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Time to File Your Form 470 FY 2008!
Message Posted October 17, 2007

~ 471 Window Dates Have Not Been Set ~

Although it's hard to believe, it's time to begin posting your Form 470's for Funding Year 2008!   Although the very last possible date to file a 470 is 29 days before the 471 window closes, do not wait this long to file, as it will only give you one day to open bids, evaluate proposals, sign contracts, and file your 471 inside the window.  I encourage everyone to file their 470's before Thanksgiving recess which will give you all of January to evaluate your bids, sign your contracts and file your 471.

In December, I'll be sending out a list of districts that haven't yet posted their 470's, so if you don't want to be on the list, file soon! Simply go to: http://www.sl.universalservice.org/menu.asp and click on 'Create Form 470.'

NOTE:  The SLD has not yet set the FY 2008 Form 471 Filing Window Dates, but we expect the window to open in mid-November and close either the last week in January or the first week in February.  I'll let you know as soon as the exact dates are announced.

Below are some helpful reminders and answers to the most common Form 470 questions:
1) Check Item 7a and b. There is no harm in checking 7 a and b and all of the boxes under 7b (that you are seeking MTM services and/or contracted services and/or multi-year contracts and/or multi-year contracts with voluntary extensions). In fact, if you intend to sign a multi-year contract or a contract with voluntary extensions, you MUST check 7b and its associated boxes.

2) File in both the Telecom and Internet categories. If you are at all unsure which category of service you should choose on the 470, put the services in both. It never hurts to have your service description listed in too many places and provides you the maximum flexibility when selecting the correct category of service on your Form 471. If you are filing for Blackberry/Treo Internet/e-mail services, you MUST file in both categories.

3) Rebidding contracts and MTM services. If you have a contract expiring on or before June 30, 2009, you must post a Form 470 to rebid that service. OR if you are receiving service under a month-to-month agreement and don't have a contract, you also must post a Form 470 to rebid that service.

4) Form 470's for multi-year contracts:  If you posted a Form 470 in a previous year, and then signed a multi-year contract that expires on or after June 30, 2009, you are not required to file a Form 470 for FY 2008.  If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if BOTH of these conditions are met: a) You notified bidders on the 470 or RFP that you were seeking a contract that contained voluntary extensions, and b) Your contract contains the terms of the voluntary extensions (meaning the exact number of years or dates that the extensions can be exercised and it's not just open-ended). Otherwise, you must post a Form 470 to extend the contract.

5) File online, even if you don't have a PIN. If you haven't received a PIN, file online, and then mail in your signature/certification page after you hit submit. The SLD will then mail you a PIN in a few weeks. There is no way to request a PIN unless you have first signed a paper certification.

6) Include all of your services on a single 470. There is no maximum number of 470's that you may submit, although it is a good idea to place all of your services on a single Form 470 because then you only have a single 470 number to keep track of for this year.  However, there is no harm in filing two or more 470's. Also, there is no way to amend a 470 after it's been submitted. If you need to change your services, you need to file a new Form 470 (in which case your 28-day clock restarts).

7) Price must be the most heavily weighted factor. Don't forget... you may have as many criteria as you like, but price (alone) must be the heaviest weighted factor. For example, if you have 4 criteria that you are using to judge proposals, price must be at least 26% of the weight, will all others being 25% or less. You also must keep track of the evaluation process you used to select the winning proposal.

8) Instead of using the print preview feature, after you've submitted your 470, go back to the "apply online" page and choose the "search posted" option. Then type-in your 470 number and print off a complete, clean copy of your application. At the top of the completed form it also will show you your allowable contract date (ACD), which is the first date you can sign contracts and file your 471.

9)  Technology plan must be written before the 470 is filed.  If your technology plan does not cover July 2008 - June 2009, E-rate rules require your new technology plan to be "written" before your 470 is filed.  Your technology plan doesn't have to be approved until July 1.  What constitutes "written?"  The SLD has stated that the plan does not need to be finalized or submitted for approval by the 470 date, but it should be far enough along in its development that it can reasonably support your requests for discounted services. If your plan isn't changing much from your previous plan, I encourage you to print your existing plan and mark up changes on it, along with a date showing you made those edits before you submitted your 470.  That way if the SLD asks you to prove when your technology plan was written, you can easily show them that draft.

* The SLD's 470 guidance can be found at: http://www.universalservice.org/sl/applicants/step03/.

If you have any questions, please contact me at jtschell@comcast.net.

-- Julie