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Changes to E-rate Forms for Funding Year 8 Listed
Message Posted November 23, 2004

As presented at the Year 8 E-rate training workshops, there are changes to the Form 470 and 471 for Year 8.  All of the changes are detailed below; please review them carefully.  I'll also be sending a separate message reminding everyone what other changes to the rules have been made.     

Changes to the Form 470
When the Year 8 Form 471 window opens on December 14, applicants will find both a new Form 470 and new Form 471 that MUST be used.  Draft (but final) copies of both new forms are available on the SLD's website at: http://www.sl.universalservice.org/reference/Presentations2004.asp at the bottom of the page. 

Because applicants are not required to wait until the window opens to file their Form 470s, you are advised to post your Form 470s NOW, using the old, well-known, form.  If you wait until the window opens and use the new Form 470, the changes you'll see are these:

Item 7b: You will be required to indicate whether you are seeking a Multi-Year Contract or a MYC with extensions.

Items 8, 9, 10 and 11:  You will be required to indicate whether you are seeking discounted bills or the BEAR process.  This decision is non-binding.

Items 8, 9, 10 and 11:  If you site that you have an RFP, you will be required to also give a brief description of what services are being requested in the RFP.

Item 11:  Because of the new 2/5 rule which says you can only receive funding 2 out of every 5 funding years for internal connections, they have created a new category for basic maintenance in order to exclude this from the 2/5 prohibition.

Changes to the Form 471
Block 2 and 3:  The Impact of Services Ordered Section is now broken out into separate categories for schools and libraries.  The questions are more pertinent and you should only complete one block for ALL of your 471s.  If you submit more than one 471, only complete this section on ONE of your 471s. 

Block 4: 
-- You will now need to list the NCES Code (schools) or FSCS Code (libraries) for EVERY BUILDING EXCEPT NIFS (non-instructional facilities).  Every school has an NCES code and we will be posting these numbers for public schools on the PDE website shortly.  Nonpublic schools and other public schools that would like to find their NCES codes now, go to:  http://nces.ed.gov/help/sitemap.asp.  Libraries that would like to find their FSCS codes can go to: http://nces.ed.gov/surveys/libraries/librarysearch.  The SLD is attempting to gather all of the NCES and FSCS codes to prepopulate this information on your Block 4 so you don't have to enter each one, but it's unknown whether they will have this internal exercise completed when the window opens.

-- In addition, you will be required to submit an FCC Registration Number for every building in your Block 4.  Unfortunately, the FCC made this a rule after the forms had been developed, so there will be no actual space to include this information on your form.  You will have to fax or mail this information to the SLD when you submit your Item 21 attachments.  To obtain your FCCRNs, go to www.fcc.gov and click on "FCC Registration Number System" on the left toolbar.  You should know that the SLD is requiring each applicant to obtain at least one FCCRN for your entity, and they are supposedly working to have the individual FCCRNs assigned to each individual building.  I'll write as I learn more.

-- There is a new column asking if the building listed in each row contains one of the following:  Pre-kindergarten?  Juvenile Justice?  Adult Education?  Be careful here.  In Pennsylvania, pre-k is not E-rate eligible, and if you check this box, they will require you to not only cost allocate your bills, but will closely scrutinize your discount calculations to ensure that your total enrollment and NSLP data does not include these pre-k students.  Juvenile Justice IS eligible in PA.  Sources vary on whether Adult Education is eligible as K-12 education in PA, so be extra careful with this question. 

-- There is a new column asking whether you are using NSLP data obtained from a source other than actual NSLP participation data that is submitted to PDE.  For example, if you used a sibling match or family income survey to obtain the data, then you would check this box.

Block 5:
-- Item 10: Is this funding request a duplicate FRN from a previous year?  If so, provide the FRN # from the previous year.  Although I don't know for certain the implications of checking this box, my gut reaction is to advise you to not check this box as it may delay in getting your application reviewed or funded pending a decision on your previous application.

-- Item 15c: Is this service being purchased from a Master Contract, such as PEPPM or a regional consortium?  Meaning, did an entity other than yours post the 470?

-- Item 15d: Is this funding request a continuation of an multi-year contract from an FRN from a previous year?  If so, provide FRN#.  I believe this is a GREAT new item, as it seems to indicate that if they have thoroughly reviewed your contract from a previous year and it was funded, the contract and FRN will receive must less scrutiny in the latter years of the contract.

-- Item 16b: Previously, the Block 5 asked what your Billing Account Number was.  Now they are asking you to list one in your Block 5, and list all of the other number on a separate page with your Item 21 attachment.  This does not include all of your individual phone numbers -- just your Billing Account Numbers. 

New Certifications
The reason the 471 window is delayed in opening is because of the inclusion of new certifications on the Form 471.  Some are significant -- especially the new Item 25 Tallies described below. You are certifying that you...

* Have secured access to all non-eligible resources (computers, training, software, maintenance, etc).
* Have a Tech Plan written that covers all 12 months of the funding year.
* Have carefully considered all bids and selected most cost effective solution with price being primary factor.
* Have complied with state procurement laws.
* Won’t resell services or products -- ever.
* Will retain all documents for 5 years, including winning and losing bids, invoices, etc.
* Are authorized to submit the application.
* Acknowledge that if you lie or cheat that you’ll be disbarred from program and prosecuted.
* Have cost-allocated out any ineligible functions or components.
* Haven’t violated 2/5 rule.
* Know that the non-discounted portion won’t be paid or waived by service provider and that you have the money in your budget to pay for it.

* Nothing free is or will be offered by service provider.

Item 25 Tallies
In the middle of your certifications, the form now magically tallies the total amount of your services, your total funding request, and the total amount that will be your non-discounted portion of the cost.  THEN it requires you in Item 25D to list the total budgeted amount allocated in your budget to resources NOT eligible for E-rate, such as professional development, software, hardware, retrofitting and maintenance.  These amounts just need to be listed as an aggregate figure, but you should be able to back up your number based on real figures in your budget.  Then the system will add up the total amount that you should have set aside (Item 25D as well as your non-discounted portion) and it will ask you to certify that you have this amount in your budget. 

A: total pre-discount amount
B: total funding request
C: total applicant non-discount share
D: total budgeted amount allocated to resources NOT eligible for E-rate
prof development, software, hardware, retrofitting, maintenance
Tally worksheet provided*
E: total amount applicant must pay A+B+C+D = E

Item 25F: This asks if a service provider is providing you with any portion of your non-discounted funding or helped you to find the money.  NEVER EVER EVER EVER CHECK THIS BOX.  It's a gotcha.

If you have any questions about these changes, please don't hesitate to contact me.  Happy Thanksgiving, everyone!

-- Julie

Julie Tritt Schell
jtschell@comcast.net

(717) 730.7133 (voice)
(717) 730.9060 (fax)

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