IU Discount Calculation Guidance
April 10, 2016
USAC has just released their formal guidance for how Intermediate Units should calculate their E-rate discounts beginning this year and it can be found at: http://lists.universalservice.org/read/archive?id=4502&mid=349978. Below is a summary in layman’s terms of this guidance (although we call them IUs in PA, USAC refers to them as ESAs (Educational Service Agencies) in their guidance).
For their own services (not consortia-related services), IUs must choose between one of these two designations:
A) IUs that operate actual PDE-recognized schools (not programs)
If you operate schools — actual schools recognized by PDE and not just programs in schools or other locations — USAC considers you an ESA School District. Your EPC profile will contain only those schools and the IU’s non-instructional facility buildings (NIFs). The IU schools will not be listed in any other entity’s EPC profiles. Likewise, no other non-IU operated school can/should be listed in the IU’s EPC portal (and if they are still listed there, you should call CSB at 888-203-8100 to have them removed from your EPC profile). These IU schools are eligible for C1 and C2 funding, and the NIFs are eligible for C1 funding. The discount will be calculated solely based on the schools that are operated by the IU.
– OR -
B) IUs that do NOT operate actual schools (but may operate programs)
Many of our IUs do not operate any actual PDE-recognized schools and only have programs and NIFs from which their staff is based. Even if the IU runs a secondary education program in a juvenile justice facility or a special ed program in an elementary school, if the program is not considered an actual school by PDE, these buildings would be considered NIFs. For this type of IU, USAC has created a special type of entity called ESA School District with No Schools which will allow the IU to properly calculate its discount rate and file in EPC. This type of entity would not be eligible for C2 funding because it is comprised entirely of NIFs. If you believe your IU matches this profile, call CSB at 888-203-8100 and have them update your IU Billed Entity Profile to become an ESA School District with No Schools.
This new type of ESA will essentially be considered an “Independent School” where there will be one school building in which the IU will list student counts totals for all of its member school districts in the appropriate fields for full time, part time, and NSLP eligible students. This will likely result in very large student counts, which USAC fully expects. No other schools (such as the schools in your service territory) can/should be in your EPC profile, even though you’re using their enrollment and NSLP data in the aggregate.
Note: You cannot be both an ‘ESA with Schools’ and an ‘ESA without Schools’ — the BEN must be one or the other and you cannot have both.
IUs that are ALSO Consortium Leaders that deliver services to their members
This designation is no different than it has been in previous years. Your EPC profile should contain all of the consortium members for which you are requesting services or aggregating demand. If the IU is also receiving services in this consortium, it should list the BEN of the IU (either one of the two types listed above). In this case, all of the consortium members will be responsible for updating their enrollment/NSLP data in their own district EPC profiles as consortia leads cannot alter this data. Although all consortia members will be captured in the IU consortia EPC portal, when you begin a 471, it asks which consortia members are receiving the service on that 471. The 471 will then calculate the discounts based on the members selected. For example, if only some of your members are receiving Internet access from the IU RWAN consortium, you would file a separate 471 and just include those districts. There’s no way to create a 471 and have 2 FRNs containing different members if you want those services to have different E-rate discounts. As always, the discount will be calculated as the simple average of the discounts of the members identified on that Form 471.
I hope this provides some much-needed clarifications. If you have any questions, please e-mail me at firstname.lastname@example.org.
Julie Tritt Schell
PA E-rate Coordinator