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Saturday, November 17, 2007

The best of times, the worst of times

First, the good news: the latest News Brief states that any FRNs which were on BEARs that had been Submitted by applicants, but not Certified by service providers, would be automatically given invoice deadline extensions until January. Bravo! As long as it doesn't become habit-forming....

Now, the bad news: there seems to be a general tightening of the requirements for approval of Invoice Deadline Extension Requests (IDERs). My impression in the past was that you could get almost any IDER approved. Based on some appeals to the FCC that I've seen recently, the party is over. The guidelines still seem pretty charitable, but you have to have a good reason. And on the latest Service Provider Conference Call, Mick Kraft mentioned that if you wait more than 120 days after the last date to invoice, that may result in denial. That seems pretty reasonable to me, since that's 240 days after the last day to receive service, which ought to be enough time to pry the billing information out of even the most stubborn business office.

While we're on the subject of invoicing, I must give kudos to the folks at USAC Invoicing. Based on the stats we heard on the conference call, it doesn't seem like the surge in BEARs before the deadline created much of a backlog.

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