E-rate Update - Billed Entities Fact Sheet Released
Message Posted February 4, 1998
The Schools and Libraries Corporation today released a "Fact Sheet on Billed Entities" that provides clarification on several issues relating to Form 470 and 471.
-- Julie Tritt
SLC BILLED ENTITY FACT SHEET
1) Q. What is a billed entity?
A. The definition of a billed entity is "the entity that remits payment to service providers for services rendered to eligible schools and libraries." [47 C.F.R. Section 54.500(a)]. The operative factor that determines a billed entity is whomever pays the service provider for services delivered to eligible schools and libraries.
2) Q. Must a billed entity be an eligible entity?
A. No, a billed entity is not required to be an eligible entity. This situation will occur when an ineligible entity pays the bills for eligible services on behalf of eligible entities to service providers. In some situations, an ineligible entity will negotiate with the service provider on behalf of eligible entities, and therefore, should be the 470 applicant.
3) Q. Does the 470 applicant have to be a billed entity?
A. No, the 470 applicant is not required to be a billed entity. The entity who will negotiate with the service provider should be the 470 applicant. A 470 applicant will not be a billed entity when the entity who will negotiate with the service provider is not the entity that remits payment to service providers for services rendered to eligible schools and libraries.
4) Q. What entities should be listed on the Form 470?
A. Each entity that will receive service and either (1) will receive a bill directly from the service provider or (2) will reimburse a billed entity for a portion of services it receives should be identified separately in Block 5. Eligible entities should be listed in Block 5, Item (19). Ineligible entities should be listed in Block 5, Item (20).
The Form 470 requires all eligible and ineligible entities that will receive the services described in the request for services (Block 3) to be identified in Block 5, Items (19) and (20). The phrases "billed entities" and "eligible entities" are used interchangeably on the Form 470 at Block 5, Item (19). The form instructions at Block 5, Item (19) state that an entity is a billed entity if "it will receive a separate bill directly for services it receives; or it will be responsible for reimbursing a billed entity for the portion of services that it receives." This definition, however, has been clarified in the FCC's rules set forth in the FCC's Fourth Order on reconsideration, as noted above. Whether or not an entity receives a bill is not the determining factor for identifying a "billed entity." Whether or not an entity reimburses another entity for eligible services is not the determining factor for identifying "billed entity." These two factors are, however, relevant to determining which eligible entities should be listed on Block 5, Item (19).
Block 5 of the Form 470 seeks to provide information to potential service providers about the entities that will receive the service described in the request for services, to assist them in determining whether they may be interested in submitting a bid on the request for services. Item (19) requires the identification of eligible entities and Item (20) requires the identification of ineligible entities that receive service.
5) Q. How should large 470 applications covering numerous entities be completed?
A. If the 470 Application will cover a statewide group of entities, the on-line application at the SLC Web Site will provide some options for presenting the information in Block 5, Item (19) in a summary fashion. The applicant may select from several check boxes which will be presented on the website screen at Item (19) of Block 5. The following selections will be offered:
All public schools in a state.
All private schools in a state.
All districts in a state.
All eligible libraries in a state.
One or more of the selections may be chosen if the 470 application will cover less than 500 eligible entities. If the application covers 500 or more eligible entities, then one of the selections must be chosen. If you have questions about the selections, call the toll free telephone number at our client service bureau at 1-888-203-8100. If the applicant chooses one of the selections, then the applicant is not required to fill in each individual line in Block 5, item (19), as part of the on-line application. The applicant will be directed to submit this information at the same time that it mails in its signature on the certification page.
Service providers may identify each entity's zip code location within a particular summary category by using the NCES code search function at Block 1, Item 3a of the 470 application. The search feature allows you to enter a zip code, which will then create a list of schools and libraries within that zip code.
6) Q. Must each applicant for Form 471 be a billed entity?
A. Yes, an applicant filling in Form 471 may be "an individual school or library or a consortium, including a school district that is the billed entity for its schools. You may also be a city, a state, or an entity created solely to participate in this universal service discount mechanism, but only if you are the billed entity, in that you actually pay the bills for the service to the service provider." (Form 471 Instructions, Block 1, Applicant Name and Address, Item (1)).
A lead member of a consortium may file a Form 471 which includes other members of the consortia if the lead member of the consortia is responsible for paying the bills to the service providers on behalf of the other members of the consortia. The lead consortia member must undertake all of the record keeping and other administrative requirements to comply with the Schools and Libraries Universal Service Program.
7) Q. May more than one billed entity file a single 471 application?
A. No, each entity which remits payment to the service provider for eligible entities must file a separate Form 471. (Form 471 Instructions, II.A. Who must file?; 47 C.F.R. Section 54.500(a).
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Julie L. Tritt
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