Form 471 Filing Guide – Category 2 – FY 2019

February 13, 2019

Attached: Form 471 Filing Guide – Category 2 – FY 2019

~ Bulk Upload Guide Coming Next ~
~ Be Sure to Read Helpful Hints below ~

Category 2 is the E-rate funding mechanism designed to fund networking equipment and infrastructure within a school or library building.  All eligible requests that have followed the proper bidding rules will be funded, regardless of E-rate discount, up to a building’s 5-year pre-discount cap.  There are only 42 days left before the March 27, 2019 Form 471 Filing Window closes and the first funding wave is slated to be released in late April.  So file early to be in one of the first waves!


Attached you will find the FY 2019 Category 2 Form 471 Filing Guide, containing 104 slides, that provides step-by-step instructions for three different types of funding requests as follows:

  • Wireless Equipment – 2 line items – WAPs/Controller (starts on slide 17)
  • Network Switches – 1 line item (starts on slide 50) – Note:  most switch FRNs will have multiple FRN Line items.
  • Structured Cabling – 1 line item  (starts on slide 73)


  1. Additional ‘Types of Internal Connections’ – The Form 471 has added three new types of Internal Connections – Licenses, Transceivers, and Modules.  You will see these additional options when creating the FRN Line Items – both in the Form, and in the Bulk Upload Templates.  Examples of when to select these options:


  • For example, for a wireless license, use the ‘License’ drop down instead of the ‘Wireless’ drop down
  • The models #’s for licenses typically begin with LIC-


  • If the pricing of the components are separate and identifiable then apply separately for the switch and any components utilizing the corresponding drop downs.  If the pricing is represented by just one bundled price where they components cannot be separated from the overall price then apply for the switch


  • Networking modules are hardware devices that are portable and usually installed in a switch or router to add interfaces to an existing network system (e.g. optical modules).  If an applicant is adding portable interfaces to existing networking equipment they should utilize the “Module” drop down, if applicable
  1. New Version of Category 2 Bulk Upload Template – The optional Bulk Upload Template is nearly identical to last year except they added several vendors to the drop down choices, and added three new internal connections ‘types’ as described above.  The updated template is Version 19.0.  The Bulk Upload process is most useful for C2 Internal Connections FRNs with multiple line items or multiple recipients of service.  Version 19.0 Template available at:


  1. Don’t Exceed Your Category 2 Budgets!

Whatever you do, don’t request more Category 2 funding for a school than what remains in their budget.  Why?  Your application will likely be moved to the end of the PIA review list, and PIA will just make you reduce your funding request anyway.  And while this sounds easy to do, it’s not because you will have to explain exactly which component from which FRN Line Item must be removed in order to come in under budget.  If a school’s C2 equipment costs exceed the school’s available C2 budget, you have two choices:  1) list the amount that is “over budget” as ineligible on the FRN and then explain this in the narrative, or 2) remove components or reduce the cost of the components from the FRN entirely to come in under budget.

  1. Calculating Remaining Category 2 Budgets

To determine the amount remaining in each school’s C2 budget, cautiously use USAC’s C2 Budget Calculator Tool:  I say “cautiously” because only the “Approved Pre-Discount” column is 100% accurate.  This figure includes the pre-discount committed amount for FY 2015 – FY 2018, minus any approved Form 500’s that returned commitments or cancelled funding.  Unfortunately, the “C2 Budget” figure is faulty because it is based on your approved FY 2018 enrollment, not the enrollment you entered into the EPC profiles during the FY 2019 Admin Window.  So do the offline math for each school as follows:  (FY 2019 School Enrollment in EPC x $156.23) minus the “Approved Pre-Discount” Amount showing in the C2 Budget Calculator Tool.

  1. Multi-Year Product Licenses Eligibility

Product licenses are E-rate eligible and should be requested as Internal Connections on the 471.  The full cost of a multi-year license may be requested upfront in the year it will be purchased, even if the number of license years exceeds the number of years remaining on a school’s C2 budget.  Request the license as if it is the piece of equipment belonging to the license, and then list the license SKU in the ‘Model’ field.  That way the PIA reviewer will know it is for a license and not the actual product.

  1. Basic Maintenance Services Are Not Considered Licenses

Be careful not to mistaken maintenance services as product licenses.  Also, E-rate rules do not permit the requesting of multi-year maintenance services in a single year – these must be amortized and requested in the funding year for which the service covers.

  1. Ignore the “View Category 2 Budget Information” in the Form 471

On the Main FRN Page of the Form 471, there is a link in the top right corner of the page “View Category 2 Budget Information”.  The data contained in that link is inaccurate because it doesn’t contain FY 2015 Category 2 commitments.  Follow the guidance in # 2 to calculate the remaining budgets.

  1. Have Structured Cabling Contracts be Single Priced

For structured cabling, try to have your vendor contracts be for a single price, by building – not broken down by widget.  Then just create 1 FRN Line Item in the Form 471.  Vendor invoices, therefore, also should have just a single price, by building – not broken down by widget.

  1. Break Out All Components into Separate FRN Line Items – Including Switches

If your Category 2 request contains multiple components, you must create a separate FRN Line Item for each component (model), and then show the # of units, the cost per unit, and which schools will be using the equipment.  For example, a common mistake applicants make is to request just a single FRN Line Item for switches, with a single SKU.  Then during USAC invoicing, the invoices are denied because the individual components were not listed/approved on the Form 471.

  1. Break Out Ineligible Costs

Firewalls:  Only the actual appliance and basic operating software are eligible.  Anti-virus, anti-spam, filtering, and DDOS features/software are not eligible and must be removed or cost-allocated.  If it’s a bundled package, your vendor can provide you with the accurate eligibility percentage.

UPSs:  Network Cards are not eligible and must be removed from your funding request.  Also, don’t forget that only eligible equipment may be connected to the UPSs.

  1. Category 2 Contract Requirement

All Category 2 purchases require a signed contract prior to submitting the Form 471.  This can be as simple as signing/dating the vendor contract, and including the contract term and any funding contingencies.  Before starting your Form 471, upload the signed contract into EPC.  Landing Page > Name of District > Contracts > Manage Contracts.  The Contract Module Guide can be found at:   The PEPPM Contract Module Guide can be found at:

  1. Wisely Allocate C2 Budgets for Shared Equipment

If a piece of Category 2 equipment is shared by two or more schools, the cost of the equipment must be allocated from the C2 budgets of the schools sharing the equipment (core switches and wireless controllers are good examples of shared equipment).  Deciding which cost allocation method to choose — and making sure you do so correctly on your Form 471 — is important.  You can either 1) allocate the costs equally (the same amounts) from each school’s C2 budget that is using the equipment, or 2) allocate the costs on a weighted basis.   The second option requires some off-line math to be done, but it allocates more funding from the schools that have larger C2 budgets which may be advantageous to you.  Here is a Guide to help you figure out the cost allocation guidelines/math for shared equipment –

  1. Service Start Date Must Be 7/1/2019

The Service Start Date must always be July 1, not April 1.  Equipment is allowed to be purchased on or after April 1, and vendor invoices also may be dated on or after April 1.  But on the Form 471, where it asks for the Service Start Date, leave it populated to be 7/1/2019.  Note:  The Service Start Date is not the same as the Contract Award Date; the Contract Award Date is what you provide in the Contract Record as the date you signed the contract.

If you have any questions as you’re working through your Form 471, please don’t hesitate to e-mail me at

Happy 471 Filing!

– Julie

Julie Tritt Schell
PA E-rate Coordinator

717-730-7133 – o
717-730-9060 – f

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