File Now for FY 2014 E-rate Reimbursements
July 16, 2015
~ List of Possible Affected Entities Attached ~
~ Online BEAR Instructions Attached ~
~ $29 million at stake for 851 different applicants ~
The 2014 Funding Year ended June 30, 2015 for recurring services and so now is the time to submit the Form 472 — BEAR — to the SLD for services in which you paid a non-discounted bill from July 1, 2014 – June 30, 2015. How do you know if you need to submit a BEAR? The easy answer is that if you received discounted bills from your vendor, you do not need to submit a BEAR (your E-rate discounts were applied to your bill). If you did not receive discounted bills, then you likely will have to file a Form 472 BEAR to collect your reimbursement. I’ve attached a list of FRNs whose vendors have NOT invoiced USAC, which likely means these schools or libraries must submit BEARs for those FRNs. Not included in this list are entities that have already filed BEARs for any or all of FY 2014 (and where USAC has already authorized disbursement).
The deadline for filing a BEAR for recurring services is October 28, 2015. The new invoicing deadline rules are VERY strict. If you cannot meet the invoicing deadline, you must submit an invoice deadline extension request (IDER) BEFORE October 28 (or whatever your invoice deadline is). USAC will then approve a single 120-day extension, but they are not permitted — under any circumstance — to grant a second extension. Also, they are not permitted to grant any extension requests that are submitted after October 28 (or whatever your original invoice deadline was). Thus, it’s important that you begin your BEAR forms NOW. Please don’t wait until the last minute because you’re likely to forget to file. Now is the very best time to submit the form. I’ll send a list in early September of the applicants that still having funding remaining to be collected, so file now and avoid the list! Each year, many applicants are committed funding, but then never go back to seek reimbursement. Don’t let them keep your well-deserved money.
A few important Q & A’s:
1) Can I complete the BEAR online?
A. Yes! The BEAR Form — 472 — can be submitted electronically to the SLD — if your service provider is accepting Online BEARs and if you have an E-rate PIN. The Online BEAR can be filed at https://www2.sl.universalservice.org/bear/login.aspx. A step-by-step guide to filing the Online BEAR is attached to this message. If you cannot file online or choose not to, you can complete the Form 472 online using the PDF format, print it, and then mail it to the SLD (after getting the service provider to counter-sign, of course). The paper BEAR is located at: http://www.universalservice.org/_res/documents/sl/pdf/forms/472.pdf under Form 472.
2) Can I put all of my reimbursement requests on a single BEAR?
A. No, a separate BEAR must be completed for each provider. For example, if you have 2 FRNs that list Comcast, and one FRN that is for AT&T, you can submit both Comcast FRN reimbursement requests on a single BEAR, but the AT&T reimbursement request must be filed on a separate BEAR.
3) Am I required to have the provider sign the BEAR?
A. Yes and No. You need the service provider’s signature on the PAPER BEAR Form before you submit it to the SLD. For the Online BEAR, the completed form will automatically be transmitted to the service provider for their electronic signature and then automatically filed with USAC. No separate signature is needed. To find the fax number of your service provider to have them sign the PAPER BEAR, use the SLD’s SPIN search database (http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp) and call the number listed.
Also, make sure the service provider signs the last page of the paper BEAR — the Service Provider Certification Page — and not the Applicant Certification Page which looks very similar. Also make certain that the provider includes the date beside their signature; dates are considered a minimum processing standard.
4) I was committed more funding than I actually spent. Can I request reimbursement for the full amount that was originally committed?
A. No. Applicants may only seek reimbursement for the exact amount paid for the service instead of just listing the full funding cap (for example, if you were committed $10,000, but then only spent $6,000, you can only request E-rate reimbursements based on the $6000). Please know that the SLD has increasingly been requesting copies of invoices when they review the BEARs as proof that you are requesting the accurate amount. Don’t send the invoices with the BEAR, but know they might be requested.
5) I spent more than what was committed on my funding commitment letter (my cap). What should I list on my BEAR — the cap or the actual amount spent?
The SLD would like you to complete the BEAR with the actual figures of what you spent for the service, and not just list your funding cap amount. For example, if you spent $10,000, and had a 50% discount, you would list $10,000 in Column 14 and $5,000 in Column 15, even if you were only committed $4,000. The reason is that the SLD would like to show how much applicants are actually spending on services and also so they know that you are not just listing the funding commitment amount (the cap), but have actually added up how much was actually spent in each of the 12 months using the actual vendor bills. Unfortunately, they will only reimburse you up to the amount that you were committed.
6) When will I receive my BEAR reimbursement check?
A. After the SLD has reviewed and approved your BEAR, they will mail to you a BEAR Approval Letter, listing the amount of your check. Your check is mailed to your service provider within 20 calendar days of the date of the approval letter. Service providers are required to mail you a check for the same amount within 20 calendar days of receiving the check from the SLD. And if the past is any indication, the BEAR Approval Letters are mostly being issued within 10-20 days of their receipt at the SLD.
7) What if I receive my BEAR Approval Letter and it lists that $0 was approved?
A. This typically means that there was an error made on the BEAR Form and the applicant must correct the error and resubmit to the SLD. Many years ago, the SLD reached out to the applicant to correct the Form over the phone, but no longer. Now the SLD will “pass zero” the BEAR (meaning they won’t fund it), but it doesn’t mean the E-rate funding is gone. It simply means that the applicant must resubmit the BEAR with corrected information and typically there is an explanation on the BEAR explaining what was incorrect to help identify the error.
8) What if I actually received a slightly different service than what was originally listed on my Item 21 attachments?
A. The SLD has increased scrutiny of the BEARs to make sure that reimbursement requests are for exactly what services were approved for on the FCDLs and Item 21 attachments. If you changed services during the 2013 funding year from what you originally listed on your Item 21 attachments, you should first seek a “correcting service substitution request” from the SLD. The instructions for submitting a service substitution can be found at: http://www.sl.universalservice.org/reference/ServiceSub.asp
9) What should I do if I didn’t use the service?
A. File a Form 500 and cancel the FRN. The easiest version to use is available at: http://www.e-ratecentral.com/formsRack/app/Form500.asp.
10) What does it mean under the Form 486 Filed Column indicates, “No – Take Action ASAP”?
A. This means that a Form 486 was not filed for the FRN. Either the applicant forgot to file and should do so ASAP (realizing that some of the E-rate funding may be lost) or the applicant does not need the funding request and should file a Form 500 to cancel the FRN.
If you have any questions about the FY 2014 Invoice Deadlines or completing the BEAR, please contact me at jtschell@comcast.net.
– Julie
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 – o
717-730-9060 – f
jtschell@comcast.net
www.e-ratepa.org
Penn*link