E-rate 2.0 Update: Forms, Rural, Trainings
October 7, 2014
Hello, E-raters! Below is an update related to several important areas of the new E-rate program.
New, More Data-Intensive Form 471 – There will be an entirely new Form 471 for FY 2015 that will collect much more detailed information than in previous years. I will send a separate message shortly that outlines the changes and provides the draft form and instructions. This year more than ever, you don’t want to start the Form 471 in the last few days of the application window.
Form 470 Available for Filing Now – There will be a new Form 470 for FY 2015 as well, but because it’s not expected to be approved until early November, USAC is permitting applicants to use the currently-available Form 470 (FY 2014) for all services, both contracted and month-to-month. Important: When you reach Item 13, indicate in this text box that this Form 470 is for FY 2015 requests. Also, if you file using the currently-available Form 470, certify the form immediately because as soon as the new form is approved, USAC won’t be able to accept any old certifications.
FY 2015 Form 471 Filing Dates – USAC has stated that the Form 471 window dates will be announced in about a month, but that the window likely will close in mid-late March. Don’t wait until the 471 window opens to file your Form 470 — file it now but no later than when you leave for Thanksgiving.
Rural/Urban Designations – USAC has been working to create an Urban/Rural look-up tool so schools and libraries can enter their E-rate entity numbers and be shown a list of which entities are considered Urban and which are considered Rural under the FCC’s new Urban/Rural definitions (there are no more county-wide designations). They hope to have the tool available by the end of October. In the meantime, a list of Urban PA areas will be posted on the PA E-rate website in the next day at: http://e-ratepa.org/?page_id=747. These are census tracts and not necessarily town names. If a school is NOT located in one of these census tracts, it is presumed to be considered Rural. If the majority (more than 50%) of schools in your district (or libraries in library systems) are considered Rural, then the entire district (system) will receive the Rural discount from the discount matrix.
Please note: The new E-rate rules have changed the definition of Rural from county-wide classifications to be any location that is not considered an Urbanized Area or Urban Cluster based on the 2010 U.S. Census. While there is no disagreement that Urbanized Areas (census tracts with populations of 50,000 or more) should be considered Urban, there is nationwide agreement that Urban Clusters (census tracts with populations between 2,500 – 50,000) should NOT be included in the Urban designation as these are mostly small towns in rural areas. At least five organizations have filed Petitions for Reconsideration with the FCC on this issue, asking that the rules be changed immediately. I will keep you updated on this issue, but for now, you should assume that the current definition includes Urban Clusters.
Voice/Data Cost Allocations – The new E-rate rules state that data plans are presumed to be ineligible, but that voice services will be phased out by 20 discount percentage points/year. For cellular phones with data plans, this will require a cost allocation to be done so that your E-rate funding request will only be for costs associated with voice. While no official announcements have yet been made by the major cellular carriers, we are in active discussions with them about what these voice/data cost allocations will be. If you are trying to do a rough calculation to determine what your E-rate funding will be over the next few years, I would use a 49% voice/51% data allocation in your math. Meaning, if you currently pay $50 for a voice/data bundle, $25.50 (51%) would be considered ineligible as data, and $24.50 would be considered eligible as voice. When the final cost allocation determinations are made by the cellular providers, I will let you know.
E-rate 2.0 Trainings – Many of you have asked what other trainings will be offered over the next few months related to all of the new E-rate changes. First, if you missed any of the E-rate 2.0 Overview Webinars held in August and September, most of the archives for those sessions can be found at http://e-ratepa.org/?page_id=745. If you haven’t yet done so, please sign-up for one of the full-day, in-person, training sessions being held at the end of October and early November at: http://e-ratepa.org/?p=3051 (please note that the Philadelphia-area training is almost full). There will be several other webinars conducted over the next few months dealing with specific changes to the program (discount calculations, Category 2 budgets and eligible services, new online Form 471, etc.), and those webinars will be announced after the new forms have been released. In addition, USAC will be releasing several helpful training videos on their website over the next several months as well. All of these additional training opportunities will be announced on the PA E-rate Listserve.
FY 2013 and FY 2014 E-rate Ships Still Sailing – Although we’re on the cusp of applying for FY 2015 under the new E-rate rules, please don’t neglect to file the required forms for the previous and current funding years, including FY 2012 and FY 2013 BEARs by October 28, and FY 2014 Form 486s no later than 120 days after the FCDL date or October 28 — whichever is later.
If you have questions, please don’t hesitate to contact me at email@example.com.
Julie Tritt Schell
PA E-rate Coordinator