Let’s Begin E-rate Funding Year 2022!

November 2, 2021

Attached: RFP-Form-470-Narrative-Guide

I’m so excited to announce the beginning of the FY 2022 E-rate application process!   Below is a summary of the changes you can expect for FY 2022, important reminders, and a helpful “what to do by what date” chart at the bottom.

1)   Form 470 Changes for Both C1 and C2 Forms

— You may recall that in recent years the Form 470 contained drop-down options for both Category 1 and Category 2 service requests.  For FY 2022, the FCC modified the drop-down options to be descriptive options with progressive disclosures for Category 1 (meaning the form takes you to additional levels of questions, depending on the options you select).  To make the options a little more understandable, I’ve created this helpful guide that contains screenshots of the new Form 470 with plain language annotations: https://e-ratepa.org/wp-content/uploads/2014/03/Guide-to-New-Form-470-Options.pdf.

2)  Options for Updating Entity Profiles in the “Administrative Window”

— The “Administrative Window” is the window before the 471 application window, during which time schools usually update their enrollment and NSLP (or CEP%) data in each school’s EPC profile.  The Admin Window is now open and is expected to close the first week in January.  USAC has just announced that schools will be permitted to use FY 2020 or FY 2021 enrollment and NSLP data if your current data has been impacted due to the COVID-19 pandemic.   Typically, discount rates rarely go up or down from year to year; therefore, it is highly likely that most schools will choose to not update the enrollment and NSLP data in each school’s EPC profiles this year, assuming the data in the profile is from fall 2019 or fall 2020.  If your E-rate discount will increase by using the most current data (Oct 2021) you should update the enrollment and NSLP data in EPC for each school before the close of the Admin Window which is expected to be around January 8.  A Guide to Updating C2 Budget Data and Discount Data is available at:  https://e-ratepa.org/wp-content/uploads/2014/03/Guide-to-Entering-Enrollment-NSLP-in-EPC-FY-2022.pdf to walk you through the process for updating each school’s EPC profiles.

3)  Form 471 Filing Window Dates

— USAC has not yet announced the official Form 471 Filing Window dates, but indicated recently that they expect the window dates to be very similar to last year, which means it would likely open around the second week in January and close around March 25, 2022.  For a suggested FY 2022 bidding/filing timeline, see the chart at the bottom of this message.

4)  FY 2022 PEPPM Mini-Bid Guide/Documents Available

— The FY 2022 PEPPM Mini-Bid Guide and related documents are available at:  https://e-ratepa.org/?page_id=6121.  In general, there are no updates from FY 2022 but I caution you to use the most updated Vendor Category List (Step 3/Attachment C) from the site each time you create a new mini-bid in order to obtain the most recent vendor contact information.

5)   Category 2 Budgets – What’s Remaining for Your School or Library

— Beginning in Funding Year 2021, the new Category 2 cycle went into effect (FY 2021 – FY 2025) at which time all C2 pre-discount budgets were reset, and a new C2 multiplier was set ($167/student for schools and $4.50/sq ft for libraries – or a minimum of $25,000/building).  In addition, C2 budgets are now calculated at the school district or library system level (no more individual school or library building C2 budget caps), the enrollment figure used for C2 budgets can be different from the enrollment used for discount calculations (see #2) and schools can use the same C2 enrollment for the entire budget cycle or modify it if enrollment has increased to take advantage of the higher C2 budget.  To see what your remaining C2 budget is for FY 2022 – FY 2025 (as of 10/20/2021), see:  https://e-ratepa.org/wp-content/uploads/2014/03/C2-Budgets-Remaining-as-of-10-20-2021.xlsx.  If you update your C2 enrollment in EPC, the C2 budget will change and the results can be found here.

6)  Unsure Whether You Need to Rebid Category 1 Services This Year?

