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E-Rate Frequently Asked Questions
1. What is meant by the requirement that the service substitution be "within the scope of the controlling FCC Form 470, including any Requests for Proposal?"
Any new specification of products and services must be within the scope of what could have been considered in responses to the appropriate FCC Form 470, and to the original RFP, if an RFP or similar procurement document was issued.
2. Can I change the technology deployed, say from T-1 to DSL? From voice to video?Changes must be within the same functionality. "Same functionality" means the same type of transmission — data, voice or video — and the same purpose, such as "telephone service," "local area network file server," "data distribution facilities," "lease of high speed data lines," and so on. "Better" or "faster" within the same functionality is allowed, if the other requirements for service substitutions are met. Thus, a change from T-1 to DSL could be approved if consistent with the Form 470 and any Request for Proposal. However, a change to a new functionality, such as from voice to video, is not authorized under FCC rules.
3. Can I change between funding categories, such as from Telecommunications Services to Internet Access?No. The same functionality requirement also means that the same Category of Service must be maintained.
4. Can the new product or service be more expensive, if discounts are not requested on that additional cost?Yes. Applicants may substitute an eligible service with a higher pre-discount price, but support will be based on the lower, original price, rather than the higher price for the substituted service.
5. If the product or service substituted is less expensive, can funds committed for the product or service represented in the original request be used for additional eligible products or services?If consistent with the applicant's Technology Plan, Form 470, and Request for Proposal (if any), additional products or services may be obtained within the same functionality provided that the applicant has the resources to make effective use of the new configuration. "Better" or "faster" products or services are allowed within the same functionality. Additional products or services that have a different functionality cannot be obtained.
6. Can the service provider be changed when making service substitution requests?Yes, this can be accomplished by using the procedure for changing service providers as described in the document SPIN Change Guidance posted on this website. Applicants may make a simultaneous request for both service substitution and change in service provider by (1) following the steps for filing a service substitution as outlined in these procedures, and (2) including the letter described in the SPIN Change Guidance procedure as an additional attachment to the service substitution request. If a simultaneous service substitution and service provider change cannot be granted due to a problem with one request or the other, USAC will contact the applicant to determine if we should continue to process the remaining request.
7. How long will it take to receive a decision on a service substitution request?If the submission is properly completed and requires no contact between USAC and the applicant or service provider, we attempt to reach a decision within 60 days of receipt of the request by the Service Substitution Team. More time may be necessary if the request is complex, if additional information is required, or if high processing workloads exist. To expedite processing, applicants are urged to make their service substitution requests as accurate and complete as possible.
8. How is "same functionality" evaluated?Service substitutions and the requirement for "same functionality" are considered based on individual Funding Request Numbers (FRNs). If there is more than one function in the funding request (such as servers, routers, and cabling in the same FRN), then individual functions may increase or decrease, as long as there is no new functionality in the substitution request. Technical equivalence is not mandatory for the requirement of "same functionality" to be met. For example, network switches may be substituted for network hubs, since both provide the functionality of distributing data signals.
9. Will unapproved changes in products and services delay payment of invoices?Yes. Invoices are checked to ensure consistency with the products and services previously approved. Invoices may not be paid if these products and services are seen to have changed, until USAC establishes that the requirements for service substitutions are met. Applicants must keep service substitution and other records on file for five years, and should be prepared to assist the invoicing team if any questions are raised.
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