Although the Form 471 filing window has closed, the E-rate process for the 2018 Funding Year isn’t yet over. The next stage is for a member of USAC’s Program Integrity Assurance, or PIA team, to review your Form 471(s), and each included Funding Request Number (FRN) to ensure that your application is complete, compliant, and cost-effective.
In some cases, especially with very low cost, very simple, or recurring services (i.e. services for which you have a long-term contract and are continuing after having been approved previously), you may not get any questions from your PIA reviewer at all. However, you should not count on that being the case; PIA reviewers will have at least some questions for many of your FRNs, and you will always be asked 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
The primary contact person listed on a Form 471 will receive an email 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 that email address. The email will contain information on how to access the PIA questions via the Erate Productivity Center, or EPC, the same portal through which you filed your 471.
When filing your Form 471, you are providing 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 do not actually need 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 scoresheets/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, but for schools that do not have a lunch program may be surveys.
Be Timely: As mentioned above, the clock will be ticking as soon as you get a PIA request. 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. They will typically grant a one-week extension upon request; for a longer extension you will likely need to provide a compelling reason why you need that much time to respond.
Hit Submit: The EPC system can sometimes be confusing, especially to relative newcomers; make sure and 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, USAC issued a News Brief on April 6 that addresses this topic comprehensively. You can find it here.