— In order to remind you of the status of your current Category 1 contracts (telecom and Internet), please see this message (https://e-ratepa.org/?p=32690) sent to the listserve on 10/20/2021 that provides a list of all FY 2021 C1 FRNs, and the expiration dates of those contracts.  In the spreadsheet there’s an additional column – “Julie’s Rebidding Status Notes” – explaining whether I think the service must be rebid for FY 2022.  Please note that this data was taken directly from your FY 2021 From 471 submissions.  If you listed the wrong contract expiration date on last year’s application, be sure to enter the accurate date on the FY 2022 application (and be prepared to show PIA your contract as you will likely receive questions on why the date changed).

7)  Extending an Existing Contract?
— If your original contract included (finite, not open-ended) voluntary extensions and you wish to exercise one of those extensions for FY 2022, be certain to notify the vendor in writing of that decision before the Form 471 is filed.  USAC will ask for a copy of that written notification during PIA review, so be sure to retain evidence of that notification.

8)  E-rate RFP & Form 470 Narrative Guide Released

— To assist applicants with preparing their E-rate Form 470’s and Request for Proposals (RFP), I’ve created the RFP & Form 470 Narrative Guide that contains the following information related to both Category 1 and Category 2 service/equipment requests:

  • RFP Basics
  • RFP Outlines of what information should be included in an RFP and also what information should be requested from vendors in their bid responses.
  • Sample Vendor Response Templates
  • Reminders of additional bidding requirements when seeking various fiber services
  • Sample Form 470 Narrative Language for applicants that are not issuing RFPs with their Form 470’s

9)  Form 470 Bidding Exemption for Commercially-Available Internet – CABIO

— A little-known Form 470 bidding exemption exists for schools or libraries that are purchasing a “commercially-available Internet package.”  This option is mostly geared to small schools and libraries that are using cable modem or DSL Internet services that are generally available to the public.  To use the CABIO option, it must meet all of the following conditions:

  • Vendor package costs less than $300 per month, per building (pre-discount).  Cost must be based per building and cannot be averaged across multiple buildings
  • Minimum speed must be 100 mbps downstream and 10 mbps upstream
  • “Commercially Available” typically means you can look on a vendor’s website and see the bundled Internet package that is generally available to the public
  • If CABIO applies, and you’re not signing a contract, applicants can proceed directly to the Form 471 filing and when it asks if a Form 470 was posted, select NO and then indicate that you’re using the CABIO option.
  • If CABIO applies, and you’re signing a multi-year contract, applicants should first create a Contract Record in EPC (indicating that no 470 was posted), and then file the Form 471.

10)  USAC Fall Training Series and News Briefs

— Starting in October 2021, USAC has moved from sending weekly newsbriefs to one/month and on an as-needed basis.  If you’re not already subscribed to the USAC newsbriefs, I encourage you to sign up at:  https://fe391570756406797d1477.pub.s10.sfmc-content.com/3n2usens2cz

— USAC has just announced their online fall training workshops will be held November 16, 17 & 18.  Workshop details and registration is available at:  https://www.usac.org/e-rate/learn/webinars/.

11)  Funding Year 2022 Suggested Timeline: 

— If you haven’t yet done so, now is the time to file Form 470s for expiring or new Category 1 services, and Form 470s (or PEPPM mini-bids) for Category 2 purchases that you will need for FY 2022 (July 1, 2022 – June 30, 2023).

Step: Timeline:
Post Form 470 in EPC to competitively bid all new/expiring contracts (unless using the PEPPM mini-bid option for C2) Now – early December (by Thanksgiving, if possible!)
Update enrollment/NSLP data in school EPC profiles Now – early January, unless you’re using data that’s currently in EPC (from last year).
Conduct bid evaluation Early January
Obtain school board approval January or February board meeting (no later)
Sign vendor contracts By End of February
Create Contract Records in EPC/upload signed contracts Late February/Early March
Submit Form 471 February/early March
Earliest applicants can purchase C2 equipment April 1, 2022
Funding Commitment Letters (FCDLs) issued End of April – Sept 1 (goal)
File Form 486 Upon receipt of FCDLs
Earliest that FY 2022 BEARs or SPIs can be submitted to USAC July 1, 2022
 

If you have any questions, please don’t hesitate to contact me!

— Julie

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

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