E-rate Update - Important 471 Reminders
Message Posted March 20, 1998
PDE RELEASES IMPORTANT 471 REMINDERS AND STRESSES ACCURACY ON FORMS
As schools and libraries are beginning to complete the Form 471, I have listed several key reminders and pointers. Important notes regarding PEPPM and DGS contracts are listed at the end of the message. We have learned that numerous Form 471s have been submitted to the SLC and already have been rejected because they did not meet the minimum processing standards. Before you submit your Form 471 BE SURE TO READ THE SLC MINIMUM PROCESSING STANDARDS that were sent via e-mail and that are located on the PDE E-rate website and at the SLC web site under the Reference section.
1) The Form 471 is very official, and as such should be completed with utmost detail and review. Please be sure the application is completed in full and that answers are entirely accurate. Call the SLC Client Service Bureau (888-203-8100) to confirm your answers if necessary. Attach all documentation that is requested. And remember, simply completing and posting a Form 470 did not guarantee you of discounts -- it was merely the first step. Form 471, the second step, will be closely scrutinized and is the real key to receiving your discounts. Please do not to risk losing your discounts because you submitted an incomplete or noncompliant Form 471.
2) Every Form 471 application must be linked to a previously filed 470 application OR IT WILL BE REJECTED. The applicant may rely on a previously filed 470 application which was filed by a third party and where the applicant was named as a billed entity under Item (19) or Item (20) of Block 5 of the 470 application (such as a consortium Form 470 or the PEPPM Form 470). The applicant should consult with the 470 applicant to obtain the Universal Service Control Number (USCN) for the relevant 470 application in which they were identified as a billed entity. This information must be supplied in Item (15) and (16) of the form 471 application, under column (2).
3) If you are contacted by the SLC for clarification or additional information after you have submitted a Form 471, be prompt in responding to their request. If you do not respond to their request within 4 business days, your application will be rejected. Be sure the contact name on the application is readily available and can lead to informed responses. A suggestion may be to list the telephone extension of the contact person or an additional number where the contact can be reached. Also, be sure the contact person has documentation readily available of all information supplied on the form. Documentation for Form 470 must be kept for 3 years, and 5 years for Form 471.
4) Review the recently released Cost Allocation Guidelines carefully before submitting the Form 471 so you are sure not to request discounts on an ineligible connection or service, or portions thereof. Using these guidelines is extremely important because the SLC will be approving or disapproving discount requests at the services ordered level (i.e., the
separate rows of Items 15 and 16). If the SLC determines that the pre-discount costs in any services ordered line item includes costs for ineligible services or for services to be provided to ineligible entities or for ineligible purposes, IT WILL DISAPPROVE FUNDING FOR THAT ENTIRE SERVICES ORDERED LINE ITEM (row of Item 15 or 16) even though the services ordered line item may also include support for eligible services to be provided to eligible entities.
5) You may want to disaggregate items for which you are seeking discounts on Items 15 and 16 if you are in any way unsure if a service is eligible. As stated previously, the SLC will be rejecting and approving requests by row. Therefore if you request discounts on one row for modems (an ineligible connection), and request discounts on another row for a network file server (an eligible connection), only the first request will be rejected, and not the entire application.
6) Attach all documentation requested and rationale as to why you entered the information you did. The more information, documentation, and calculations that you submit, the less likely the SLC probably will be to summarily reject your application.
7) Although we encouraged schools and libraries to not hastily submit their Form 471s a few weeks ago pending the release of additional resources and information from the SLC (such as the minimum application standards and cost allocation guidelines), we also encourage schools and libraries not to wait until the final week of the program to submit your Form 471. In the event that your Form 471 is summarily rejected by the SLC, you want to give yourself enough time to re-submit a new, accurate, Form 471 during the 75-day window.
8) Enter the SPIN for your service provider in Item 15 or 16, column 1. If you do not enter the SPIN on your application, the SLC will contact you to get it, and this will delay your application. You may want to require the service provider to include their SPIN in your contract.
9) Contracts for new services may not be signed until after the 28 day posting period for the 470 application. Likewise, no Form 471 should have a signing date next to the authorized signature that is before the 28-day posting period ends.
PEPPM and DGS CONTRACTS REMINDERS
* * * 1) Entities filing a Form 471 for purchases made from the PEPPM contract should be sure that in Block 2, Item 7 - Purpose of Request, Item 7a and Yes should both be checked so the SLC knows that a Form 470 was filed for the PEPPM contract. IF IT IS NOT CHECKED, THE APPLICATION WILL BE REJECTED.
Also, entities filing a Form 471 for purchases made from the PEPPM contract should insert on Items 15 and 16, column 4, the date that the PEPPM contract was executed (January 8, 1998) as the award date. The expiration date requested in column 5 should be the ending date for the contract for service executed by the applicant -- not the ending date of the PEPPM contract (December 31, 1998) as mentioned in a prior message. The service start date requested in column 7 should be the date the specific service was purchased from the PEPPM contract.
2) Entities should make their purchase from the PEPPM contract prior to filing the Form 471. If the entity cannot afford to pay 100% of the purchase price, then they should submit the signed request to the vendor, indicating product, cost, etc.(in order to indicate to the SLC on Form 471 that you have signed an agreement), but include language in your request to the vendor that you will not take possession of the product or service until after you have received a guarantee of your discounts from the SLC. Then, if you do not receive your guarantee, you are not obligated to purchase the product. This contingency was spelled-out to PEPPM vendors at the vendor conference on March 16.
3) In the past three weeks, we received a few inquiries whether we would be filing a Form 470 on behalf of the Department of General Services (DGS) Commodities Contract. It seemed that the schools desired to do business with a specific vendor that had a contract with DGS, but not with PEPPM. Although we felt this only would benefit a handful of schools and libraries, on March 13, we did file a Form 470 on behalf of several qualified contracts. If you are one of the schools who submitted this request to PDE, please contact Julie Tritt via e-mail (00jtritt@psupen.psu.edu) to request the pertinent contracts, dates, contract numbers, etc. that you will need to file your Form 471.
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