Updated May 2018
A service substitution is a change in the products and/or services specified in the FCC Form 471 (Description of Services Ordered and Certification Form). In certain limited circumstances, applicants or service providers may request and be approved for service substitutions. In addition, service providers or equipment manufacturers may submit a "global" service substitution if, for example, they want to replace a discontinued product with a new product across all funding requests.
The certifications and representations made in the original FCC Form 471 application apply to the service substitution request. False statements on a service substitution request carry the same penalties as those indicated in the FCC Form 471 certifications.
Service substitutions encompass changes in the technical components (products, services, or both) specified in the FCC Form 471. Applicants who file service substitution requests must comply with the deadlines for the certifying the FCC Form 486 (Receipt of Service Confirmation and Children's Internet Protection Act Certification Form).
Service or product substitutions must meet the following conditions as specified in the Federal Communications Commission (FCC) rules:
If a service substitution results in a change in the pre-discount price for the supported service, Schools and Libraries (E-rate) Program funding will be based on either the pre-discount price of the product or service for which support was originally requested or the pre-discount price of the new, substituted product or service, whichever is lower.
Example: USAC approves an applicant's request to use 87 six-port network modules at a pre-discount cost of $8,700.00 instead of a different brand of 58 eight-port network modules that were originally approved in the applicant's FCC Form 471 at a pre-discount cost of $10,000.00. In this example, the pre-discount cost would be reduced to $8,700.00 as this is the lower price.
You should submit your service substitution requests after you receive a FCC Form 471 Receipt Acknowledgment Letter (RAL).
USAC must receive a service substitution request on or before the last day to receive service for that FRN. In general, the last day to receive service is:
However, the deadline for the receipt of non-recurring services may be extended beyond the June 30 (i.e., special construction services) or September 30 (i.e., other non-recurring services) deadlines. (Service delivery extensions are only available for non-recurring services/charges.) If the deadline for receipt of these services is extended, the deadline for the service substitution request is automatically extended as well.
If a service substitution results in a decreased pre-discount price, the service substitution request will be considered a request for modification of the funding commitment, just as though the applicant submitted an FCC Form 500 (Funding Commitment Adjustment Request Form). Therefore, when USAC approves a service substitution request that includes a cost decrease, we will adjust the commitment for the affected funding request to reflect the decreased pre-discount cost.
USAC's review includes an evaluation of whether the "same functionality" is maintained between the original and proposed configuration, and whether the proposed configuration is eligible for funding. For service substitution requests involving internal connections, our review may first evaluate the substitution based on the function and product type for each line item in the "from" and "to" lists.
An internal connections service substitution request is deemed to meet FCC requirements for "same functionality" if the original and new configurations maintain consistent functions and the request does not change the type of service from one category to another.
For example, these service substitution requests meet the requirement for same functionality:
USAC may only approve service substitution requests when FCC requirements for same functionality are met. USAC will respond in writing to the service substitution request, either approving the request or indicating the reason(s) why the request cannot be approved.
If you need to make subsequent corrections to a service substitution, applicants must follow the normal service substitution procedures and timelines in order to obtain pre-approval of changes.
If USAC finds an unapproved change during the invoice review process, USAC will refuse to pay the invoice for products or services that were not originally requested. Furthermore, if, during an audit, USAC discovers different products or services were installed and/or delivered from those that were approved, USAC may make a commitment adjustment and require that you return the funds that were disbursed incorrectly for unapproved products or services.