Global Service Substitutions
A “global” service substitution can involve a product and/or service that is being discontinued, has a model number change, or is being replaced. Additionally, if a manufacturer is bought by or merged into a different company, this type of service substitution should be filed to address products produced by the original company.
Global service substitutions only apply to situations where the product or service originally specified on the FCC Form 471 is no longer available, or is no longer being provided by the service provider. In these cases, the manufacturer or service provider must notify USAC that the product or service is being changed, along with a listing of one or more replacement products or services.
For service substitution requests initiated by a manufacturer or service provider, applicants do not need file anything with USAC to complete the request. However, the change must be consistent with the establishing FCC Form 470, the request for proposal (RFP), if any, and any state and local procurement laws.
When to File a Global Service Substitution
There is no specific timeline for service providers and manufacturers to file global service substitutions. However, they should submit model changes as early as possible to avoid delays in invoice processing. Since a service provider-initiated service substitution does not reference any specific funding request(s), the service delivery deadline for funding requests that include these services is not automatically extended.
How to File a Global Service Substitution
When you submit your global service substitution, you must indicate that the new products or services are functionally equivalent to the product or service you are replacing, and that they do not increase the percentage of ineligible features. USAC encourages service providers to include a publicly-issued product announcement of the discontinuation or model number change in the letter with their request.
Service provider-initiated service substitutions are designed to accommodate replacements that USAC can substantiate as near-identical. Replacements that cannot be substantiated as near-identical cannot be accommodated with this approach. However, if a service provider is aware of similar changes among many of its customers, it can facilitate a service substitution among these customers by providing similar service substitution requests to each customer to sign and submit. Such similar requests may be sent in one request to USAC.
Global Service Substitution Review
Service providers will receive a response to the service substitution request in EPC, indicating whether the request can be granted or requesting additional information. Service providers should supply a copy of USAC’s approval letter to each affected applicant. Applicants should keep this copy on file in the event of an audit.
USAC will maintain the list of submitted substitute products and/or services, in order to process invoices that specify the replacement product or service. This eliminates the need for many applicants to request the same service substitutions for changed or discontinued products. Such service substitutions will not result in a change to an applicant’s funding commitment.
USAC’s decision to process invoices with the replacement configuration does not change any contractual requirements between applicants and service providers. Applicants are not forced to accept a modified configuration that would violate the agreement or contract with their existing service provider(s).