E-rate Update - Process, Confirmations, & Validations
Message Posted March 6, 1998
APPLICATION FILING/RECEIVING PROCESS
SLC APPLICATION RECEIPT ACKNOWLEDGMENT - FORMS 470 & 471
PROGRAM INTEGRITY INSURANCE REVIEW (APPLICATION VALIDATION PROCESS)
1. Applicants begin the process by completing Form 470 and submitting the application to the SLC, either on-line or on paper. Once the application has been properly completed and accepted by the system, the 470 application will be posted on the SLC Web Site for 28 days, if the application is a request for new services or includes new services. Applications for discounts to support only pre-existing service contracts are not posted on the SLC Web Site for competitive bidding, but 28 days must elapse before SLC will receive a Form 471.
2. The on-line application at the SLC Web Site contains built-in on-line instructions to guide the applicant while filling in the Form 470. These on-line instructions have built-in features to assure that the SLC Web Site will accept only properly completed Form 470 applications.
3. For those applications requesting new services, a competitive bidding process must occur. Applications requesting bids must be posted for 28 days before the applicant can sign a contract for new services and submit the Form 471. The SLC will post on the SLC Web Site applications submitted for any new services to notify potential service providers of an applicant's request for service. The 28 day posting period will be measured by days and hours (28 days * 24 hours = posting period). On applications submitted for existing services, applicants should wait 28 days before submitting a Form 471. Such forms received before the end of that waiting period will be held; clients will not be contacted about their applications and data will not be entered until the waiting period has passed.
4. After a service provider is selected and a contract is signed, the school or library requests the SLC to commit to make payments to the service providers for the discounted portion of the costs by submitting a Form 471. It is important to keep in mind that, until the SLC reviews and approves the Form 471 and makes a funding commitment, applicants cannot assume that they will receive the discounts for which they are applying. Applicants should therefore exercise caution in signing a contract and consider including appropriate conditions and contingencies.
5. Forms 471 must be submitted on paper to the SLC in Iowa City, Iowa. See "Methods to Ease Filing of FCC Form 471" for ways to help make completing the form easier. The SLC Client Service Bureau personnel will enter the data into the SLC system.
6. To establish a position inside the 75-day window, applicants must have a properly completed Form 470 (submitted either electronically or manually); a properly completed and signed 470 Certification; a properly completed, signed and certified Form 471. If the SLC has received all properly completed components by April 14 (with the 28-day waiting period for the 470 completed), an applicant will have successfully filed during the 75-day window.
7. Applicants must retain documentation in support of their applications - for 3 years in support of the Form 470 and for 5 years in support of the Form 471. These files should back up the information provided in each application form.
8. Once a Form 471 application has been approved for funding, and the applicant begins to receive services, a simple notification document (a forthcoming FCC Form 486) must be submitted to the SLC to confirm that the contracted services requested by the applicant are being received. The Form 486 will also identify the service provider and the services being delivered to the applicant, and will serve as a trigger for payment of invoices.
SLC Application Receipt Acknowledgment -- Form 470
1. In processing manually filed Form 470 applications, the SLC Client Service Bureau will verify that the application meets minimum processing standards and therefore will not be rejected for failure to meet those criteria. (See "SLC Minimum Processing Standards for FCC Forms 470 & 471" for an explanation of what is required to avoid rejection.)
2. All properly completed, manually filed Form 470 applications will be entered into the SLC system within 2 business days of receipt. If a manually filed Form 470 application features some incomplete or inconsistent information, and therefore cannot be entered into the SLC system, a Client Service Bureau representative will contact the applicant and work with the applicant to address the problem.
3. The SLC will mail a letter to each applicant who submits a properly completed Form 470 application. This letter will acknowledge receipt and posting (if for new services) of the Form 470 application; provide the status of the Certification: and identify the date on which the applicant may first submit a Form 471 application. If the Form 470 Certification does not accompany the Form 470 when it is first received, the Certification must be received by the SLC before the end of the day on April 14 in order to complete filing for discounts within the 75-day window.
SLC Application Receipt Acknowledgment -- Form 471
1. In processing all Form 471 applications, which are required to be filed manually, the SLC Client Service Bureau will verify that the application meets minimum processing standards and therefore will not be rejected for failure to meet those criteria. (See "SLC Minimum Processing Standards for FCC Forms 470 & 471" for an explanation of what is required to avoid rejection.)
