October 16, 2015
TIP OF THE WEEK: If you are working in the E-rate Productivity Center (EPC) and want to return to your Landing Page, click on the USAC logo in the upper left-hand corner of any EPC page. You can also click on the "Reports" tab and choose "My Landing Page" on the Reports page.
Commitments for Funding Year 2015
Funding Year 2015. USAC will release Funding Year (FY) 2015 Wave 22 Funding Commitment Decision Letters (FCDLs) on October 22. This wave includes commitments for approved requests for all service types and at all discount levels. As of October 16, FY2015 commitments total over $2.32 billion.
On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC's Automated Search of Commitments tool.
Entity Numbers in EPC
In the October 2 SL News Brief we discussed entity numbers in general, and in the October 9 SL News Brief we provided some specific examples of situations where entity numbers may or may not be required.
Because of the way organizations are structured in EPC, some options that were available in the past under a single entity number now require more than one entity number. Applicants are sometimes confused by the need to get a second entity number when one would previously suffice. The concept of "parent" and "child" entities helps illustrate when new entity numbers are required.
Parent entities and child entities
Parent entities make decisions on behalf of child entities, and may also be responsible for managing their child entities' information in EPC. In general, organization accounts in EPC are assigned to parent entities, and their associated child entities are listed on those accounts. Parent entities are responsible for filing E-rate program forms.
The three most common parent-child relationships in EPC are:
A school district (parent entity) to the individual schools and non-instructional facilities (NIFs) that are part of that school district (child entities)
A library system (parent entity) to the individual library outlets/branches and NIFs that are part of that library system (child entities)
A consortium leader (parent entity) to the members of the consortium (child entities).
In general, a parent entity must have an entity number solely to identify itself in its role as a parent entity. The parent entity represented by this entity number is not itself eligible for discounts. For applicants who have in the past used one entity number for two roles, this may be confusing. Specifically, in the October 2 SL News Brief, we noted the information in the first two bullets below and now add a third:
In the past, some school districts used the entity number of their administrative building (a NIF) to represent both the school district and the NIF. For FY2016, these school districts must have two entity numbers – one to represent the school district and one to represent the NIF.
Similarly, some library systems used the entity number of their main branch to identify both the library system and the main branch. For FY2016, these library systems must have two entity numbers – one for to represent the library system and one to represent the main branch.
Following the same logic, a consortium leader that is also an eligible entity must have two entity numbers – one to represent the parent entity (the consortium) and one to represent the eligible entity (for example, if the consortium leader is also an independent school, which may or may not be a member of the consortium).
If you need to request a new entity number from CSB to differentiate these two roles, we suggest that you retain the original entity number for the entity that has historically applied for discounts to simplify your record keeping.
If you have applied for discounts in the past for your school district using the school district administration building entity number in Block 1 of program forms, you can continue to use that entity number to identify the school district (parent entity) and ask CSB to create a new entity number for the administration building (child entity), which would be a NIF.
If you are both a library system and a consortium leader but you have applied for discounts in the past for both the library system and the consortium using your library system entity number, you can continue to use that entity number to identify the library system and ask CSB to create a new entity number for the consortium leader (parent entity).
The need to distinguish the roles of parent and child entities comes from the structure of organization accounts in EPC. In EPC, you can only file program forms as a parent entity.
Filing program forms
The type of organization account you have in EPC determines the type of application you can file.
An individual school that is part of a school district cannot file a program form on its own, but must be featured on its school district program form because it is a child entity on the school district's (the parent entity's) organization account. Similarly an individual library outlet/branch that is part of a library system cannot file a program form on its own because it is a child entity on the library system's (the parent entity's) organization account.
A school district or a library system cannot file a consortium application, because its organization's account in EPC is not set up as a consortium. The school district or library system can still be a consortium leader; however, it must have two organization accounts in EPC and two entity numbers – one entity number and organization account for the school district or library system and a second entity number and organization account for the consortium.
Situations where two entity numbers are not required
There are two specific situations where an entity number can represent both a parent and a child. In these situations, a second entity number is not required.
An independent school – that is, a school that is not part of a school district, does not share a common board with other schools, and is individually responsible for its finances and administration – can file a program form (a parent entity role) and also be eligible for discounts (a child entity role) using the same entity number. Similarly, an independent library – a library that is not part of a library system, does not share a common board with other libraries, and is individually responsible for its own finances and administration – can file a program form (a parent entity role) and also be eligible for discounts (a child entity role) using the same entity number.
A consortium – a parent entity – can have members (child entities) that are also parent entities in their own right. For example, a school district or a library system can be a member of a consortium (in the role of a child entity of the parent consortium) while also acting as the parent to its own schools in the school district or library outlets/branches in the library system, respectively. In this case, the library system or school district does not need a second entity number to identify its role as a child entity of the consortium.