E-rate Update - Tariff Services Clarifications
Message Posted March 31, 1998
SLC ISSUES CLARIFICATIONS ON RETROACTIVITY DATES FOR TARIFF SERVICES
Today the SLC issued the following newsflash to clarify misunderstandings created by their recent announcement that tariffed services would not be retroactive to January 1. The most significant item in this announcement states that if you already submitted your Form 471 reflecting the assumption that the discounts would be retroactive to January 1, your application will NOT be rejected. Instead, the SLC will adjust your application to reflect the correct date and will contact you to determine if the amount requested in the application will need adjusted. Please be sure to read the entire document as it provides additional clarification on tariff reference numbers and rebidding tariffed services in subsequent years. -- Julie
TARIFF SERVICES AND YOUR FORM 471: IMPORTANT CLARIFICATION AND INSTRUCTIONS
The Schools and Libraries Corporation (SLC) recently announced that tariff services--telecommunications services purchased under terms and conditions prescribed in a state or federal tariff and NOT set forth in a written, binding contract signed on or before January 30, 1998--would NOT be eligible for discounts back to January 1, 1998. Our thanks go out to the many clients who have contacted us--applicants and vendors alike--with urgent questions about this policy and how it will impact the processing of Form 471 applications. This Clarification Advisory is intended to answer those questions.
Q. (1) What exactly are tariff services?
A. Tariff services are those telecommunications services that are purchased at prices regulated by your state regulatory commission and/or the Federal Communications Commission (FCC). The prices, terms and conditions of these service offerings are set forth in tariffs that are on file at the regulatory commission. Unlike other E-rate eligible service, these services usually are not covered by a formal written contract. The items listed in the Telecommunications Services section of the SLC Eligible Services List--such as basic phone service and long distance service--are offered through tariff prices. Tariff prices may be used as the "pre-discount" cost for services that are eligible for discounts. This may happen when the tariff price is the "lowest corresponding price": the price charged to similarly situated non-residential customers for similar services, or when no alternate bidders have responded to your request for services posted in your Form 470.
Q. (2) Why aren't the discounts on tariff services retroactive to January 1, 1998?
A. The Form 470 instructions required applicants who were obtaining services from tariffs to post a competitive bid for those services. The FCC rules prescribe that services obtained from the posting of a request for new services cannot become effective until after the 28-day waiting period for the 470 Web Site posting has passed. Because FCC rules require tariff services to be considered "new services," the 28-day waiting period must be applied to tariff services.
Q. (3) What dates SHOULD I include in my Form 471 for tariff services?
A. Please remember that all tariff telecommunications services--like any other service not covered under a pre-existing, signed, written contract--are subject to competitive bidding. Once you have filed your Form 470, your request for telecommunications services must be posted on the SLC Web Site for 28 days. On or after Day 29, you can choose to continue to receive tariff telecommunications services from your current service provider, OR, if you have received another, more cost-effective bid, you may switch to a different service provider. If you continue with your current service provider, the "Start Date" in Items 15 or 16, Column 7 of your Form 471 Application will the date of Day 29. If you switch service providers, the Start Date will be the date your service with the new provider begins, and can be no earlier than Day 29.
Q. (3) What if I already have filed my Form 471 for tariff services using a different date, such as January 1, 1998?
A. If your Form 471 application already has been submitted, and includes a "Service Start Date" (Item 15/16, Column 7) that predates the 29th day after your Form 470 was filed, your application will NOT be automatically rejected. Instead, the SLC Problem Resolution Team will adjust the date to Day 29 and then contact you (by your preferred mode of contact) to determine whether your Estimated Pre-Discount Costs (Items 15/16, Columns 8-10) should be adjusted accordingly.
Q. (4) Do I have to include "tariff reference number" in my Form 471 Application?
A. NO, you do not HAVE to list tariff reference numbers on your Form 471 Application. Apparently, our March 23rd News Flash and Subsequent Web Site announcement on this subject generated a lot of concern. These materials cross-referenced the Instructions accompanying the Form 471 Application and stated that the tariff reference number should be filled in Column 3 instead of a contract reference number. However, recognizing that many of you may not be familiar with what a tariff reference number is, we will accept as a valid entry the letter "T" in column 3 of Items 15/16 OR a tariff reference number. Although you do not need to include these numbers in your Form 471 Application, you may need them if you are audited by SLC or if you are contacted by our pre-commitment Program Integrity Assurance Team. We recommend, therefore, that you work with your service provider to obtain this information and maintain it as part of your recordkeeping responsibilities.
Q. (5) What will I do about tariff services for 1999?
A. This July 1, when SLC begins accepting applications for the 1999 calendar year, you will have to submit a new Form 470 Request for Services, post your bid to the Web Site for 28 days, receive and consider the bids in response, and then make your choice of service providers on or after Day 29. You will then have to complete a new Form 471 Application. All applicants--whether they are procuring new services or continuing with services already under contractØmust file Forms 470 and 471 to apply for discounts each year, although applicants with written multi-year contracts will not be required to re-bid those contracts each year.
Q. (6) Does this mean that I should try to get a formal contract for these services instead of buying them under tariff?
A. The Universal Service Program is not intended at all to change the way that you and the telecommunications companies do business. Tariff services are and will continue to be eligible for discounts; they also will be subject to competitive bidding each year. If a telecommunications company offers you a written binding contract for these services, you may enter into such a contract if you believe it is the most cost effective option for you.
Q. (7) I'm still confused. What should I do?
A. The SLC Client Service Bureau has been specially briefed on the tariff services issue and is ready to help. Please call toll free 888-203-8100.
SPECIAL REMINDER: The SLC strongly encourages all schools and libraries to submit their Form 471 Applications in a correct and prompt manner. If you are hoping to file your Form 471 Application within the 75-day window, which closes on April 15, please do not wait until the last minute to do so. Remember, your Application MUST BE RECEIVED by April 15, and it must pass the Minimum Processing Standards. The earlier we receive your Form 471, the better able we will be to work through with you any questions or problems that we see.
Please mail your carefully completed Form 471 to: Schools and Libraries Corporation, P.O. Box 4217, Iowa City, IA 52244-4217, or send via express delivery to Schools and Libraries Corporation, c/o Sherri Chalupa, 2510 N. Dodge Street, Iowa City, IA 52245. No Form 471s will be accepted via e-mail or fax.
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Julie L. Tritt
Office of Educational Technology 717/787-5820
Pennsylvania Department of Education 717/787-7222 (fax)
333 Market Street, 10th Floor 00jtritt@psupen.psu.edu
Harrisburg, PA 17126 www.cas.psu.edu/pde.html
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