Did You Miss the Form 470 Deadline?
April 7, 2016
The Form 471 deadline is April 29, which made the Form 470 deadline April 1 (29 days prior to the Form 471 deadline). I’ve heard from several applicants in the last few days that missed the Form 470 deadline and need relief. My answer to them (and to everyone in this same situation) is to FILE THE 470 TODAY. Here’s why:
There is a little known fact that if you miss the Form 471 deadline, but file the Form 471 application within 14 calendar days of the deadline (May 13 in this case), you can still have your application considered as having been filed “in the window,” if you request a waiver from the FCC. Will the FCC grant it? Yes — if the 471 was filed with 14 days after the deadline.
For example, if you file a Form 470 today, the Allowable Contract Date will be May 5 (29 days after the 470 is posted). Between May 5 and May 13, you will do your bid evaluation, select your vendor, obtain necessary approvals, sign your contract, and file the Form 471 with USAC. After the Form 471 is filed, you will then file the waiver request with the FCC. The FCC will likely grant the waiver request within 60-90 days and your application will be put “in-window” along with all of the other 471s received by the actual deadline. Your application may be reviewed by PIA later than other applications, but nonetheless, it will be reviewed for FY 2016.
For all affected entities, I will create and send to the listserve a 1-page sample FCC Waiver Request for you to fill in and send to the FCC after you file your 471.
If, for some reason, USAC decides to extend the FY 2016 Form 471 deadline (as they did last year), obviously the waiver request wouldn’t be needed. The “Late 471 Filing Option” is always available for 2 weeks after the Form 471 deadline — whatever date that turns out to be.
If you have any questions, please let me know. Happy Filing!
Julie Tritt Schell
PA E-rate Coordinator