SLD Now Requiring Entity Numbers for Non-Instructional Facilities
Message Posted January 18, 2004
Last April, the FCC released a decision which expanded the definition of
“educational purpose” for Telecommunications and Internet Access Services
(priority 1) to separate administrative buildings and other
non-instructional facilities (e.g., bus garages) beginning with Year 7
(Funding Year 2004). In order to implement this change, the SLD has
finally released a reference document "Entity Numbers for Non-Instructional
Facilities" which requires applicants to obtain entity numbers for two types
non-instructional facilities and then list those facilities/entities on the
Block 4 discount rate worksheets of their Form 471s.
WHAT TYPES OF BUILDINGS NEED/DON'T NEED ENTITY NUMBERS?
Need:
1) A separate building (or facility) located on a school (or library)
property that serves multiple schools (or libraries). An example would be
an administrative building (or even a bus garage) located on high school
property that serves the entire district. If the facility serves only one
school, no separate entity number would be required.
2) Any separate facility located on a separate school or library property.
Don't Need:
1) All other facilities, such as modular classrooms that sit on a school's
property, and admin offices that reside in a school, would not be required
to have entity numbers.
WHERE CAN ENTITY NUMBERS BE OBTAINED?
Entity numbers for these facilities can be obtained by calling the SLD’s
Client Service Bureau (888-203-8100). When you reach the recording, press
'0' to speak to a live CSB representative.
WHAT DISCOUNT WILL THE NEW ENTITY USE?
When listing a non-instructional facility on a Block 4 worksheet, use “0”
for the total number of students, and "0" for the total number of NSLP
eligible students. Then check the box which says, "non-discount matrix",
and enter the District or Library's shared discount rate. If you're not
sure what your shared discount rate is, enter all of the entities that have
students first, then look at the discounted listed at the bottom of the
Block 4 calculations where you will see, "Weighted Average Discount % for
Shared Services (#8 total / #4 total X 100) for this worksheet: XX%" (this
will be in RED numbers). Then go back and enter your non-instructional
entity, and use this discount where it asks for a non-matrix discount.
WHEN DOES THIS NEW REQUIREMENT TAKE EFFECT?
This rule becomes official for Year 8 (2005). For Year 7 (2004), ideally
applicants would get entity numbers for these types of facilities and list
them on their Form 471, Block 4. Given the current stage of the application
cycle, the SLD has set forth interim guidance for Year 7/2004. At a
minimum, the following guidelines apply:
1) Priority 1 services provided to non-instructional facilities —
particularly site-specific, not networked, services — should be clearly
labeled as such on related Item 21 attachments. If necessary to meet this
requirement, applicants who have already filed Form 471 applications with
attachments for FY 2004 should resubmit their Item 21 attachments.
2) Applicants, who have not yet submitted their Form 471 applications,
should include Block 4 references to non-instructional facilities. If
specific entity numbers for these facilities are not obtained, the
applicants can use either of two dummy entity numbers created by the SLD
(“88888888” for libraries and “99999999” for schools). These numbers will
work only on an interim basis for FY 2004. Only 1 entry described as
“Non-Instructional Facilities” on the Block 4 should be listed regardless of
how many such facilities exist. During PIA review, applicants may be asked
to add entity numbers as appropriate.
CAN BOTH THE ONLINE 471 AND ONLINE INTERVIEW 471 BE USED IF I HAVE
NON-INSTRUCTIONAL ENTITY NUMBERS?
No, the 471 interview format doesn't allow you to enter non-instructional
entity numbers. However, the traditional online format, called "Create Form
471", does permit you to enter such entity numbers.
DOES THE FCC'S NEW DEFINITION OF EDUCATIONAL PURPOSE EXPAND INTERNAL
CONNECTIONS E-RATE FUNDING FOR NON-INSTRUCTIONAL BUILDINGS?
No, the new rule does not apply to Internal Connections (Priority Two).
This means, for example, that network equipment and services for standalone
administrative LANs remains ineligible.
If you have any questions, please don't hesitate to contact me.
jtschell@comcast.net
(717) 730.7133 (voice)
(717) 730.9060 (fax)
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