E-rate Tips: 4 Best Practices for Producing a Quality Form 471

In our first “Consult the Consultant” blog post, we covered key elements of special construction RFPs. Now that the E-rate Form 470/RFP window has closed, it’s time to turn our attention to the next step in the E-rate process: filing a quality Form 471 before the Wednesday, March 27, 2019 deadline.

While most errors on Form 471s may be corrected during the Receipt Acknowledgment Letter (RAL) or Program Integrity Assurance (PIA) processes, it is much better to submit a clean, well-written Form 471 which will both speed up approvals and minimize the chances of a negative outcome. Below are four tips from our E-rate Specialist Josh Chisom for how to maximize your clients’ chances of a successful review process:

1. Use the FRN Narratives to Tell Your Story: When submitting funding requests (FRNs) for complex and/or expensive projects, especially those involving Special Construction Costs, it is very important to “tell the story” of the project. Explain what the project outcome will be, including the impact on the students at the school and the challenges faced by the district due to remote locations or difficult terrain. Prove why the solution selected was the most cost-effective by mentioning the Total Cost of Ownership modeling and the length of time over which the bids were compared. If the cost of a fiber build is more than the average, explain why: lack of competition, lack of existing fiber infrastructure, mountains, water crossings, tribal lands, etc. The more you can prove the cost-effectiveness of the project, the fewer questions you should get during the PIA review process.
2. “When in Doubt, Break it Out”: The E-rate Form 471 requires up-front Non-recurring Charges (NRC)/Special Construction costs to be broken out from Monthly Recurring Charges (MRC) for the ongoing service. Hopefully your vendors broke out their pricing proposals in order to make the difference clear and easy to add to your Form 471. Also recognize that some NRCs, like optical signal regeneration equipment (Dense Wave Division Multiplexing or DWDM gear) for long fiber routes are non-recurring, one-time charges that are not special construction charges. Make sure to file these properly as separate FRNs or line items within FRNs as the case may be. Finally, do not use the “Other” category unless you are certain that the service or equipment you are filing for is not included as a listed category.
3. Use the Correct Connection Type: The drop-down options on Form 471 for connection type and fiber type can be very confusing. Do not be afraid to ask the winning vendor to assist in preparing this portion of the 471. It is understandable if you don’t know the difference between OC-12 and OC-24 fiber (refer to this Optical Carrier cheat sheet), but each Optical Carrier rating is specific to an exact bandwidth amount, so it is important to use the correct option. If the solution is Leased Lit Fiber, you can select the “Ethernet” option and enter the exact speed the vendor is delivering.
4. Be Mindful of Excess Strand Counts: In the case of a leased lit fiber or leased dark fiber project with special construction, it is almost certain that the vendor will be installing far more strands of fiber optic cable than will be needed or used by your school sites. Make sure to perform an accurate and supportable cost allocation wherever necessary. If you are submitting a request for a self-provisioned network, you will need to ask for only the number of strands that are being lit. In many cases, the cost of installing 12 strands of fiber (an industry standard bundle size) will be the same or less than the cost of installing a lower number, say the two or four strands that would be commonly needed by a school. In these cases, if you can show that the 12-strand bundle is more cost-effective to install, you will not need to perform a cost-allocation for this line item.

EducationSuperHighway is here to support E-rate Consultants through our webinar series and individualized support. If you are new to special construction projects and would like to talk through the process, please schedule a call to speak with us.