E-rate Update - SLC "Hot Tips"
Message Posted April 8, 1998
The Schools and Libraries Corporation has just released "hot tips" to assist those schools and libraries who haven't yet submitted their Form 471s. The statement includes tips on what's required for the worksheet of calculations (Item 14), how to tell the difference between site specific and shared services (Items 15/16), and what is acceptable as a list of services (Item 17). I know this document probably comes too late to help most of your who already mailed in your Form 471s. As a side note, I will be out of the office on Thursday, April 9, and Friday, April 10 and will not be checking e-mail or voice mail. I realize that many of you have had little luck getting through to the SLC toll-free number during the last week, but I encourage you to keep trying. And sending your questions via e-mail or faxing 888-276-8736 seems to be getting results for some schools I've talked to. Finally, don't forget that the SLC must have received your Form 471 by 11:59 p.m. on April 15 in order to have your application filed during the 75-day window.
-- Julie
Form 471 Hot Tips from the SLC
Item 14: "What's Required for the Worksheet of Calculations"
Note: This Hot Tip offers additional guidance and clarification for using the Instructions to the Form 471 Application for Item 14. Please do consult the Instructions to complete your application.
1. THE PURPOSE OF THE WORKSHEET OF CALCULATIONS
The Universal Service Fund is intended to provide discounts on services to schools and libraries according to their respective level of economic disadvantage and rural/urban status. Item 14 is set up to capture individual schools’ and libraries’ discount percentages AND the average discounts used for shared services by school districts, library systems, and consortia. These discounts are then used to fill in Column 11 of Item 15, if services are shared, and Column 11, Item 16, for site-specific services. (See the SLC Fact Sheet on Discount Calculations for the specific methodology that should be used by the different types of entities, such as library systems, schools, school districts, and consortia.) For each discount amount identified in Column 11 of Item 15, you should provide a Worksheet that shows the derivation of the discount calculation. This Hot Tip discusses what those Worksheets should show.
2. NO WORKSHEET REQUIRED FOR AN INDIVIDUAL SCHOOL OR LIBRARY BRANCH
a.Individual schools should calculate their discounts by using Item 14, Columns 4 and 5, and the Discount Matrix.
b.Library branches should base their discounts on the WEIGHTED average discount applicable to the school district in which they are located. To obtain this information, the library should:
--First, contact the school district administrator to obtain this information. Document the conversation with a memo stating the date, time and participants of the call and the pertinent discount information; or
--Second, contact your state department of education or state library agency to see if they may have the needed information. Document the source of the information, and the date of the information; or
--Third, if neither of the first two suggestions is successful, contact the Client Service Bureau at 1-888-203-8100 to ask us to help.
3. WORKSHEET FOR A SCHOOL DISTRICT OR LIBRARY SYSTEMS
If your Form 471 application requests discounts for one school district, you will need to provide a Worksheet which shows how you calculated the district’s weighted average discount based on each school’s individual discount. Consult the SLC Fact Sheet on Discount Calculation for specific advice on how to calculate the weighted average discount. For library systems, your Worksheet should show how you calculated the simple average of your individual library branches’ discounts (each of which is based on the weighted average discount of the district in which it is located).
4. WORKSHEET FOR A CONSORTIUM
Here’s what Worksheets should show for different kinds of consortia. --If the consortium comprises two or more school districts, your Worksheet should show the calculation of each district’s weighted average discount, and also the simple average calculation of the two districts’ discounts.
--If the consortium comprises one school district and one library system, your Worksheet should show the calculation of the district’s weighted average calculation; and the simple average of the district’s and library system’s average discount.
--If the consortium comprises one school district and one library system which is located in more than one school district, your worksheet should show the calculation of the district’s weighted average discount calculation; the library system’s simple average discount of the different districts’ weighted average discounts, and the simple average of the district’s average and library system’s average discounts.
Item 15/16: "Shared or Site-Specific"
Note: This Hot Tip offers additional guidance and clarification for using the Instructions to the Form 471 Application for Items 15 and 16.
Please do consult the Instructions to complete your application.
1. GENERAL RULE
A service is considered shared unless it is clearly site specific.
2. SHARED SERVICES—ITEM 15
a.WHAT’S THE TEST FOR "SHARED"?
Is the same service used (accessed) by more than one eligible school and/or library covered by this application?
b.WHAT’S USUALLY "SHARED"?
-- Telecommunications services are almost always considered SHARED
(see "Site-Specific," below, for exceptions).
-- Even dedicated telecommunications connections from individual schools or libraries to a district office or to a telecommunications company central office are SHARED.
-- Internet access and internal connections which are distributed among eligible schools and libraries may be shared services.
c.WHAT DISCOUNT APPLIES TO SHARE SERVICES?
--For shared services which cannot, without difficulty, be allocated directly to a particular entity, an aggregate discount rate comprising the discount rates of the entities who will be receiving a proportionate share of the shared services may be used to fill in Column 11 of Item 15 (see Form 471 instructions for more information).
Example: A school district has five schools whose discounts range from 20% to 90%. The weighted average discount of the school district is 70%. The school district receives one bill for telecommunications services provided to the five schools. The school district may apply the 70% discount to the telecommunications services and list this information in Item 15 under one row.
--If an individual institution’s discount rate can be easily applied to compute the requested amount of discounts, then that institution’s individual discount rate can be applied to a shared service. Each institution’s pre-discount cost should be identified as a separate row in Item 15, and its individual discount rate applied.
