FY 2009 Form 471 Window Not Yet Open
Message Posted November 23, 2009

~ Post 470's Before Thanksgiving ~

Many people have asked if they missed the Form 471 window date announcement. The Form 471 application window has not yet opened, but I expect the window dates will be announced this week. The SLD typically tries to have at least a 75-day window, but they also like to have the window close as early as possible in order to begin making funding commitments as quickly as possible. My best guess is that the window will open the first week in December and close in the second week in February.

However, there is no Form 470 window and everyone should continue to plan to post their Form 470's before they leave for Thanksgiving break. Please do not wait for the Form 471 window to open to post your 470's!

If you haven't yet posted your Form 470, below are a few helpful reminders. In December, I'll be sending out a list of districts that have posted their 470's, so if you want to be on the list, file soon! Simply go to: http://www.sl.universalservice.org/menu.asp and click on 'Create Form 470.'

Don't forget: You cannot file a Form 470 unless you have a written technology plan that covers July 2010 - June 2011. What constitutes "written?" The SLD has stated that the plan does not need to be finalized or submitted for approval by the 470 date, but it should be far enough along in its development that it can reasonably support your requests for discounted services. If your plan isn't changing much from your previous plan, I encourage you to print your existing plan and mark up changes on it, along with a date showing you made those edits before you submitted your 470. Be sure you have something documenting the "written" status and date which is before you post your Form 470. Auditors require it, and sometimes the SLD asks for it as well.

Below are some helpful reminders and answers to the most common Form 470 questions:
1) Check Item 7a and b. There is no harm in checking 7 a and b and all of the boxes under 7b (that you are seeking MTM services and/or contracted services and/or multi-year contracts and/or multi-year contracts with voluntary extensions). In fact, if you intend to sign a multi-year contract or a contract with voluntary extensions, you MUST check 7b and its associated boxes. Don't check 7c.

2) File in both the Telecom and Internet categories. If you are at all unsure which category of service you should choose on the 470, put the services in both. It never hurts to have your service description listed in too many places and provides you the maximum flexibility when selecting the correct category of service on your Form 471. If you are filing for Blackberry/Treo Internet/e-mail services, it's best to file in the both categories.

3) Rebidding contracts and MTM services. If you have a contract expiring on or before June 30, 2011, you must post a Form 470 to rebid that service. OR if you are receiving service under a month-to-month agreement and don't have a contract, you also must post a Form 470 to rebid that service.

4) Form 470's for multi-year contracts: If you posted a Form 470 in a previous year, and then signed a multi-year contract that expires on or after June 30, 2011, you are not required to file a Form 470 for FY 2010. If you wish to exercise a voluntary extension of a contract without posting a 470, you may only do so if BOTH of these conditions are met: a) You notified bidders on the 470 or RFP that you were seeking a contract that contained voluntary extensions, and b) Your 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.

5) File online, even if you don't have a PIN. If you haven't received a PIN, file online, and then mail in your signature/certification page after you hit submit. The SLD will then mail you a PIN in a few weeks. There is no way to request a PIN unless you have first signed a paper certification.

6) Include all of your services on a single 470. There is no maximum number of 470's that you may submit, although it is a good idea to place all of your services on a single Form 470 because then you only have a single 470 number to keep track of for this year. However, there is no harm in filing two or more 470's. Also, there is no way to amend a 470 after it's been submitted. If you need to change your services, you need to file a new Form 470 (in which case your 28-day clock restarts).

7) Instead of using the print preview feature, after you've submitted your 470, go back to the "apply online" page and choose the "search posted" option. Then type-in your 470 number and print off a complete, clean copy of your application. At the top of the completed form it also will show you your allowable contract date (ACD), which is the first date you can sign contracts and file your 471.

8) The SLD's 470 guidance can be found at: http://www.universalservice.org/sl/applicants/step03/.

If you have any questions, please contact me at jtschell@comcast.net.

-- Julie