Category 2 Form 471 Filing Guide – FY 2024

February 8, 2024

Attached: Form 471 Filing Guide – Category 2 – FY 2024

~ 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 (FY 2021 – FY 2025).  There are only 48 days left before the March 27, 2024 Form 471 Filing Window closes and the first funding wave is slated to be released in April.  So file early to be in one of the first waves!

CATEGORY 2 FILING GUIDE

Attached you will find the FY 2024 Category 2 Form 471 Filing Guide, containing 98 slides, that provides step-by-step screenshots/instructions and hints/answers for three different types of funding requests as follows:

  • Wireless Equipment – 4 line items – WAPs/Licenses/Controller/Installation (starts on slide 20)
  • Network Switches – 2 line items (starts on slide 47)
  • Structured Cabling – 1 line item  (starts on slide 63)

Also, there is a section to assist applicants with submitting/certifying, printing the form, as well as slides to help with any revisions that must be made after the form has been submitted.  This section begins on slide 77.  For applicants that may wish to copy a previously-created FRN (even one that’s drafted on a different Form 471), help guidance for that feature begins on slide 91.

WHAT’S NEW FOR FY 2024 – The actual FY 2024 Form is identical to last year, however applicants seeking shared equipment are no longer required to deduct a portion of the pre-discount cost related to the NIF usage of that equipment.  Equipment being used only by the NIF remains ineligible for Category 2 funding.

HELPFUL HINTS FOR FILING THE CATEGORY 2 FORM 471

1. Don’t Exceed Your Category 2 Budgets!

Be certain to doublecheck that you’re not requesting more Category 2 funding for your district than what is available in your C2 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 district’s C2 equipment costs exceed the 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 an FRN entirely to come in under budget.  To see your available FY 2023 budget, go to:  https://opendata.usac.org/E-rate/E-rate-C2-Budget-Tool-FY2021-/8z69-hkn7 and enter your BEN on the right toolbox.

2. 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.  Under Type of Equipment, select “License” instead of Wireless Data Distribution (or other equipment type).

3. 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.

4. 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 – not broken down by widget/connectors.

5. 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, and the cost per unit.  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.

6. 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.  Also, High Availability firewalls are not eligible as USAC will only fund a single firewall and HA require 2.

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.

7. 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: http://e-ratepa.org/?p=34634.   The PEPPM Contract Module Guide can be found at: http://e-ratepa.org/?p=34641.

8. No Requirement to Cost Allocate for Shared Equipment Used by a NIF

Beginning September 2023, applicants are not required to cost-allocate the non-instructional facility (NIF) usage of a shared piece of equipment that is located in a NIF. This rule previously applied to a district switch or wireless controller located in an administrative building or data center.  Unfortunately, C2 equipment that is solely used by the NIF will continue to be ineligible (for example, WAPs in admin buildings)

9. Service Start Date Must Be 7/1/2023

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 7/1/2023.  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.

10. No Requirement to Identify Equipment by Buildings

Although the form continues to ask which buildings are receiving equipment, you are no longer required to identify specific buildings because the Category 2 budgets are district-wide.  So just click “all” and move through the form.

11. Manufacturer Cost Allocation Links – new!

Some Category 2 equipment is not fully eligible for E-rate funding and requires a percentage of the base costs to be deducted to arrive at the E-rate eligible pre-discount amount.  Here is a list of manufacturers’ sites that provide eligibility percentages for their products: https://secaerate.net/Applicant-Resources (scroll to bottom of the page).

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

Happy 471 Filing!

– Julie

Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org

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