Form 471 Guidance & PIA Review

If you are filing for new services (or existing services but under a new contract) don’t forget that you must wait a minimum of 28 calendars days after filing your Form 470 and RFP (or after filing the last addendum to your 470 or RFP) before you sign a contract for the new service. Contracts should be signed no sooner than the 29th day after your Form 470 was filed.

When you are evaluating bids, make sure you follow the bid evaluation criteria you decided on at the beginning of the process. If you introduce new criteria or eliminate a bid based on criteria that was not disclosed in your 470/RFP, that could be grounds for a competitive bidding violation and subsequent denial of your funds. And remember, you must select the most cost-effective solution; while this doesn’t always mean the least expensive, you need to make sure you have a solid, written explanation of why you selected your winner and be ready to defend it during the review process.

Prior to starting your Form 471, you will need to upload any new contracts into the EPC system and associate them with the Form 470 that initiated the relevant bidding process.

Per the program’s competitive bidding rules, you must keep all vendors at arm’s length during the bidding and evaluation process. However, that all changes once you’ve selected a winning vendor. Once that contract is signed, they are your partner and you can and should work with them to gather the information needed to complete your Form 471. This could include:

1. Line Item Information: For Category 2 projects (internal connections equipment and services), you are often purchasing a lot of different items, from routers and wireless access points down to jacks, screws, and cables. On the Form 471 you will need to enter the information for every last piece of equipment, the number of each item being purchased, and the cost. We recommend asking your vendor to fill out a spreadsheet with this information for you, which you can then upload into the EPC system instead of having to type it all out yourself. You can find templates for these spreadsheets HERE.
2. Build Cost Information: If your new Internet Access or WAN service requires special construction of fiber optic or microwave connections, you need to be prepared for a LOT of questions regarding the build costs. Many of these questions can only be answered by your vendor, so make sure and reach out to them as quickly as possible to gather this data. This information may include:

• For fiber builds, the length of the fiber being installed in feet, and the cost per foot of the construction.
• The cost of any modulating electronics, maintenance, and operations, or additional equipment (for dark fiber or self-provisioned fiber projects).
• The number of strands of fiber being installed. The E-rate program will only cover the cost of the actual number of strands being lit and used by the applicant, so if additional strands are being installed a cost allocation should be done for the incremental cost of those extra strands.

Although you can file for both Category 1 and Category 2 projects and services on the same Form 470, you must submit separate Form 471s for each Category. Also, within your Form 471s, you will need to make sure and file separate funding requests for parts of certain projects. For example, if you are requesting funding for a fiber build that includes special construction costs, you will submit one funding request (FRN) for the monthly recurring charges (MRC) related to the ongoing use of the fiber, and a separate FRN for the non-recurring charges (NRC) related to the special construction.

18 States now offer E-rate State Matching Funds for Special Construction Projects. Simply put, if you are filing for special construction funding for a fiber or microwave build, and you are located in one of these states, you can file for matching funds. If approved, your state will cover an additional 10% of the cost of the NRC special construction costs, AND the E-rate program will match that, essentially increasing your discount (on the up-front construction costs only, not the MRC) by 20%. So if you have an 80% E-rate discount you will pay nothing for the special construction costs, if you have a 70% discount you will only pay 10%, and so forth. In order to access these funds:

• You will need to follow the application process specific to your state. Links to this information can be found here.
• On your Form 471, when you create your FRN for the special construction costs, you will be asked if state matching funds are available. Answer ‘yes’ and then upload the requested documentation. If you have not received approval for state match, upload a placeholder showing that you have applied; you will then need to provide proof of approval during the review process.

Once you have submitted your Form 471, unfortunately, it’s not yet time to relax. The next phase is the review process, when USAC’s Program Integrity Assurance (PIA) team reviews your form, asks you questions, requests supporting documentation, and ultimately sends you a Funding Commitment Decision Letter (FCDL). This letter, which is actually an email nowadays, lets you know if your funding has been approved or denied.

Make sure you retain all documentation, electronic and otherwise, related to your application. This would include:

• • Bid evaluation score sheets, notes, and memos.
  • School board minutes and records related to contract approval.
  • All correspondence with service providers.
  • ALL bids received, whether winning or losing.
  • Supporting documentation for your discount level (i.e. NSLP school lunch forms or surveys).