Form 471 Filing Guidance When Transitioning to a New Broadband Service

March 22, 2019

I’ve received multiple inquiries this week about how to structure Form 471s when a new broadband service may be turned-up after July 1 and wanted to provide some important, last-minute filing guidance.  Unfortunately, E-rate rules do not permit applicants to request more than 12 months of service, nor will they hold a 471 application until the network cut-over is complete.  Please review the guidance below and follow the instructions based on your specific scenario.  The goal is to request 12 months of a service at the higher cost, and then after the new network is turned-up, do a true-up with USAC via a post-commitment process (yet to be established).

Summary of Form 471 Filing Guidance:

• Where all circuits will be cut-over on the same date:  Submit 1 FRN, requesting the higher cost and higher speed for 12 months.
• Where circuits will be cut-over on different dates:  2 OPTIONS:  a) Submit 1 FRN for each circuit, requesting the higher cost and higher speed for 12 months, or b) Submit 1 FRN, then submit a post-commitment request to break down the original FRN into multiple FRNs based on cut-over dates.
• Where the price of the new contract is LOWER than the price of the old contract:  Apply for 12 months at the higher prices (from the old contract) but reference the new Contract Record.  Then explain in the FRN Narrative Box that there likely will be a DELAYED TRANSITION OF SERVICE where the new contract has lower prices than the old contract.  PIA should then ask you to substantiate the higher prices and you can either send them a current invoice or refer them to your previous Contract Record in EPC (let me know if PIA balks at this).

Other:

• If you know the EXACT date of your network cut-over (and are 100% sure it won’t change), only then should you file 2 FRNs – one for the months with the old vendor and one for the months with the new vendor.
• If cut-over dates become known during PIA review (but prior to funding commitment), ask the PIA reviewer to split the FRN during their review.
• Recommendations to applicants/service providers:  If at all possible, do these 2 things:
  • Cut over all circuits on the same date.
  • Have any and all circuits cut-over on the last/first day of the month so that no funding is lost (EPC currently cannot split months in system).

Then What Happens: 

• After the network cut-over is complete, there will be a post-commitment process available to do a “true-up” with USAC where they will create multiple FRNs so you receive E-rate funding for both the new contract and the “hold-over” service that was provided before the cut-over was complete.  We’re working with USAC now to provide guidance on what that post-commitment process should entail to make it as easy as possible for affected applicants.  Stay tuned.

Please let me know if you have any questions.

— Julie

Julie Tritt Schell
Pennsylvania E-rate Coordinator
717-730-7133 – o
jtschell@comcast.net
www.e-ratepa.org