Although the Form 471 filing window has closed, the E-rate process for the 2019 Funding Year isn’t yet over. Next, a member of USAC’s Program Integrity Assurance (PIA)PIA team reviews your Form 471(s), and each included Funding Request Number (FRN) to ensure that your application is complete, compliant, and cost-effective.
Please note that the E-rate program has brought in a new vendor to manage the PIA process for them in Funding Year 2019, so some of the specifics of the process may be slightly different this year; we will update this article if we learn of any substantive changes to the process.
In some cases, especially with very low cost, simple, or recurring services (i.e. services for which you are continuing under a previously approved long-term contract), you may not get any questions from your PIA reviewer at all. However, you should not count on that being the case; PIA reviewers typically have at least some questions for many of your FRNs, and will always ask for extensive additional information on complex, high-dollar applications such as special construction projects. To help you navigate the review process successfully, we’ve gathered the following tips.
PIA Review Best Practices
Check your email and EPC Task Page
The primary contact person listed on a Form 471 will receive an email and/or a notification on their Tasks page within the E-rate Productivity Center, (or EPC), the same portal through which you filed your 471 when any activity occurs related to that form, including PIA questions. Most PIA questions require a response within 15 days, so make sure that someone is monitoring EPC and that email address.
When you filed your Form 471, you provided a summary of your procurement process and the details of the winning providers and bids. However, aside from an uploaded copy of the signed contract(s) associated with your services, you were not required to provide any of the supporting documentation that demonstrates compliance with the rules. During the PIA process, you may be asked to provide some or all of that documentation for one or more of your FRNs, including but not limited to:
- Bids: All bids received, winning, losing, or disqualified.
- Bid Evaluation Documents: Bidding score sheets/matrices, sign-in sheets for vendor meetings, etc.
- Correspondence with vendors during the bid window.
- Discount Percentage Supporting Documents: These would typically be records of your National School Lunch Program participation.For schools that do not have a lunch program, they may be surveys.
Be Timely: As mentioned above, most PIA requests require a response within 15 days. While you should take the time to formulate a complete response, you should also try and respond as quickly as possible. The longer you take to complete the PIA process, the longer it will take for your funding to be approved.
Review Your Answers: When responding to PIA questions, keep the following in mind.
- Address only the question at hand: Try to avoid including materials or information unrelated to the questions asked. PIA reviewers handle a large number of ‘cases’ during review season; by complicating your response you make their job harder and potentially delay your funding decision.
- Involve your vendor: Once you have signed a contract and filed your Form 471, your vendor is your partner. There will often be questions, especially for special construction projects, that only your vendor will be able to answer. Keep in mind that they will be juggling information requests from many customers at this time of year so be sure to contact them as quickly as possible when you get a PIA question that requires their input.
Don’t Panic: If you have any fears that the 15-day response window will not be long enough to allow you to gather all of the information needed to respond, you may request an extension from your reviewer. On March 1, 2019, USAC announced that applicants are no longer limited to one, seven-day extension; applicants can submit more than one request and all approved requests will allow applicants 15 days to respond. Please note that applicants must provide a compelling reason why more time is needed.
Hit Submit: The EPC system can sometimes be confusing, especially to relative newcomers. Make sure to read all instructions, and make sure that your responses are shown as ‘submitted’ before you log off.
For more detailed information on the mechanics of receiving and responding to PIA questions, browse USAC’s News Briefs. Several comprehensive updates categorized by the topic “PIA Review” are available to support you throughout the PIA process.