Form 5640 Initial Application – What to Consider
By Rachel Kimbrough
Rip & Replace is the upcoming FCC-managed reimbursement program that affects any rural telecom carrier with Huawei or ZTE equipment on their cell tower sites.
Unlike REPACK, Rip & Replace is not an opt-in or -out program. It’s a matter of national security. Like REPACK, the timeline for mandatory participants is hard-set, firmly established. The schedule is tight, like most telecom schedules, and unforgiving.
Telecom professionals affected by the Rip & Replace program will have a 60-day window in which to submit their applications for reimbursability and program compliance. Sixty days may sound like ample time, but in reality the work required to compile the information the FCC requires and to account for all potential reimbursable costs will take more than 60 days. That work needed to begin yesterday.
It’s not just a matter of conducting site surveys. A physical examination may suffice to gather information in regards to existing site equipment in order to compile a pre-construction inventory log. On that topic, please note that a pre-construction inventory log of some kind is required in order to participate in the program. When removing Huawei or other qualifying equipment, these pieces of inventory can’t just be tossed aside or resold without some kind of documentation verifying their existing on site or as part of the network in some way.
Anyway, in its Public Notices and most recent Cost Catalogue, the FCC accounts for expenses that do not qualify for reimbursability, like strategic upgrades or new shelter structures or even new towers. It’s not enough to simply prove in some way that your cell tower has Huawei gear installed. These types of expenses must be thoroughly documented, verified as completely necessary or accepted as costs that the carrier will have to cover out-of-pocket.
The initial application requires four primary pieces of information.
In order to submit the initial Form 5640 to participate in the program and yield the maximum results for reimbursable expenses, telecom carriers must provide this information:
- Project Budget Request
- Specific Timeline
- Overall Project Plan
- Proof of Equipment
That means that for every site in your network, someone will need to review every piece of existing documentation, identify which documents are missing, fill in the gaps between the two, justify every piece of equipment that you’ll request to cut over your network from existing gear to proposed gear, break down what that timeline looks like, and ultimately spell out in no uncertain terms why all of it should be reimbursable.
So initially, just to apply to participate in the program (in which participation is required), you’ll need someone to review all existing documents just to get an idea as to scope of work for each site.
If you have a recent structural analysis for each site, reviewed against ANSI-TIA-222 Rev H standards, you’ll need someone to examine that recent SA, demonstrate why any structural modifications are required to participate in Rip & Replace, and provide that documentation in your initial application. If you don’t have a recent SA, then you’ll need to justify why the expense of getting an updated SA is required and reimbursable in order to participate in the program.
If you intend to follow the “Replace then Rip” model, then you’ll need to explain why a temporary structure is truly required in order to prevent your network from going off-air during cut over.
Point is: if you are required to participate in the Rip & Replace program, you need specialized back-office support. And you need that support right now.
In order to begin your application process, you’ll need to identify a project management firm and share all existing documents for review.
That means CDs, RFDS documents, structural analyses, pre-construction photos, equipment inventory logs — in short, share any existing COPs for each site.
This data dump will allow your chosen project management firm to review each site condition to confirm scopes of work, identify any potential risks, manage vendor lists and prepare an argument justifying costs on a per-site basis before presenting your application to the FCC.
Ideally, the project management group reviewing your existing site documentation will have a variety of specific backgrounds. In order to minimize risk, the group preparing your initial application should have something like a site acquisition professional, a construction manager, maybe a technical consultant, and an RF engineer.
A telecom-specific group reviewing your application can confirm reimbursability and advise as to what constitutes an eligible expense and what qualifies as a strategic upgrade — therefore, not reimbursable.
Whichever firm you sign onboard, the initial review and application phase is considered 100% reimbursable. But whatever estimated budget that group determines will be the figure that you’ll be stuck with. So it must be thorough and it must be accurate. Choose your PM firm wisely.
We’ve heard that quite a few carriers have already begun work.
That’s legitimately great. It certainly doesn’t hurt to get ahead of schedule as far as field installation work goes. However, it’s worth noting that without having submitted your initial application, it is very possible that some of the work that’s already happened may not be reimbursable.
While many carriers have already designated vendors for various scopes of work, what we’re seeing that’s missing is a single entity to serve as program manager. Every vendor has its own kind of specialty area, but there’s no one entity in place to pull all the pieces together. We’re telling you, for the purposes of an FCC reimbursement program, without someone keeping track of the project from a high-level viewpoint, carriers are at high risk to miss out on reimbursable expenses — or even miss out on compliance-related requirements.
If you have already begun work but do not have a reimbursement project management group on board, you’re already behind.
Here’s what you don’t know that you need to know.
Fact is, everyone’s scrambling. And if they’re not, they should be.
Here’s the situation. We all know how telecom works. This is not some weird sales pitch, but to be clear, QComm is made up of telecom professionals. We became FCC reimbursement program professionals through REPACK, but we come from telecom. We’ve got some staffers who come from an FCM background, a VP from site acq, RF engineers on staff, a whole group of drone pilots. We come from Ericsson, T-Mobile, Sprint, Samsung, Nokia, SAC, others. We’ve seen time and again in telecom how the higher-ups think that a specific timeframe is perfectly reasonable, and then it never really is.
But usually, when that unreasonable timeframe doesn’t pan out, that just means that you have to deal with whatever dissatisfied entity, and get to it on your own time.
When it’s a matter of national security, and a matter of FCC reimbursement, telecom does not have that luxury.
Telecom participants do not get to have the luxury to get to it when you get to it. In this case, telecom does not have the luxury of having a backlog, nor do we have the luxury of accounting for traditional change orders. In fact, the concept of a change order is nonexistent in this context (and more on that in future posts). Doesn’t matter if you already started work, doesn’t matter if you’re waiting until the application window opens. Your work is either compliant or not. And wouldn’t it be better to have specialists in your corner telling you Yes or No in regards to reimbursability.
Whichever route you choose, the time for action has arrived.
If you have not already done so, initiate a dialogue with a program management entity of some kind. Someone needs to manage your Rip & Replace process in order to pull all the pieces together and track milestones throughout this process.
But before any of that, you will need someone to help you navigate the application process. Start compiling your site documents and photo list, and send that information to your chosen project management group today.
In our next Rip & Replace post we’ll take an in-depth look at what Equipment Verification looks like. Stay tuned.