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How to Receive Discounts When Your Service Provider Changes
Message Posted September 18, 2008

Now that applicants are completing their FY 2007 E-rate BEAR reimbursement forms, a common question is what they should do if their service provider changed mid-year or if the services were provided by a completely different service provider than what was listed on their funding commitment letter.  Both of these situations are easily corrected by following the instructions below.

1) When the Provider Has Changed Mid-Funding Year or the Service is Split Between Two Providers:

If the service provider listed on the original 471 changes mid-funding year and the service has been provided by two different vendors within the same funding year, the applicant must request a SPLIT FRN. There is actually no guidance on the SLD website describing a SPLIT FRN, but the impact of filing an Operational SPIN change and stating that two vendors are providing services under the same FRN in the same funding year, will be that the SLD will consider it a SPLIT FRN (whether the applicant calls it that in their correspondence or not). Item 18 of the SPIN change requirements asks, "Has the original service provider supplied any services under this funding request?"  In this case, answer 'yes' and then proceed to answer the next questions relating to the number of months each vendor has provided services, and the division of pre-discount amounts that should be allocated to each vendor.

Hint:  Although the SLD's guidance doesn't state it, it is permissible to state that each vendor provided 12 months of services.  Meaning, you don't have to list that the total months of service provided by both vendors equal 12 months.  This is important because it is quite common for vendors services to overlap and not have a clean cut-off and start dates. 

Important: When the SPLIT FRN is approved, the SLD will create a new FRN for the amount of funding that has allocated to the new service provider.  A revised Funding Commitment Decision Letter also will be mailed to the applicant showing the original FRN, now with reduced funding, and the new FRN showing its share of the original funding. Because a new FRN has been created, the applicant then must file a new Form 486 for that FRN within 120 days of the date on the revised Funding Commitment Decision Letter. 

Also, a BEAR for the new FRN (new vendor) cannot be submitted until the new FCDL has been issued and the Form 486 has been submitted.  However, a BEAR for the original vendor FRN can be submitted.  In fact, it's often advantageous to calculate the amount that should be on the BEAR for the original vendor so you can calculate how much funding is remaining on your FRN in order to tell the SLD in the Split FRN request how much funding should follow the new FRN. 


2) When the Provider Has Changed,
AND the New Provider Has Provided All Services Since the Start of the Funding Year:
If the service provider listed on the original Form 471 changes, and the new provider has been providing services for the entire funding year, the applicant should notify the SLD of an Operational SPIN change. In this case, the SLD will change the SPIN in their databases, keep the original FRN number, and notify the applicant that the SPIN change has been approved. The applicant does NOT have to refile The Form 486 for the new provider.  After the applicant receives the SPIN change approval from the SLD, the BEAR can be submitted.

Instructions for completing SPIN changes are at: 
http://www.universalservice.org/sl/about/changes-corrections/operational-spin.aspx.  The deadline for requesting SPIN changes is the last date to invoice (typically October 28 for recurring services).  When the SPIN change or Split FRN is approved, the applicant will automatically be given an invoice deadline extension of another 120 days in order to submit their BEARs.

If you have any questions related to SPIN changes, please don't hesitate to contact me at jtschell@comcast.net

-- Julie

717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
Penn*link

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