• USAC is moving Universal Service Fund payments to bank details held in recipients' active SAM.gov registrations
  • Recipients can still submit invoices with incomplete registration, but USAC will hold payment until the required registration and banking details are in place

The fact

The Universal Service Administrative Company said it would begin using banking information from SAM.gov for support payments on 8 September. The change affects telecommunications providers and eligible schools and libraries receiving Universal Service Fund payments.

USAC says recipients need an active SAM.gov registration, a valid bank account linked to that registration and their Unique Entity Identifier recorded on FCC Form 498. Organisations that already meet those requirements do not need to register again.

For E-Rate applicants that invoice USAC directly for reimbursement, incomplete registration does not prevent an invoice from being submitted. Payment will instead be held until the SAM.gov requirements are completed. USAC also says registration must be renewed annually. Its public identifier data can show whether a Unique Entity Identifier is recorded, but not whether the registration is active or the banking information is correct.

The assessment

The change separates two steps that recipients may previously have treated as part of the same payment process. An invoice can be accepted by USAC while the payment itself remains on hold because the organisation's SAM.gov registration or bank details are not ready.

That creates a hand-off between the people submitting programme invoices and whoever maintains the organisation's federal registration. Before relying on an expected payment date, the finance team needs to know that the registration is active and linked to the correct bank account. An invoice acknowledgement alone does not confirm that the money can be sent.

For BTW readers, the immediate risk is therefore a payment delay rather than a loss of programme support. Recipients need to keep the SAM.gov record current throughout the payment cycle, including its annual renewal, so an otherwise valid reimbursement is not held after submission.

What to watch

Watch the first payment cycles under the new process for hold notices and USAC guidance on any recurring problems. The useful distinction will be between delays caused by an individual recipient's registration and any wider issue affecting the transition to SAM.gov banking records.