Example: A school district has five schools whose discounts range from 20% to 90%. The school district receives one bill for telecommunications services, and each school’s charges are separately identified on the bill. The average discount of the school district is 70%. The school district could complete the Form 471 application on behalf of the schools in either of the following ways:
-- The district could list each school’s "pre-discount cost" for telecommunications services as a separate row in Item 15, and fill in each school’s individual discount in Column 11; or
-- The district could list the total amount of the telecommunications bill as one row in Item 15, and fill in the average discount for the district in Column 11.
3. SITE-SPECIFIC SERVICES—ITEM 16
a.WHAT’S THE TEST FOR "SITE-SPECIFIC"?
Is the service used (accessed) by a single school or library and not available at any other school or library served by the billed entity?
b.ALWAYS "SITE-SPECIFIC"
-- Internal connections for a single school or library that is not available at any other school or library served by the billed entity.
-- Dedicated ("private line") connections from a single school or library to another end-user outside of the school district or library system or to an Internet Service Provider.
c.USUALLY "SITE-SPECIFIC"
-- Internet access that is provided to an individual school or library under a separate account with an Internet Service Provider that may or not be servicing other schools or libraries covered by the same application.
d.WHAT DISCOUNT APPLIES TO SITE-SPECIFIC SERVICES?
The individual school or library’s discount applies to site-specific services.
4. IF THE FORM 471 IS FILED BY AN INDIVIDUAL SCHOOL/LIBRARY BRANCH
Telecommunications services (except dedicated "private lines") should be listed in Item 15 as shared services. Internal connections and Internet access should be listed in Item 16 as site specific (in this instance, Internet access is a "dedicated service"). Your individual school or library branch discount would apply in all instances.
5. IF YOU THINK YOU MADE A MISTAKE
If you have already submitted Form 471, and mistakenly listed some shared services as site specific, or vice versa, you WILL NOT be automatically rejected. Instead, you may be contacted by the Problem Resolution Team who will work with you to correct your application. Please do not resubmit your application unless specifically requested to do so by the Problem Resolution Team.
6. REFERENCE MATERIALS
Form 471 Instructions, Block 5, Services Ordered SLC Clients Commonly Asked Questions-Set III (February 24, 1998), Question No. 3. SLC Clients Commonly Asked Questions-Fourth Order on Reconsideration, Question No. 15.
Item 17: What's Acceptable as a "List of Services"?
Note: This Hot Tip offers additional guidance and clarification for using the Instructions to the Form 471 Application for Item 17. Please do consult the Instructions to complete your application.
1. THE PURPOSE OF THE "LIST OF SERVICES"
Applicants must verify that discounts are being requested only for eligible services. Therefore, the "List of Services" you attach to Item 17 should: --specify the exact services provided under each contract (or tariff services account) you list in Items 15/16; and -- indicate that any ineligible services covered by these contracts are NOT included in Items 15/16.
2. WHAT A "LIST OF SERVICES" MUST INCLUDE
To fulfill the purpose of Item 17, any attached list of services must include the applicable contract number (for contracted services), the vendor's and contracting party's legal name, and a concise but specific break-out of services provided. If ineligible services are also being provided by the vendor, and if they are featured on the list, the applicant should clearly identify them as ineligible. A listing of pre-discount costs for eligible items is highly desirable but not required.
3. LIST OF ACCEPTABLE ATTACHMENTS
Any of the following are acceptable as attachments for Item 17 IF they include all the information specified in 2, above.
a.Form 471 Pre-Discount Cost Calculation Optional Grid. Primarily intended to help applicants accurately complete Items 15/16, the completed Grid will also satisfy Item 17. The Grid is available for downloading/printing at the SLC Web Site under Reference Area, 471 Application Guidance.
b.Vendor-created list. Service providers often have standard formats to describe the services or products for which they have contracted; they should provide this to you upon request, and applicants may find it useful to require this documentation in the contract.
c.Bill or invoice. If a service provider bill includes the information specified in number 2, above, the bill may be attached for Item 17. Please include only summary pages listing categories of services, and not every detailed transaction.
d.Purchase order, if based on and referencing a contract named in Items 15/16. Please remember that the Purchase Order may be sufficient documentation to meet the Item 17 list requirement, but it may not be sufficient to meet the requirement for Item 15/16 that there be a written binding contract or tariff services to support a funding request.
e.Applicant-created list. Applicants may create their own summary lists as long as they include all of the information specified in 2, above. If you or your vendor create a list specifically for this purpose, be certain it is legible and includes all the information specified above.
4. WHAT NOT TO ATTACH TO ITEM 17
Please do not send entire contracts or lengthy, minutely detailed bills. Note however, you will want to retain ready access to contracts, in the event that this information is requested by the SLC for a Program Integrity Assurance review or for a post commitment review.
5. HOW TO IDENTIFY INELIGIBLE SERVICES
Ineligible services and products may be included in the overall contracts and tariff service arrangements you document with your List of Services in Item 17, as long as you clearly indicate that you are NOT requesting discounts on these services. Therefore;
a.On a list you or your vendor create specifically for Item 17, list ineligible services under a separate heading.
b.On a bill, invoice, or purchase order, please highlight and clearly note them as ineligible, and NOT INCLUDED in your pre-discount costs claimed in Items 15/16.
6. URGENT REMINDER ABOUT ITEM 17
This item MUST be checked AND appropriate lists of services attached or your Form 471 Application will be automatically rejected.
7. NEED MORE HELP?
Call toll-free 888-203-8100, or send your query via e-mail.
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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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