E-rate Changes and Updates for Funding Year 2014
November 6, 2013
During yesterday's E-rate Webinar for E-rate Veterans, several important changes and reminders were provided to attendees. Attached is a copy of the PowerPoint from that training and the major changes/updates are summarized below. If you didn't attend yesterday's webinar, please read the following message carefully.
FY 2014 Eligible Services List Released - The only substantive eligibility change is a clarification that you cannot have 2 funding requests in the same year for webhosting service.
FY 2014 E-rate Application Window Dates - USAC has not yet set the FY 2014 Form 471 application window dates, but we expect the window will open on or around January 8 and will close on or around March 18. I'll e-mail the listserve as soon as the exact dates have been set.
New Form 470 - Soon there will be a new Form 470 released and the most significant change will be to align the form to the new rule that (for the purposes of the Form 470 only), there is a single Priority 1 category instead of separate Telecommunications Services and Internet Access categories. Applicants will still be required to choose the proper category on the Form 471, but if they don't, this can be corrected. In the meantime, use the currently posted Form 470 but know that you can post your P1 services in either the Telecom or Internet category.
New Form 471 - When the Form 471 window opens in January, there will be a new Form 471. The new form replaces the old Block 2 (the inventory/assessment chart), with several additional items in Block 5. If your funding request is for broadband or other types of connectivity (this includes mobile broadband and data services), you must complete the data-gathering chart in item (a), as well as questions (b) and (c). If your Block 5 is NOT for broadband services, you may check a box and then skip the questions. Question (a) asks the type of connection (fiber, cable, etc), # of lines, and download speed. Question (b) asks what percentage of the classrooms/public library spaces have wired and wireless Internet access. Question (c) is for consortia applications, and asks if the connections in this FRN include the last mile connection to the school or library, and if not, are these just backbone connections.
PEPPM Will Not Be E-rate Eligible Beginning in FY 2014 - For several reasons directly related to new E-rate rules and interpretations, the PEPPM contract will not be eligible for use beginning in Funding Year 2014. Therefore, schools and libraries that want to apply for Priority 2 funding for FY 2014 must post their own Form 470s (using the words "or equivalent"), simultaneously bid in local newspapers, evaluate all vendor proposals received (including equivalent equipment bids), obtain board approval (pending E-rate funding), and sign a contract with the awarded vendor -- all before the Form 471 is filed in March. Be sure to build-in extra time to complete these tasks.
Priority 2 Form 470/RFP Requirement - Beginning with FY 2013, applicants must list "or equivalent" language on the Form 470s for Priority 2 services and equipment. For example, you cannot say, "HP 2510 Switch," but you are permitted to say, "HP 2510 Switch or equivalent." Any bids received with comparable equipment must be considered in your bid evaluation. If you don't use these words, USAC will deny your application.
New RFP Definition - USAC has recently stressed that if an applicant posts a 470 and then provides additional written instructions or information to bidders, this would constitute an RFP for E-rate purposes and therefore the box indicating you have an RFP must be checked on the 470. Providing prospective bidders with building addresses and answering vendor questions is ok.
Caution Providing Contracts to Multiple Service Providers - Based on a recent FCC appeal decision, USAC is instructing applicants that they cannot request funding for the same service from multiple service providers, that resulted from the same 470 procurement. The FCC believes that in the same procurement there can only be one 'most cost effective bid.' Service from different vendors from different procurements should be fine as well legitimate reasons for multiple vendors, such as service territory/service quality issues.
Off-Campus Internet Access - Please don't forget that E-rate does not cover any off-campus usage of data service, 3G/4G service or aircards, even when used for educational purposes. On-campus usage of these services remains eligible. If you need to do a cost allocation, you may either deduct the ineligible amount from the pre-discount price on the BEAR Form 472 before it's submitted, or instruct your cellular provider to deduct a certain percentage from your monthly discounted invoices. I realize this rule sounds antiquated, but it is the rule.
Bid Disqualification Reasons - Reminder, if you're going to disqualify any proposals, those reasons must have been pre-stated in the Form 470, Item 13 section or in your RFP. Bid evaluation criteria itself does not need to be posted upfront.
The Form 470 can be filed NOW at: http://www.sl.universalservice.org/menu.asp. I will be sending detailed information on filing the Form 470 in the next week, but applicants should begin preparing to file their FY 2014 Form 470 to competitively bid their services in the next few weeks. Don't forget, you must post a Form 470 and competitively bid your E-rate-discounted services every single year unless you're in a multi-year contract. File your 470 by Thanksgiving!!!
If you have any questions, please e-mail me at email@example.com. E-mail is always the best way to reach me!
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 - o
717-730-9060 - f