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Time to File Your Form 470 FY 2011!
Message Posted November 5, 2010

· 471 Window Dates Have Not Been Set; Will Likely Be Early January - Mid March

· New 470 and 471s to be Released

· File 470 Now Using Existing 470

New Form 470

The FCC is in the process of adopting new E-rate Forms 470 and 471 for FY 2011. The old Form 470 version should be used until the new one becomes available and I encourage you to file your Form 470 now using the currently-available form. The main difference between the old 470 and the new 470 is that several unused boxes and sections have been removed (MTM/contract/multi-year contract checkboxes, BEAR/SPI preference question, ineligible entities section, necessary resources checkboxes, & the area codes and phone pre-fixes section). After the new 470 is released, the old version will no longer be accepted. We do not have an anticipated date when the new 470 will be released.

New Form 471 and FY 2011 Form 471 Window Dates

The old Form 471 will not be accepted for FY 2011. As soon as USAC develops the backend IT system to reflect the new Form 471 changes, the Form 471 Application Window will open. The estimated window opening is the first week in January, with a close date in mid-March. The changes to the 471 will not be as noticeable as those made to the 470.

When 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 will give you all of January to evaluate your bids, have your board approve contracts in February (if required by local policy), and then sign your contracts and file your 471 in February or early March. In mid-December, I'll be sending out a list of districts that haven't yet posted their 470's, so if you don't want to be on the list, file soon! Simply go to: http://www.sl.universalservice.org/menu.asp and click on 'Create Form 470.'

Below are some helpful reminders and answers to the most common Form 470 questions:

1) 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 listing 'cellular service with data plans'. Also, if you're planning to request funding for dark fiber service, lit fiber service, or hosted VOIP service, these services also should be listed in both the telecom and Internet categories to ensure that all possible vendors (telecom and non-telecom vendors) are able to submit proposals.

2) Rebidding contracts and MTM services. Unless you are under a multi-year contract (that was originally competitively bid using a Form 470) that expires on or after June 30, 2012, YOU MUST POST A FORM 470 FOR EVERY SERVICE FOR WHICH YOU ARE SEEKING E-RATE DISCOUNTS.

3) 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, 2012, you are not required to file a Form 470 for FY 2011. 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.

4) 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.

5) 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).

6) 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.

7) 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

717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
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