Form 471 Guidance & PIA Review

After you have negotiated with your vendor and signed a contract, you will have to file a Form 471 to officially request E-rate funding for your new service or equipment purchase. After this form is filed, it will undergo a process known as program integrity assurance (PIA) review where USAC will decide if it will provide the funding you requested on your Form 471.

Form 471 Tips

Information required to fill out a Form 471 such as service provider name, contract length, type of service, and the related costs can easily be found on the contract you signed. An important field for each funding request on your Form 471 is the narrative. This is where you can provide more details or relevant information for the services you are seeking that may not be clear in the other fields you must fill out. Providing more detail in the narrative box can help reviewers make a decision on your funding request much quicker. Additionally, there are a few other tips for the Form 471 that can save you a lot of time and frustration in the future. Read more about the Form 471 on the USAC website.

Include all necessary funding requests on the same Form 471

When your project requires multiple funding requests (for example, leased dark fiber service and the equipment to light it), all the funding requests need to be on the same Form 471. If you are not requesting funding for an expected component (for example, you already own the necessary equipment to place leased dark fiber into service), you should mention this fact in your narrative.

If you are requesting	USAC will expect to see individual funding requests for the following on the same Form 471:
Leased Lit Fiber with special construction	Monthly recurring cost and any standard non-recurring cost if applicable Special construction charges
Leased Dark Fiber without special construction	Monthly recurring cost for the lease OR non-recurring cost for the IRU fee Network equipment to place the fiber into service Maintenance and operations services if requested
Leased Dark Fiber with special construction	Monthly recurring cost for the lease OR non-recurring cost for the IRU fee Special construction charges Network equipment to place the fiber into service Maintenance and operations services if requested
Self-Provisioned Fiber	Special construction charges Network equipment to place the fiber into service Maintenance and operations services if requested

Category 1 special construction details

When requesting any funds for special construction associated with an eligible Category 1 service, you will be asked to supply more details on the construction costs. It is extremely important to answer these questions accurately in order to save you time during PIA review.

Field	Input Guidance
Total Project Plant Route Feet	This measure only accounts for newly deployed fiber, and should not include any existing fiber. For example, if the total project covers 150,000 feet but 5,000 feet is existing infrastructure that will be spliced to the newly deployed fiber, the response to this field would be 145,000 feet.
Average Cost per foot of outside plant	This will equal the “Total Special Construction Charges” divided by “Total Project Route Feet.” If total special construction charges are $5,000,000.00 for 145,000 feet special construction, then the response in this field should be $5,000,000.00/145,000 feet = $34.48/foot.
Total Strands	Enter the total number of strands installed at the time of construction. For example, if the build is segmented into a backbone segment with a 48 strand cable and a lateral segment with a 12 strand cable, then the response for this field would be 60 strands. You can provide additional explanation in the narrative field.
Number of E-rate Eligible Strands	Enter the total number of strands that will be lit within the current funding year and are for the exclusive use of eligible E- rate entities. Using the example above, if 12 strands are being lit in the backbone segment and 8 strands in the lateral segment for the exclusive use of the E- rate eligible entities, then the response to this field would be 20 strands. If this number is less than the number in Total Strands, you must have an ineligible cost listed on the funding request.

Category 2 allocations

When filling out the necessary information on your Form 471, it will ask you to list the Recipients of Service for each service you are requesting funds for. For Category 2 requests, it is extremely important to accurately list which schools will receive the listed service. Since Category 2 budgets are calculated per-school, incorrectly listing a school as a recipient of a funding request could deplete its budget for a purchase it is not receiving. While this type of error may be caught during PIA review, it saves time to make sure this is correct when the form is filed.

Reminder: you have to file separate Form 471’s for Category 1 and Category 2.

PIA Review

All E-rate funding requests undergo a review process known as Program Integrity Assurance (PIA) review before any funding commitments are made. This is a necessary part of E-rate to protect against waste, fraud, and abuse of program funds. If you are unfamiliar with the PIA review process, read more on the USAC website.

All requests that include special construction, as well as leased dark fiber requests with no special construction, undergo a more detailed PIA review. It is important to know that the review of your request will be much more involved than you may be used to and you will be asked for detailed documentation proving the most cost-effective solution was chosen. Knowing what to expect, having the information prepared, and providing it in a timely fashion will speed up the decision. Possible information requested may include:

Copies of bidding documents: RFP, amendments, and communication with vendors during the procurement process
Copies of all bids received
Proof that the most cost-effective solution was chosen: bid evaluations, reasons for bid disqualifications, explanation of cost comparisons
Excess strands and ineligible costs: how many fiber strands are being built, how many are eligible, and documentation showing proper cost-allocation of any ineligible costs
Maps of construction route and whether alternative routes were considered
Detailed, invoice-level pricing of construction costs:
- Costs for ROW access, easements, permitting, surveys, environmental impact assessments, traffic control, construction labor, and testing
- Quantity and costs of required OSP materials such as handholes, splice enclosures, and marker posts
- Total footage and cost of fiber being installed
- Percentage of the build that will be aerial and buried
  - Whether new or existing conduit will be used
  - Total footage and cost of new conduit
  - Whether new or existing poles will be used
  - Quantity and cost of new poles
  - Costs of trenching, boring, pole attachments, and pole make-ready
- Explanation of special materials or procedures required, such as:
  - Galvanized conduit
  - Directional boring through hard rock or under a paved surface
  - An excessive number of handholes or marker posts
  - New pole installation
Proof that you have the necessary equipment to place leased dark fiber or self-provisioned fiber into service if you did not request new equipment for this purpose.
Proof that your solution will meet the long-term FCC bandwidth goals if you are requesting state matching funds.