E-RATE NEWS FOR THE WEEK OF 12/2/02 – 12/6/02
•
Form 471 Application Window Extended
•
SLD Warning on Form 470 Process
•
SLD Provides Item 21 Attachment Examples
•
Upcoming E-rate Deadlines – Updated
The E-Rate News for the Week, prepared by E-Rate Central, is sponsored by the Council
of Chief State School Officers ("CCSSO") and made possible by a grant from the AT&T
Foundation. Official SLD news is in the "What’s New!" section of the SLD’s Web site
(http://www.sl.universalservice.org). Additional information is on the State Education
Telecommunications Alliance’s ("SETA") Web site (http://www.e-ratecentral.com).
•
Form 471 Application Window Extended
The closing date for the FY 2003 Form 471 application window has been
extended from January 16
th
until Thursday,
February 6, 2003.
The primary reason for the extension relates to problems that the SLD
experienced with its online filing system when the window opened November 4
th
.
A new system platform was initially used, but proved to be unstable. After two
weeks, the SLD reverted to the previous platform. In order to assure full,
unimpeded, online entry for at least 74 days – the length of the original
application window – the SLD extended the window an additional three weeks.
•
SLD Warning on Form 470 Process
A serious warning was posted on the SLD Web site this week concerning
violations the SLD has been seeing in the application and competitive bidding
patterns of certain applicants and associated service providers. The SLD indicated
that it has started denying related applications.
The following patterns and practices were discussed in the SLD’s warning:
(1) Applicants cannot file a Form 470 indicating there is no RFP (i.e., by checking
Item 8b, 9b, or 10b) when, in fact, there is a RFP available for the services being
requested.
Note: If, for a given category of service, there is a RFP for one type of service and
no RFP for other services, the applicant must file two Form 470s – one checking
the "YES" box and one checking the "NO" box (and listing the non-RFP services
sought).
(2) The Form 470 (or referenced RFP) must define the specific services or
functions being sought.
Note: The original warning (posted 12/3/02) appeared to require that the Form
470 list a very precise description of "specific services" needed. The revised
posting (on 12/4/02) added the words "or functions." Form 470 instructions give
several examples of descriptions of "Service or Function" that indicate the broad
nature of acceptable functional descriptors (e.g., "videoconferencing services,"
"high speed direct access to the Internet," or "local area network"). This should be
combined with an appropriate indication of quantity or capacity (e.g., 5 buildings,
100 classrooms, or 50 users).
(3) Service providers cannot assist an applicant in developing a technology plan
after a Form 470 has been posted.
Note: More precisely, the SLD expects an applicant to have a technology plan –
although not necessarily an "approved" plan – before posting a Form 470.
(4) Winning proposals cannot provide "free" ineligible services.
Note: A minor clarification is provided in the SLD reference section dealing with
bundled services that include ineligible components on a purely ancillary basis
(see http://www.sl.universalservice.org/reference/costallocationguide.asp#Two).
(5) RFP and winning proposals cannot be designed merely with the goal of
"maximizing" funding.
(6) RFPs and other solicitation methods must be tailored to the needs of each
applicant.
•
SLD Provides Item 21 Attachment Examples
A Form 471 Item 21 Attachment section has been added to the Reference Area
(http://www.sl.universalservice.org/ContentInc/reference/Form471item21Attach
ments.asp). This document explains what an Item 21 Attachment should contain,
details the acceptable methods for submission, and provides sample attachment
formats for: outlining Telecommunications, Internet Access, and Internal
Connections services; describing ineligible functionality; using representative
bills; amortizing large installation charges; justifying on-premise Priority 1
services; and certifying non-use of remote access services.
•
Upcoming E-rate Deadlines – Updated
While most applicants are focusing on the new February 6
th
deadline, the last day
of the Form 471 application window for FY 2003, there are actually several other
earlier deadlines that apply to the FY 2001 and FY 2002 filings.
The first is the extended deadline for filing invoices (BEAR reimbursement or
supplier invoices) for recurring services received in FY 2001. These invoices
must be postmarked by Monday, December 9. The invoice deadline for non-
recurring services, that must have been installed by September 30
th
, is January 28,
2003. Invoices postmarked after these deadline will not be processed and funding
will be lost. Remember that BEAR forms must be acknowledged by suppliers
before they can be submitted.
The other upcoming deadlines are for FY 2002 Form 486s which must be filed
within 120 days of the start of service (normally July 1, 2002) or the date of the
Funding Commitment Decision Letter ("FCDL"), whichever is later. Most
applicants funded in Waves 1-6, with FCDL dates on or before July 1, were
subject to the well publicized Form 486 deadline of October 29, 2002. Applicants
funded in subsequent waves, have later Form 486 deadlines. Here are the next
few:
FCDL
Date 486 Deadline
Wave 9
08/13/02
12/11/02
Wave 10
08/26/02
12/24/02
Wave 11
09/10/02
01/08/03
Wave 12
09/24/02
01/22/03
Wave 13
10/08/02
02/05/03
The penalty for missing a Form 486 deadline is a reduction in funding. If, for
example, an applicant funded in Wave 6 did not file the associated Form 486 until
November 29
th
, the SLD will adjust the start date to 120 days prior to the
postmark date (i.e., to August 1, 2002) and reduce the funding accordingly (i.e., to
11/12
ths
of the originally approved amount)
Disclaimer: This newsletter may contain unofficial information on prospective E-rate
developments and/or may reflect E-Rate Central’s own interpretations of E-rate practices
and regulations. Such information is provided for planning and guidance purposes only.
It is not meant, in any way, to supplant official announcements and instructions provided
by either the SLD or the FCC.