Final Stretch to File 470s for FY 2017
March 21, 2017
By now, I hope you have all filed your Form 470′s to competitively bid the services or equipment for which you will be seeking E-rate discounts in FY 2017 (unless, of course, you’re in a multi-year contract for which a 470 was posted in a previous year), and you are in the final bid evaluation or contracting state (or already have your contracts signed!). What is the last possible date to file a Form 470? There are different answers to that question, depending on whether board approvals are required. If you are an….
- Entity that requires board approval prior to signing contracts: You should count back about 35-40 days from your board’s April board meeting date(s), and that will be the very last day you’ll want to post a 470. For most of you, that date is now. Why 35-40 days? Because you’ll need 29 days + a few days to open and evaluate bids and get the materials to your board in advance of the meeting.
- Entity that does NOT require board approval prior to signing contracts: Your last day to file Form 470 is April 13, which would give you 1 day – May 11 – to open and evaluate bids, negotiate and sign contracts, upload contract details into the EPC Contract Module, and create/submit the Form 471 in EPC. Please don’t wait this long to file! My advice? File no later than April 1.
Either way, if you still need to submit a Form 470 this year, do it now.
When Must a Form 470 be Filed?
1) If a service is covered on a Month-to-Month basis, a new 470 is required annually.
2) At the beginning of any new contract. Note: If you posted a Form 470 in a previous year, and then signed a multi-year contract that expires on or after June 30, 2018, you are not required to file a Form 470 for FY 2017. If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if your contract contains the terms of the voluntary extensions (meaning the exact number of years or dates that the extensions can be exercised and it’s not just open-ended). Otherwise, you must post a Form 470 to extend the contract.
About the Form 470
The FY 2017 Form 470 requires filers to build the application by selecting “Add New Service Request” and then shows drop down boxes and asks specific questions related to that service. Because the choices/questions on the form aren’t very instructive, you are STRONGLY encouraged to use the narrative box to further describe any services you want (there is only a single narrative box, for each category of service). In addition, if you have an Request for Proposal (RFP), you MUST upload it into the Form 470 at the time the 470 is filed. No longer can you give a URL and direct service providers to your website for a copy. Any RFP addenda, Q & A, additional information given to bidders also must be uploaded to the Form 470, a process that can be done using the Related Actions feature in EPC when on the 470 page.
- All disqualification reasons must be stated on the 470 or in the RFP
- Must bid “equivalent” products for internal connections
Applicants must list “or equivalent” language on the Form 470s for Category 2 services and equipment. For example, you cannot say, “HP 2510 Switch,” but you are permitted to say, “HP 2510 Switch or equivalent.” Any bids received with comparable equipment must be considered in your bid evaluation. If you don’t use these words, USAC will deny your application. You MAY say that the equipment must be interoperable and compatible with your existing xxx make/model equipment.
- Upload RFP with 470
If you are using an RFP in addition to your 470, you must upload the RFP with the 470, AND upload any additional documentation given to bidders during the bidding process. If any of the new documentation materially changes the services being bid, you must restart the 28-day clock. To add additional documentation to your RFP: find your Form 470 in EPC (easiest way is searching Records in the top toolbar, or Forms at the bottom of your Landing Page), then Related Actions on the left Toolbar, then Add an RFP Document. No such function exists if you only used a Form 470.
- Installment Payment Plan with vendors
If you would like to spread out the non-discounted (the applicant’s share) amount of the cost of special construction, you must indicate so on the 470 under the ‘Payment Installation Plan’ section located beneath the narrative box.
- Use State/Local Procurement Requirements narrative box
This is the space where you place instructions on bidders, such as the final date to submit bids (must be at least 29 days after 470 filing date), where to submit bids, in what format, if references are required, if vendors must have SPIN numbers, if you require discounted bills, etc. Use this space wisely!
Hints for Completing the Form 470:
- Category 1 and Category 2 Form 470 Filings
C1 and C2 equipment/services may be included on the same Form 470, but it’s not required. Also, you can file as many 470s as you need.
- Voice Services
For voice services on the new 470, it asks for the # of users, instead of # of lines. To get passed the system, list the # of lines in this box, and then in the narrative box list the actual services required. For example, if you need 2 PRIs and 20 POTS lines, in the # of users box you would list 20, and then in the narrative box below, you would explain the services you actually need. Don’t forget, voice services are only eligible for 70, 80 and 90% discount applicants in FY 2017.
- Cellular Voice if You Have Bundled Voice/Data Services
For most applicants, cellular data is not eligible, but many applicants that are still eligible for voice funding may want to bid both voice/data bundles. In these cases, choose Cellular Voice on the drop down menu (not Cellular Data), and then list the # of plans. In the narrative box below, list how many voice-only plans you want and how many bundled voice/data plans you want, recognizing that you will be required to declare the data portion of the bundle as ineligible on the 471.
- Viewing Draft 470 Before Filing
At the end of the form, the system will require you to select ‘Review 470’ and will say that it’s generating the PDF. To see the PDF, you must click on ‘Refresh’ until it appears. The PDF will not appear unless you click Refresh (and sometimes it takes up to 30 seconds to appear). Review the draft and if you want to make changes to the form, click ‘Edit’ to re-enter the form. To submit, click on the certification box, and then ‘Continue to Certification’ to proceed with the certification/submission.
- Obtaining a Final, Submitted Copy of Your 470
After you’ve “certified” your 470, it’s often difficult to find a final copy. At the bottom of your Landing Page (home), scroll to the bottom where it says Form 470. Click on the 470 Nickname that you gave the form and it will show you a summarized version of the 470. To download an actual copy, click on Generated Documents on the left toolbar, and then Original Version.
- Additional Information on Filing a Category 1 Form 470 can be found at: http://e-ratepa.org/?p=16731.
- Category 2: Public school entities filing a Form 470 must also issue an RFP if the equipment costs more than $19,700 – or – they can use the PEPPM Mini-Bid process in which case no Form 470 or RFP is required. Additional information on C2 bidding:
* Category 2 Eligibility: http://e-ratepa.org/?p=16881
* Non-Public School and Library: http://e-ratepa.org/?p=16921
* Public School: http://e-ratepa.org/?p=17051
* PEPPM Mini-Bidding Information: http://e-ratepa.org/?p=17131
If you have any questions about posting last-minute 470s, please let me know!