FY 2013 E-rate Application Window Closes - Now What?
March 18, 2013
Congratulations to everyone who successfully submitted and postmarked or eCertified their Form 471s by midnight, March 14th! The next phase in the funding process is for the SLD to review the 42,000+ applications that were filed in the window, to determine if they have complied with all program rules and deserve funding. To my knowledge, PIA has not yet begun contacting applicants but is expected to do so in the next few weeks. If you missed the Form 471 deadline for a really good reason, please contact me ASAP.
If you need to make a correction to your Form 471, cancel a Form 471, cancel a funding request, add a funding request or increase/decrease the amount you requested, you should do so using the PINK Receipt Acknowledgement Letter (RAL). A RAL is sent for each Form 471 that has been submitted/certified and summarizes each of your funding requests. If nothing needs changed on your Form 471, no applicant action is required. If you need to make a correction, cancel an FRN, cancel the Form 471 completely, you can do so by making the changes to the RAL and faxing back to USAC. You also may add a forgotten funding request or even increase a funding amount using the RAL, but only if you have a substantiating document that's dated prior to the date you submitted your Form 471 (such as an invoice or signed contract). RAL changes should be faxed to 973-599-6526.
Listed below are the next steps that you should review.
1) Print a Copy of Your 471
If you haven't already done so, go back to the SLD website and print a copy of your submitted 471 for your files. Go to: http://www.sl.universalservice.org/menu.asp, then "Display." Enter your Form 471 number and select 'original' version of your form to view (you do not need your security code to display your 471).
2) Submit Your Item 21 Attachments
Although the Item 21 attachments were required to be submitted by the Form 471 deadline, there will be a grace period to provide limited relief to applicants who were not able to get their Item 21 attachments submitted by the deadline. If the SLD determines that Item 21 information is missing, the SLD will send the applicant a written notification requesting the Item 21 attachments and grant the applicant 15 calendar days to timely submit their information to the SLD. If the Item 21 information is not received within 15 days, the funding request(s) will be denied.
The easiest and preferred way to submit your attachments for Priority 1 funding requests is through the SLD's Online Item 21 system (http://www.sl.universalservice.org/menu.asp then "Item 21 Attachment"). The best way to submit Item 21 attachments for Priority 2 requests is either by fax (973) 599-6511 or e-mail email@example.com.
3) Review Your School's CIPA Policy!
The new CIPA requirements went into effect July 1, 2012. This is a good time to make sure your school has updated its Internet Safety Policy to include provisions to educate minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response, and that your school is educating students about online safety/cyberbullying. The FCC release FAQs on the new CIPA requirements and they are available at: http://e-ratepa.org/Listserve-Archive/2012/11-14-12_2.html.
4) Requesting Priority 2 Funding? Review Your Technology Plan!
If your school or library is requesting any Priority 2 funding for FY 2013, be sure that you have a technology plan that covers the services included in your 471(s) and that it covers the full Funding Year 2013 (July 1, 2013 - June 30, 2014). If your technology plan expires, needs updated, etc, be sure you submit it to the appropriate approving agency ASAP as the plans must be approved by July 1, 2013. For public school entities, technology plan elements must be included in your LEAs Comprehensive Plan. If your Comprehensive Plan is not yet due, you may use the eStrategic Planning Process to create a "bridge" plan to cover the years until your CP is due. If you are a public school entity and are unsure when your plan is due, you can view the status here or contact the CP helpdesk at firstname.lastname@example.org with questions.
5) Review your 2013/14 Draft Budget
Does your 2013/2014 budget contain your non-discounted amount or "fair share"? Meaning, if you requested $40,000 and your discount is 50%, is your share -- $20,000 -- in your budget?
6) Wait for PIA Review
The Program Integrity Assurance (PIA) review is a detailed application review conducted by PIA staff in Whippany, New Jersey. Inquires from PIA reviewers (identified by direct telephone numbers with a 973 area code) generally involve requests for clarification and/or additional documentation on product or applicant eligibility, discount rate calculations, non-instructional facility validation, etc. These are serious inquires that must be addressed in a timely fashion. PIA inquiries typically provide 14-day deadlines for responses. PIA review is often a multi-step process. A reviewer may request additional data once he/she (or a higher-level review team) has reviewed an initial response, or may initiate a second request on an entirely different application issue. To see if your application has already moved to "initial review" status, go to http://www.sl.universalservice.org/menu.asp and click on "Application Status" then enter your Billed Entity Number, then click 'continue' on the next screen.
7) Retain Your Records
The FCC rules require applicants and service providers to keep a myriad of documents. Here is what is required to be kept relating to competitive bidding, contracts and 471 application process:
-- Request(s) for Proposal (RFP(s), including evidence of the publication date; bid evaluation criteria and weighting; bid evaluation worksheets
-- All written correspondence between the beneficiary and prospective bidders regarding the products and service sought
-- All bids submitted, both winning and losing
-- Signed and dated contracts, as well as all amendments and addendums
-- All documents relied upon to submit the Form 471, including National School Lunch Program eligibility documentation supporting the discount percentage sought; documents to support the necessary resources certification, including budgets; and documents used to prepare the Item 21 description of services attachment.
So sit back, review your RAL for accuracy, submit your Item 21 attachments if you haven't already done so, make sure your technology plan is up to date, make sure that your 2012 budget contains the non-discounted portion of the cost of the service, and wait for PIA to contact you! The next form to submit will be the Form 486, and you can't file that until after you receive your funding commitment decision letter. I'll explain more when that time comes.
Please e-mail me if you have any questions! And again… congratulations on another successful E-rate filing window!
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 - o
717-730-9060 - f