Like the federal tax code, a program as large and complex as the eRate is open to considerable interpretation. Just as most Americans use the services of tax accountants to minimize their tax burden, many larger school divisions and library systems have hired eRate consultants to decipher the rules, keep up with the changes, and get the greatest discount to which they are entitled.
Now that the rules seem to be relatively stable, here are a few strategies you can employ during the second filing window to increase your discounts and cover additional equipment and services:
Sign separate internal wiring contracts for your highest-discount schools
Funding for telecommunications services and internet access receives top priority, while any money left over will fund internal connections according to need. If you plan a major purchase of servers, routers, and other “internal connections” for your school system, specify in your bid that you want a separate contract for your highest-discount schools. This would increase the likelihood of funding for those items.
Increase your discount percentage by identifying eligible students at high schools
For some reason, older students are more reluctant to participate in the National School Lunch Program. If you can identify participating siblings of non-participating students living in the same householdtypically the siblings are in elementary schoolyou may count the non-participating sibling as an “eligible” student. This is most effective if you need relatively few students to jump from one discount level to another. Lock this information away and use it only if the SLD questions your discount or in case of an audit.
Lease your wide area network
Wide area networks are eligible for discounts only when leased from a telecommunications carrier, or when leased from any vendor (such as a cable company) when the cost of the WAN is less than what a telecommunications carrier would charge for equal service. Since wide area networks do not constitute internal connections, the cost of purchasing components and services used for their construction is not eligible for discounts.
During the first filing window, many applicants who waited until the last minute to file their Forms 470 and 471 had their applications rejected because they failed to meet the “minimum processing standards” established by the SLD and were unable to resubmit their applications within the window.
For all services that are ongoing (local and long-distance phone service, existing contracts, internet service, wide area network contracts, etc.), file a Form 470 as soon as possible. File a Form 471 when the 28-day posting period has passed for tariff services (you don’t need a contract for tariff services).
For “existing contracts”contracts signed on or prior to July 10, 1997, or as the result of a previous Form 470 postingyou may file a Form 471 immediately after you file the Form 470. The SLD will not process your Form 471 for 28 days, but will hold it.
All other 471 forms can only be filed after you have a signed contract in place. Filing early will give you more time to correct any mistakes in an application that is rejected. Remember, you may resubmit rejected applications, but they must be corrected and received by the SLD before the filing window closes on March 11 to receive funding.
Separate services on multiple 471 forms
Because the FCC has established new rules of priority (funding all requests for telecommunications services and internet access first, then prioritizing requests for internal wiring), 471 forms containing only requests for telecommunications service and internet access will be processed first. The 471 forms that include requests for internal wiring will be held, in most cases, until all other applications have been funded before being processed. If you file one Form 471 for telecommunications services and internet access and a separate form for internal connections, you’re likely to get funds sooner.
As eRate specialist for the Virginia Department of Education, Gregory Weisiger advises the state’s applicant community. He can be reached at firstname.lastname@example.org.