2. The SLC Client Service Bureau will contact clients promptly after the arrival of a Form 471 application, if an application falls into one of three categories:
a) Summary rejection: If the submitted Form 471 does not meet minimum processing standards (which include the requirement that the application include a dated, signed, and fully completed Form 471 certification), it will be promptly mailed back to the applicant, and the applicant's position in the 75-day window will not have been established. (See "SLC Minimum Processing Standards for Forms 470 & 471" for an explanation of what is required to avoid rejection.)
b) More Information Needed: If an application features inconsistencies or incomplete entries but does not require summary rejection, an SLC Client Service Bureau representative will work with the client to process the application. An SLC representative will notify the applicant with the additional information the applicant must provide. An applicant must provide responses to the SLC Client Service Bureau queries within 4 business days of the receipt of the query, or the application will be rejected.
c) No SPINs for Service Providers. A 471 applicant is asked to have its service providers inform it of the service provider's Service Provider Identification Number (SPIN) so that it can be entered in Column 1 of Items 15 and 16 in the Form 471. This is not a mandatory item - applicants may provide the service provider's full legal name instead - but the SPIN will ultimately be needed for SLC to pay the discounted portion of service costs to the service provider. The Universal Service Administrative Company (USAC) is currently assigning SPINs to service providers who wish to participate in the Schools and Libraries Universal Service Program. If the SPIN is not included on a Form 471, SLC's Client Service Bureau will contact the applicant and work with it to obtain a SPIN for the service provider. If service providers have not yet obtained their SPINs, the applicant should encourage them, as soon as possible, to obtain them by contacting the USAC at (973) 560-4440; USAC is now in the process of establishing a new toll-free number. (See "Assignment of the SPIN.")
3. Assuming the application meets the minimum processing standards and the client satisfactorily responds to the SLC Client Service Bureau queries within the deadline, the SLC Client Service Bureau will promptly enter the application and its certification. The client will have maintained his position consistent with the SLC receipt date stamp.
4. All acceptable forms will be entered by the SLC Client Service Bureau. When that process is completed and the 471 has been filed, the SLC will notify the applicant that the Form 471 has been received for consideration.
5. The criteria in paragraph 2 of this section will apply to Form 471 applications that arrive on the last day of the 75-day window (April 14, 1998). This may mean that clients will receive processing phone calls after the "window" has closed. These processing calls are not necessarily an indication that the application will not be considered as received during the window. However, applications that do not meet the minimum processing standards will not be considered as being received during the window.
Program Integrity Assurance Review
1. The SLC will process the Form 471 application through its Program Integrity Assurance (PIA) unit, which will review and analyze the substantive information set forth in the application. The SLC's review and analysis will seek to confirm that the applicant has complied with the rules governing the Schools and Libraries Universal Service Program. For example, the SLC will confirm that the application is submitted on behalf of eligible entities, the application requests discounts only for eligible services, and the discounts have been computed properly. (This list is illustrative only.)
2. The SLC's response to an application is dependent upon the completion of the PIA process. Applications may be fully approved, fully rejected, or approved in part - that is, some requests for discounts (i.e., rows in Items 15 and 16) may be approved and others disapproved. These decisions will be based on program rules relating to eligibility of services, eligibility of entities, appropriateness of discounts, and availability of funds. The purpose of the program review function is to help assure full program compliance. In certain instances, additional documentation of information certified as correct on the Form 471 will be requested.
3. A deadline of 4 business days for responding to the PIA inquiries will be established. An applicant's failure to respond satisfactorily (i.e., no response or an incomplete response) to the PIA inquiries within 4 business days will result in the rejection of the application. For this reason, the contact name on the application must readily lead to informed responses to queries. When an applicant fails to respond before the deadline, a written explanation of rejection of the Form 471 application will be provided to the applicant.
4. Audits of documents supporting application forms may be conducted before or after funding commitments. Applicants must provide any documentation requested to support their application forms. If an audit suggests that statements were included in application forms that may be violations of statutes, regulations, rules, or orders, the matter may be referred to the Federal, state, or local agency responsible for prosecuting, enforcing, or implementing the statute, regulation, rule, or order.
Summary - Key Tips
1. Contact Name. The named contact for the Forms 470 and 471 must be readily available when SLC calls. If the named contact person is on vacation or unavailable for other reasons, a surrogate should be available through the same communication channel. The Form 471 process requires a 4-day turnaround from applicants when questions are asked.
2. Avoiding Rejection. The Minimum Processing Standards should be used by the applicant as one tool to help assure the form is properly filled in and is not automatically rejected.
3. Service Provider Identification Number (SPIN). If service providers have not already obtained SPINs, 471 applicants should encourage them, as soon as possible, to contact USAC to obtain a SPIN, and the SPIN should be included in Column 1 of Items 15 and 16 if available.
4. Services List (Form 471 Item 17). In order to meet the requirements of Item 17 to include a list of the services that each service provider is to provide and for which the applicant is seeking a discount, applicants are encouraged to request these lists from the service provider as the Form 471 instructions suggest. (Also, see the discussion of the "Pre-Discount Cost Calculation Grid" in "Methods to Ease Filing of FCC Form 471.")
5. Backup Information. Documentation for all information supplied on the form should be readily available to facilitate SLC's program integrity assurance review and for audit purposes.
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