Time to File the E-rate Form 470 for FY 2019

September 26, 2018

Attached: Form 470 Filing Guide – 2019

Attached: FY 2019 Bidding Status for Recurring Services

~ List of PA Applicants that May Need to File 470 for Recurring Services Attached ~
~ Form 470 Filing Guide Attached ~

~ Confused?  Register for Beginners’ Training!  http://e-ratepa.org/?page_id=745 ~

The Form 470 marks the start of the FY 2019 funding year because it opens the competitive bidding process for equipment and services that aren’t yet under contract for FY 2019.  In the Form 470, schools and libraries identify and seek proposals for the products and services they need, and for which they will be requesting E-rate discounts, so that potential service providers can review your requests and submit proposals to you for consideration.  The Form 470 is filed in the EPC Portal and is only slightly changed from last year’s form.

Form 470 Changes for FY 2019

  • You may recall that last year the Form 470 contained confusing drop-down options for applicants seeking Internet Access services.  The FY 2019 Form 470 has been modified, but only slightly (slides 17 – 20 of the attached Form 470 Guide explains the Internet options/requirements in more detail).  Essentially:

– If you want Internet delivered over Fiber Transport, you must select “Leased Lit Fiber” and then explain in the narrative that you’re seeking Internet and at what bandwidth.

– If you are seeking Internet via a different mode of transport (cable modem, DSL, etc.), then you must select “Internet Access and Transport Bundled – Non-Fiber

  • Voice services has been completely phased out, and thus all references to voice have been removed from the FY 2019 Form 470.

When Must a Form 470 be Filed?
1)  If a service is covered on a Month-to-Month basis (meaning no contract), a new Form 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, 2019, you are not required to file a Form 470 for FY 2019.  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.

Attached is a list of all recurring service FRNs submitted in FY 2018 and a note explaining whether *I think* they need to be rebid for FY 2019.  My conclusions are drawn from a few factors – whether your contract expires on or after June 2019, and whether you have any contract extensions that may be available to be exercised so that rebidding isn’t necessary.  The data available to me, unfortunately, doesn’t make clear whether you still have extensions remaining; it only shows if you listed that your contract included extensions when your original contract was signed.

Please refer to Column N of the attached spreadsheet (Julie’s Rebidding Status Notes). The data is color coded as follows:

Red:  Must rebid services.

Blue:  May need to rebid, depending on whether contract extension is available/signed.

Black:  Service under contract and no rebid is required.

About the Form 470

The FY 2019 Form 470 requires filers to build the application by selecting “Add New Service Request” and then selecting one (or more) drop down selections.  The form then asks questions related to the selected service.  Because the 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.

When to File Form 470
Although the very last possible date to file a 470 is 29 days before the 471 window closes, do not wait this long to file.  I encourage everyone to file their 470′s by the first week in December!  You will then receive vendor questions/proposals during the month of December, can evaluate your bids and select your vendors in January, have your board approve contracts in January or February (if required by local policy), and then sign your contracts and file your 471 before the March 20 deadline.

Important Requirements/Reminders:

  • 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 or entities served, you must restart the 28-day clock.

  • 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 (installation), 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.

  • 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 ‘Back to re-enter the form.  To submit, check 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 Form 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 FCC Forms and Post-Commitment Requests.  Select ‘Form 470’ and the funding year.  Then 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 top toolbar, and then ‘Original Version.’

It’s important that you begin the Form 470 bidding process as soon as possible so you don’t run out of time during the Form 471 application window, except for PEPPM mini-bids which cannot be released until at least January 2, 2019.   If you have any questions about filing the Form 470, please e-mail me at jtschell@comcast.net!  Better yet, come to one of my trainings!  http://e-ratepa.org/?page_id=745

Happy Filing!

– Julie

Julie Tritt Schell
PA E-rate Coordinator

717-730-7133 – o
717-730-9060 – f

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