Although the Form 471 filing window closes on April 29, 2020, the E-rate process for the 2020 Funding Year continues with Program Integrity Assurance (PIA). Next, a member of USAC’s PIA team will review your Form 471(s), and each included Funding Request Number (FRN) to ensure that your application is complete, compliant, and cost-effective.
To minimize potential disruptions caused by coronavirus disease 2019 (COVID-19), on March 13, the FCC’s Wireline Competition Bureau directed USAC to extend the deadline for applicants to submit their FY 2020 FCC Form 471 to Wednesday, April 29, 2020, at 11:59 p.m. EDT. They also directed USAC to provide all applicants with an automatic 14-day extension for PIA requests.
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 (EPC), the same portal through which you filed your Form 471, when any activity occurs related to that form, including PIA questions. Make sure that someone is monitoring EPC and the listed email address because responses are required by the listed due date.
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: Communication 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, all applicants were granted an automatic 14-day extension for PIA requests. Your reviewer will clearly state a response due date with the request, so be sure to abide by that date.
While you should take the time to formulate a complete response, you should also try and respond in a reasonable time frame. 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: Answer the questions thoroughly, but 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 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. 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.