Second, if you do not have those types of documents at hand - and truly, most stations do not have a reason to have these kinds of documents at hand - then that 30-day deadline will go from a reasonable timeframe to an absolute nightmare. If you will have upcoming costs, whether related to equipment or legal support or PM costs, you will no longer be able to submit those costs as REPACK-eligible costs after initiating the closeout process.
Conversely, if you get your COP professional compiled during your REPACK phase, it is 100% reimbursable.īut of course, that also means that if you’re not actually completely done with your REPACK project, then initiating the FCC closeout process will serve to your detriment. So if you don’t already have a COP (closeout package) ready prior to closing out - which is the package that actually prepares you to handle the FCC’s closeout process, in addition to protecting you from future audits - then your time spent compiling your own COP or hiring out a third party to compile your COP will no longer be reimbursable. If you incur additional REPACK-related costs after initiating the FCC’s closeout process, it will be out of pocket. Here’s what that actually means for REPACK station owners.įirst, and maybe most importantly, once you tell the FCC that you’re ready to close out, you no longer have the option to submit additional invoices.Ĭlosing out with the FCC locks your access to Form 399. Relying on a third party with a hard deadline is hardly ideal. You’ll be relying on other companies or individuals to respond to, say, an email or a phone call to yield a deliverable that the FCC will accept as proof of payment, according to the parameters they’d established in their initial closeout email. But the involvement of third parties entails a risk of missing a deadline. Now this is where a station can prove that after reimbursed, those funds had gone where they should go. The FCC had been reimbursing costs submitted throughout the life of the project. Separately, you’ll have 30 days to provide proof of payment. It’s essentially a confirmation form - the station owner signing off on the fact that what has been submitted and represented is, indeed, true and is an accurate representation of costs accrued during the REPACK project. The financial reconciliation form, attached to the above email, looks like this. Basically, you’ll need to prove definitely that the invoices you submitted were valid and necessary, and that what your station was reimbursed for was used on-site, and funds paid out correctly. You’ll have 30 days to provide financial reconciliation. In short, once a station initiates the closeout process with the FCC, a 30-day countdown begins. But once a station initiates that process, a timer starts. As expected, the FCC requires documentation aligning the station’s financial records throughout the REPACK project in order to true up what was submitted to the FCC versus what actually happened. This email informs REPACK project participants of the FCC’s interim closeout requirements. The moment a station tells the FCC it’s ready to close out, this email is automatically generated. In addition to the fact that the FCC requires REPACK stations to keep all financial documentation until 2033, and can audit stations both financially and physically at any point between right now and that date, the FCC has also confirmed its own internal closeout process when a station indicates that it’s ready to close its REPACK project. But for REPACK stations specifically, no matter what your standard COP looks like on its own, your REPACK-specific COP is a game-changer. It’s no secret that a COP, or Closeout Package, is a known standard for any tower construction project. We’ve been talking about COPs for a few weeks now.