Service Substitution

Change in service and/or equipment associated with a funding request (Service Substitution)

A service substitution is a change in the products and/or services specified in the ECF FCC Form 471 (Description of Services Ordered and Certification Form). In certain circumstances, applicants or service providers may request service substitutions, which will be subject to USAC review and approval.

The certifications and representations made in the original ECF 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 ECF FCC Form 471 certifications.

Service substitutions encompass changes in the technical components (products, services, or both) specified in the ECF FCC Form 471.

Service Substitution Criteria

Equipment or service substitutions must meet the following conditions as specified in Section 54.1710(b) of the Federal Communications Commission (FCC) rules:

  • The substituted equipment or services have the same functionality as the equipment or services identified on its ECF FCC Form 471. For example, this service substitution request meets the requirement for same functionality:
  • A router or a modem (but a router may not be replaced with a connected device).
  • The substitution does not violate any contract provisions or state, local, or Tribal procurement law.

If a service substitution results in a change in the amount of support, support will be based on either the price for the equipment or service for which support was originally requested or the price of the new, substituted equipment or service, whichever is lower.

Example: USAC approves an applicant’s request to use 87 Brand D laptops at a cost of $21,750.00 instead of 87 Brand H laptops that were originally approved in the applicant’s ECF FCC Form 471 cost of $26,100.00. In this example, the equipment cost would be reduced to $21,750.00 as this is the lower price.

Reimbursement for substitutions shall only be provided after the Administrator has approved a request for substitution.

Service Substitution Corrections

If you need to make subsequent corrections to a service substitution, should use the external communications tab in the ECF Portal to make any modifications to their Post-Commitment Request Form.

If USAC finds an unapproved change during the invoice review process, USAC may not approve the request for reimbursement. Furthermore, if an audit reveals that different equipment or services were installed and/or delivered from those that were approved, a commitment adjustment will be made and you will be required to return the funds that were disbursed incorrectly for the unapproved equipment or services.