SLD Tips & News Nov. 18, 2011 – Form 470 & Tech Plan

TIP OF THE WEEK: If you are filing a Form 470 certification on paper, be sure to include all of the Block 5 certification pages, not just the signature page. Your submission should include Items 16 through 27g.

Please note that USAC will not issue a News Brief next Friday, November 25, due to the Thanksgiving holiday. Also, the Client Service Bureau will be closed Thursday, November 24 and Friday, November 25.

Commitments for Funding Years 2011 and 2010

Funding Year 2011. USAC will release FY2011 Wave 23 Funding Commitment Decision Letters (FCDLs) November 22. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90%. As of November 18, FY2011 commitments total over $1.27 billion.

Funding Year 2010. USAC will release FY2010 Wave 76 FCDLs November 23. This wave can include commitments for approved Priority 2 requests at all discount levels. As of November 18, FY2010 commitments total just under $2.86 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

FY2012 Eligible Services List Links Added

You can now access the FY2012 Eligible Services List directly from both the Latest News section of the Schools and Libraries website and the Eligible Services List page in the Reference Area.

First FY2011 Form 486 Urgent Reminder Letters Issued

On November 16, USAC issued just under 2,040 Form 486 Urgent Reminder Letters for FY2011. These letters notify applicants whose Forms 486 may be late and give them an opportunity to file and certify Forms 486 without penalty.

In general, the deadline for certifying a Form 486 for a Funding Request Number (FRN) is:

  • 120 days after the date of the FCDL or
  • 120 days after the service start date reported on the Form 486, whichever is later.

USAC calculates the date to issue a Form 486 Urgent Reminder Letter based on:

  • the date of the FCDL and
  • the service start date reported on the associated Form 471.

Note that if you have already filed a Form 486 online but have not yet certified that form online or on paper, USAC will issue you a Form 486 Urgent Reminder Letter to remind you to certify your form.

USAC issues one Form 486 Urgent Reminder Letter per Form 471 if all of the FRNs listed on that Form 471 have the same service start date and FCDL date. However, if the FRNs on a single Form 471 have different service start dates and/or funding decisions were not issued for all FRNs on the same FCDL, USAC will issue one Form 486 Urgent Reminder Letter per FRN or group of FRNs as appropriate when each Form 486 deadline has passed.

If USAC issues you one of these letters in this first letter run for FY2011, you must certify a Form 486 featuring the associated FRN(s) no later than Tuesday, December 6 to avoid an adjustment to your service start date and possible reduction in funding.

  • If your actual service start date is (or will be) later than the date you reported on the Form 471, you should refer to the Deadlines Tool on the USAC website to calculate your deadline for filing a Form 486. However, USAC will not issue a second Form 486 Urgent Reminder Letter because the calculation for the letter is based on the service start date reported on the Form 471.

USAC will continue to issue a Form 486 Urgent Reminder Letter for each FRN that appears to have missed its Form 486 deadline, based on the FCDL date and the service start date reported on the Form 471.

If you do not certify your Form 486 by the deadline in the appropriate letter, USAC will adjust your service start date to 120 days before the date your Form 486 is received or postmarked and adjust your funding commitment as necessary to be consistent with your adjusted service start date.

Technology Planning and Form 470

In last week’s SL News Brief we discussed technology planning. It is also important to keep in mind the relationship between the technology plan and the Form 470. (The Form 470, Description of Services Requested and Certification Form, is the first program form in the application process.) Below are several questions that you should consider as you write your technology plan and prepare to file a Form 470.

What is the relationship between the technology plan and the Form 470?

Your technology plan, if properly done, forms the basis for the acquisition and use of the products and services featured on your Form 470. By describing your current and future needs and your goals and strategies for using technology, you can prepare reasonable funding requests and evaluate and monitor your progress toward reaching your technology goals.

The services you request on your Form 470 should follow from your goals and strategies and your current and future needs as described in your technology plan. This helps to ensure that the products and services for which E-rate provides discounts will be put to good and effective use.

How do I avoid an overly broad Form 470?

An overly broad or “encyclopedic” Form 470, instead of being tailored to your technology plan, covers a wide and unconnected range of services that may be eligible for discounts but that do not truly advance or support the specific goals and strategies articulated in that technology plan.

Instead, you should prepare a Form 470 with a level of detail appropriate to the size and complexity of your technology plan that features services that you actually plan to use. Your entries in the “Service” and “Quantity and/or Capacity” fields on the Form 470 should be consistent with both the overall goals and the specific details included in your plan.

How long and how detailed should my technology plan and Form 470 be?

There is not a minimum or maximum requirement for the length or complexity of a technology plan. We suggest that you keep the following general guidelines in mind:

  • A small entity or an entity with limited technology needs will probably have a smaller, less complex technology plan than a large entity or an entity with more complex technology needs.
  • Your current situation may affect the detail and the degree of complexity in your technology plan and your Form 470. For example, a school with no infrastructure in place could explore a variety of technological solutions, while a school planning a buildout of an existing infrastructure might have more limited options because of compatibility issues with its existing equipment.
  • Technology Plan Approvers (TPAs) can set requirements of their own for the technology plans that they approve. For example, TPAs may add requirements to ensure that the technology plan complies with the requirements of other federal or state programs in addition to E-rate.

You should also make sure your technology plan is not overly narrow but could cover more than one solution to your needs. That way service providers that might not otherwise bid on your services may be encouraged to offer cost-effective solutions you may not have considered.

What effect should my needs assessment have on my Form 470?

The needs assessment element of your technology plan should address more than just the number of computers or other hardware you have or intend to acquire in order to make use of discounted services. For example, an old building with limited electrical capacity may not be able to support your requests for services unless you first make substantial modifications to its electrical system. If this is the case, upgrading your infrastructure may precede your request for all of the services you have included in your technology plan and your Form 470 should take this into account.

How specific should I be about the scope of my project?

When completing your Form 470, you should give service providers an accurate understanding of the scope of your project. For example, if your school district is either growing or shrinking rapidly, or your school district comprises many schools and not all the schools will share all services, you should make that clear in your Form 470 and may want to include that information in your technology plan as well.

The Quantity and/or Capacity fields on the Form 470 could therefore be simple or very detailed, depending on the information you need to convey to potential bidders.

What effects could minor or major changes to my technology plan have on the Form 470 I already filed?

Minor revisions or updates are those that remain within the scope of the original version of the technology plan and any related Forms 470. Program rules do not require minor revisions or updates to be re-approved, but you should check with your TPA to see if he or she has other requirements.

Major revisions or updates are those outside of the scope of the original version of the technology plan and/or the Form 470. A major revision would require the issuance of a new Form 470 because the provision of the new or expanded products and/or services is significant enough to require a new competitive bidding process. If you intend to make a major revision or update to your technology plan, talk to your TPA.

As you get ready to file your Form 470, you should review any revisions or updates that you have made to your technology plan and consider any other changes that may be necessary. If you have revised or updated your technology plan, don’t just copy the Form 470 you filed last year. Think first if those revisions or updates will affect the Form 470 you file for the upcoming funding year.