Category 1 Eligibility and Form 470 Filing Guide: Time to File for FY 2022!
November 11, 2021
Attached: Guide to New Form 470 Options
Attached: Category 1 Eligibility and Form 470 Filing Guide FY 2022
Attached: Rebidding Status for Category 1 Services from FY 2021 Data (1)
~ List of PA Applicants that May Need to File 470 for Recurring Services Attached ~
~ Category 1 Eligibility and Form 470 Filing Guide Attached ~
~ Gide to New Form 470 Options Attached (470 updated for FY 2022)~
The Form 470 marks the start of the FY 2022 funding year because it opens the competitive bidding process for equipment and services that aren’t yet under contract for FY 2022 (July 1, 2022 – June 30, 2023). On 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 those requests and submit proposals to you for consideration. Attached is an updated Form 470 Filing Guide for Category 1 services that provide complete details and step-by-step screenshots showing how to complete the Form. Category 2 eligibility and Form 470 filing instructions will follow.
New Form 470 for FY 2022!
For FY 2022, the Form 470 has changed. You may recall that in recent years the Form 470 contained drop-down options for both Category 1 and Category 2 service requests. For FY 2022, the FCC modified the drop-down options to be descriptive options with progressive disclosures for Category 1 (meaning the form takes you to additional levels of questions, depending on the options you select). To make the options a little more understandable, I’ve created the attached helpful guide that contains screenshots of the new Form 470 sections with plain language annotations to help you select the appropriate option(s).
When Must a Form 470 be Filed?
- If a service is covered on a Month-to-Month basis (meaning no contract), a new Form 470 is required annually.
- 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, 2023, you are not required to file a Form 470 for FY 2022. If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if your original 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.
- If you’re upgrading bandwidth mid-contract and the upgrades and associated prices are not included in the original contract (or making any other significant changes to your original contract).
Who Must File for FY 2022?
Attached is a list of all recurring services FRNs submitted in FY 2021 and a note explaining whether *I think* they need to be rebid for FY 2022. My conclusions are drawn from a few factors – whether your contract expires on or after June 2022, and whether you have any contract extensions available to be exercised so that rebidding isn’t necessary. The data is also color coded as follows:
Red: Must rebid services.
Blue: May need to rebid, depending on whether contract extension is signed.
Black: Service under contract and no rebid is required.
Note: If you see that your contract expiration date (CED) is not accurate on the attached list, it means you entered it incorrectly on your FY 2021 Form 471. If this happened, simply use the correct CED on your FY 2022 Form 471 and if PIA asks about the change, you can simply provide them with a copy of your contract that shows the accurate CED.
Form 470 Narratives and RFPs
I encourage you to use the narrative box to further describe any services you want. In addition, if you have a Request for Proposal (RFP), you MUST upload it into the Form 470 at the time the 470 is filed. In addition, any RFP addenda, Q & A, or additional information given to bidders also must be uploaded to the Form 470 with the RFP, a process that is done using the ‘Related Actions’ feature in EPC when on the 470 page. However, this can only happen if an RFP was uploaded with the 470 initially. Important: When any of the services or locations change, the 28-day clock must be restarted.
To assist with knowing what requirements to put on the Form 470 or in RFPs, please refer to this helpful E-rate and Form 470 Narrative Guide: http://e-ratepa.org/wp-content/uploads/2021/11/RFP-Form-470-Narrative-Guide-FY-2022.pdf.
Deadline 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 in early March.
Important Requirements/Reminders:
- List bid due date in Form 470 or RFP. If such a deadline isn’t stated, you must consider all bids received up until the date you conduct your bid evaluation. Therefore, I strongly recommend that all Form 470s/RFPs include a vendor proposal due date (be sure that this date is at least 29 days from the date this Form 470 is posted).
- All disqualification reasons must be stated on the 470 or in the RFP
- 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. In light of this, you also may wish to consider adding 2 weeks to the 28-day clock to allow for initial vendor questions (set a deadline for those questions and then upload answers with the RFP).
- 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 Form 470 Last Steps:
- 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. If you have any questions about filing the Form 470, please e-mail me at jtschell@comcast.net!
Happy Filing!
– Julie
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133
jtschell@comcast.net
www.e-ratepa.org