Telcos Say USAC Portal Thwarting E-Rate Discounts, May Exit Program Absent Fixes

The telcos expressed concerns in the April 20 letter and a May 4 meeting with USAC officials "about the viability of the EPC portal to enable service providers, particularly large ones, to retrieve E-rate related data pertaining to their consumers from the EPC platform in a timely and accurate way," said the Wednesday letter. "Specifically, we noted that 'unless and until USAC corrects design flaws in EPC preventing service providers’ timely access to information in the system, our companies will be unable to provide services and accurate discounts to E-rate beneficiaries during Funding Year 2016 (FY2016) in a timely fashion.'" The FCC and USAC didn't comment.

USAC has made progress in addressing some concerns, but "key barriers remain," the new letter said. Some large service providers are still struggling to log onto the EPC platform due to account administrator and user credential problems, limiting their access to the status of customer funding requests. Certain electronic file changes are also preventing service providers from processing application funding information, the telcos said. "Unannounced and unplanned changes" made by USAC's School and Libraries Division (SLD) to forms and files have made telco processing systems "unworkable," their letter said. "The Recipient Acknowledgement Letter (RAL), the [FCDL] applicant and service provider notification, and Form 486 Notification of Service Start Date Form, all containing essential information about each applicant’s funding status, are not usable due to formatting errors and electronic file changes."

"Unless and until these issues are resolved," the telcos won't be able to give E-rate discounts to customers, said their letter, which cited invoicing and other problems they were having. "If faced with over-stringent invoicing requirements, service providers may have no choice but to exit the E-rate market which would ultimately hurt E-rate customers and the overall sustainability of the program," the telcos wrote. They said they welcome USAC efforts to modernize its IT systems and processes, recognize the resources USAC was devoting to implementing the EPC, and remain committed to resolving the problems.

The telcos asked USAC to work with them on achieving various objectives, including immediate resolution of EPC limitations on service provider account administrator and user credentials. "Critically, we request that USAC make a public announcement and actively reach out to every SLD applicant informing of the challenges that service providers are facing due to design flaws of the EPC system and explaining that, due to such challenges, service providers may be unable to access information pertaining to their E-rate funding status and, therefore, provide timely service discounts to their E-rate customers," their letter said.

"The problems raised in this industry letter are very similar to the problems encountered by the schools and libraries that are members of the SHLB Coalition," emailed Executive Director John Windhausen of the Schools, Health & Libraries Broadband Coalition. "The EPC portal has been difficult to navigate and we understand that hundreds of E-rate schools and libraries are still having trouble submitting applications through the EPC portal. USAC personnel have worked very hard to address the difficulties faced by applicants, and have often developed short-term work-arounds that allow applications to move forward in this filing window. We are grateful that USAC intends to engage in a comprehensive review of its application portals for all four of the USF programs, and we hope that USAC engages in more detailed user-testing with our community to avoid these kinds of problems in the future."