 2020 and May 22, 2020, regardless of the funding year for which those requests relate.

Waiver of the invoice filing deadline

  • For all applicants and service providers whose invoice deadline falls between March 11, 2020, and October 28, 2020 (October 28 is the invoice deadline for FY2019 recurring services and special construction), the invoice deadline is automatically extended for 120 days regardless of whether the applicant or service provider already requested an extension of the deadline.
  • USAC will provide an additional 30-day extension to applicants or service providers that file an invoice deadline extension request with an explanation of, and documentation supporting, their entities’ inability to file invoices at that time (e.g., dates of closure, difficulty securing the appropriate resources, etc.)

Waiver of the service delivery deadlines for non-recurring services and special construction

  • The September 30, 2020 service delivery deadline for non-recurring services for FY2019 is waived and extended to September 30, 2021.
  • The June 30, 2020 special construction service delivery deadline for all FY2019 applicants, as well as for FY2018 applicants that already received a one-year extension, is waived and extended to June 30, 2021.

Waiver of deadline for appeals and requests for waiver

  • The deadline to file appeals with USAC or the FCC, or waiver requests with the FCC, is now doubled to 120 days after the date of the USAC decision for program participants whose 60-day filing deadline would ordinarily fall between March 11, 2020 and September 30, 2020. Therefore, program participants that have received or will receive an adverse decision dated from January 11, 2020 to August 1, 2020 now have an additional 60 days to file an appeal or waiver.
  • Program participants whose FCC Form 486 deadline falls between March 11, 2020 and September 30, 2020, will have an additional 120 days to submit these forms without penalty. This includes FCC Forms 486 from FY2019 and previous funding years. (The earliest certification deadline for an FY2020 FCC Form 486 is October 29, 2020.)

Extending the procedural deadline for filing the FCC Form 486

  • Program participants whose FCC Form 486 deadline falls between March 11, 2020 and September 30, 2020, will have an additional 120 days to submit these forms without penalty. This includes FCC Forms 486 from FY2019 and previous funding years. (The earliest certification deadline for an FY2020 FCC Form 486 is October 29, 2020.)

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