Time to File the E-rate Form 470 for FY 2020
November 21, 2019
Attached: Form 470 Category 1 Filing Guide – FY 2020
Attached: FY 2020 Rebidding Status for Category 1 Services (1)
Attached: Internet Access Form 470 Filing Cheat Sheet
~ List of PA Applicants that May Need to File 470 for Recurring Services Attached ~ ~ Category 1 Form 470 Filing Guide Attached ~ ~ Internet Access Form 470 Cheat Sheet Attached ~ The Form 470 marks the start of the FY 2020 funding year because it opens the competitive bidding process for equipment and services that aren’t yet under contract for FY 2020. In the Form 470, schools and libraries identify and seek proposals for the products and services they need, and for which they will be requesting E-rate discounts, so that potential service providers can review your requests and submit proposals to you for consideration. Attached is a Form 470 Filing Guide for Category 1 services that provide complete details and step-by-step screenshots showing how to complete the Form. Category 2 bidding and filing instructions will be sent after the FCC releases the Category 2 Order in the next few weeks. Form 470 Changes for FY 2020 The FCC is expected the make major changes to the form for next year, but for FY 2020, the Form 470 has not changed. This means that the ‘unusual’ Internet Access choices are the same. Essentially…
- If you are seeking proposals for Internet delivered over Fiber Transport, you must select “Leased Lit Fiber (with or without Internet Access)” and then explain in the narrative that you’re seeking Internet and at what bandwidth.
- If you are seeking proposals for Internet via a different mode of transport (cable modem, DSL, etc.), then you must select “Internet Access and Transport Bundled – Non-Fiber.” But be careful not to specify which transport mode you’re seeking.
- If you are seeking proposals for both Internet delivered over Fiber, AND a separate Leased Lit Fiber wide area network, you should create two separate services on the 470 and then explain in the narrative what exact services you want for each. Why? The “Leased Lit Fiber” service drop down option is used for two things: 1) Internet Access service that is delivered over a leased lit fiber circuit, and 2) Leased Lit Fiber circuits – not including Internet — but you’ll want to make it clear to vendors that you’re actually are seeking proposals for different types of services.
To help you decide which Form 470 drop down to select based on the actual service you’re seeking, I’ve created the attached Internet Dropdown Cheat Sheet. Note that that transport selections are at the top of the chart and the Internet selections are at the bottom in red – but these are not the same order as you will see them on the actual Form 470 drop down list. When Must a Form 470 be Filed?
1) If a service is covered on a Month-to-Month basis (meaning no contract), a new Form 470 is required annually.
2) At the beginning of any new contract. Note: If you posted a Form 470 in a previous year, and then signed a multi-year contract that expires on or after June 30, 2020, you are not required to file a Form 470 for FY 2020. If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if your original 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.
Who Must File for FY 2020? Attached is a list of all recurring services FRNs submitted in FY 2019 and a note explaining whether *I think* they need to be rebid for FY 2020. My conclusions are drawn from a few factors – whether your contract expires on or after June 2020, and whether you have any contract extensions available to be exercised so that rebidding isn’t necessary. The data is also color coded as follows:
Red: Must rebid services.
Blue: May need to rebid, depending on whether contract extension is signed.
Black: Service under contract and no rebid is required.
Form 470 Narrative Box and RFPs The Form 470 requires filers to build the application by selecting “Add New Service Request” and then selecting one (or more) drop down selections. The form then asks questions related to the selected service. Because the questions on the form aren’t very instructive, you are STRONGLY encouraged to use the narrative box to further describe any services you want (there is only a single narrative box, for each category of service). In addition, if you have an Request for Proposal (RFP), you MUST upload it into the Form 470 at the time the 470 is filed. In addition, any RFP addenda, Q & A, or additional information given to bidders also must be uploaded to the Form 470 with the RFP, a process that is done using the ‘Related Actions’ feature in EPC when on the 470 page. However, this can only happen if an RFP was uploaded with the 470 initially. Important: When any of the services or locations change, the 28-day clock must be restarted. Deadline to File Form 470 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. I encourage everyone to file their 470’s by the first week in December! You will then receive vendor questions/proposals during the month of December, can evaluate your bids and select your vendors in January, have your board approve contracts in January or February (if required by local policy), and then sign your contracts and file your 471 in early March. Important Requirements/Reminders:
- List bid due date in Form 470 or RFP. If such a deadline isn’t stated, you must consider all bids received up until the date you conduct your bid evaluation. I suggest the following language:
“Deadline for vendor proposals is 9:00 am Eastern, 29 days from the date this Form 470 is posted. We reserve the right to reject late-submitted proposals. Proposals must be e-mailed to the Form 470 contact unless otherwise noted.”
- All disqualification reasons must be stated on the 470 or in the RFP
- Must bid “equivalent” products for internal connections
Applicants must list “or equivalent” language on the Form 470s for Category 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. You MAY say that the equipment must be interoperable and compatible with your existing xxx make/model equipment.
- Upload RFP with 470
If you are using an RFP in addition to your 470, you must upload the RFP with the 470, AND upload any additional documentation given to bidders during the bidding process. If any of the new documentation materially changes the services being bid or entities served, you must restart the 28-day clock.
- Installment Payment Plan with vendors
If you would like to spread out the non-discounted (the applicant’s share) amount of the cost of special construction (installation), you must indicate so on the 470 under the ‘Payment Installation Plan’ section located beneath the narrative box.
- Use State/Local Procurement Requirements narrative box
This is the space where you place instructions on bidders, such as the final date to submit bids (must be at least 29 days after 470 filing date), where to submit bids, in what format, if references are required, if vendors must have SPIN numbers, if you require discounted bills, etc. Use this space wisely!
Hints for Completing the Form 470:
- Viewing Draft 470 Before Filing
At the end of the form, the system will require you to select ‘Review 470’ and will say that it’s generating the PDF. To see the PDF, you must click on ‘Refresh’ until it appears. The PDF will not appear unless you click Refresh (and sometimes it takes up to 30 seconds to appear). Review the draft and if you want to make changes to the form, click ‘Back to re-enter the form. To submit, check on the certification box, and then ‘Continue to Certification’ to proceed with the certification/submission.
- Obtaining a Final, Submitted Copy of Your 470
After you’ve “certified” your Form 470, it’s often difficult to find a final copy. At the bottom of your Landing Page (home), scroll to the bottom where it says FCC Forms and Post-Commitment Requests. Select ‘Form 470’ and the funding year. Thenclick on the 470 Nickname that you gave the form and it will show you a summarized version of the 470. To download an actual copy, click on ‘Generated Documents’ on the top toolbar, and then ‘Original Version.’
It’s important that you begin the Form 470 bidding process as soon as possible so you don’t run out of time during the Form 471 application window. If you have any questions about filing the Form 470, please e-mail me at jtschell@comcast.net!
Happy Filing!
— Julie Julie Tritt Schell PA E-rate Coordinator 717-730-7133 jtschell@comcast.net www.e-ratepa.org