Category Two equipment and other one-time services must be delivered and installed by month’s end. Two new checklists walk applicants and service providers through it.
Funding Year 2025 recurring services wrapped up on June 30, 2026, but the year is not closed. Non-recurring services — Category Two equipment, internal connections, installation labor, basic maintenance — carry a separate deadline of September 30, 2026.
The word that trips people up is installed. Equipment that has been delivered but is still sitting in boxes does not meet the deadline. Neither does partial installation. USAC measures completion by whether the work is finished, not by whether the hardware arrived.
If an installation will not finish in time, there is a remedy — but it has a hard cutoff. An applicant can file an FCC Form 500 to request a one-year extension of the service delivery deadline, and that request must be filed on or before September 30, 2026. Filing after the deadline passes is not an option.
Two circumstances support a request:
- The service provider is unable to complete the work for reasons beyond its control, such as a supply chain or manufacturer delay, or the provider is unwilling to finish because USAC withheld invoice payments for more than 60 days during a compliance review.
- Separately, USAC grants automatic extensions when the FCDL was issued on or after March 1 of the funding year, or when a SPIN change or service substitution was approved on or after March 1. Those require no filing — check the FRN Extension Table in EPC before you file anything.
The part both sides need to understand
Only the applicant can file a Form 500. A service provider facing a delay has no independent filing path; it has to notify the applicant, supply the documentation supporting the certification, and give the applicant enough runway to complete and certify the form in EPC. A provider that raises the problem in late September has effectively run out of time on the applicant’s behalf.
That single point is why we have prepared two separate checklists.
Download the checklists
| FY2025 Applicant Checklist Verifying what is actually installed, checking for automatic extensions, filing and certifying the Form 500, canceling or reducing unused FRNs, and lining up invoicing. FY2025 Service Provider Checklist Auditing open non-recurring orders, notifying applicants early and in writing, supplying documentation for the certification, and keeping Form 498, UEI, and SAM.gov records current so invoices are not held up. Each is a printable checklist with the key dates and the highest-risk items flagged. Download the Service Provider Check List- PDF Format Download the Applicant Check List – PDF Format |
Dates to calendar
| Date | What it is |
| September 30, 2026 | FY2025 non-recurring service delivery deadline — also the last day to file a Form 500 extension request |
| October 28, 2026 | FY2025 recurring services invoice deadline |
| January 28, 2027 | FY2025 non-recurring services invoice deadline |
One caution: these are general deadlines. Individual FRNs can carry different dates because of late funding decisions, prior extensions, approved service substitutions, or SPIN changes. Confirm the deadline on each FRN rather than assuming one date governs the whole application.
| Questions about a specific FRN, a Form 500 filing, or whether an extension applies to you? Contact your Kellogg & Sovereign consultant before September 30. https://kelloggllc.com/contact/ |
