If any part of your Form 471 application arrived at the SLD’s office in Lawrence, Kansas after 11:59 p.m. EST, you’re out of luck. Because of extenuating circumstances, the SLD had allowed a limited number of late applications into the system last year. But at the quarterly board meeting of the SLD on April 19, SLD President Kate Moore said the agency does not have the authority to waive the application deadline for Forms 471 that arrived late this year, according to a recent FCC ruling.
A source from the SLD said that a Federal Express delivery arrived at the Lawrence, Kansas office at 12:15 a.m. on April 7, which prompted the FCC’s decision. If your application was delivered after April 6, you’ll have to appeal to the FCC.
At the Kansas office, your application will be bar-coded to help the SLD track it through the system. It will be evaluated to see if it meets the SLD’s minimum processing standards and will be returned to you if it doesn’t. If you filed your Form 471 online (more than one-quarter of the 32,000 applications were received online), you don’t have to worry because the system ensured that your application passed the minimum processing standards.
The SLD’s minimum processing standards for a Form 471 are:
1. It must be an OMB-approved form, or the visual equivalent.
2. It must be submitted correctlyno fax or eMail submissions are allowed.
3. All pages must be submitted.
4. At least one row of Items 15 and 16 must have a valid USCN number and a completed entry in Columns 8, 9, or 10.
5. Your signature in Block 6 must be an original and not pencil.
Then the same team of SLD employees that staff the agency’s customer service lines enter the data from your application into the SLD’s system and work with you through the problem resolution process, if necessary.
Items for problem resolution may include:
1. Incomplete entries in Item 14: Only individual schools and libraries can list just themselves. All other applicants must list all eligible entities covered by their application.
2. Miscalculating your discount: Different applicants must calculate their discounts in different ways. For example, school districts must calculate a weighted average of their schools’ discount percentages, and libraries must use their school district’s weighted average discount.
3. Not documenting your discount: You must attach a worksheet of calculations for Item 14 if you’ve used any alternative means of calculating your discount, or if you represent more than one entity.
4. Leaving off a Service Provider Identification Number (SPIN) for any item you list in Items 15 or 16.
5. Listing a non-telecom provider for telecommunications services: Only common carrier telecommunications companies can be service providers in the “Telecommunications Services” category. If your service is passed through to you by a state network or other non-telecom provider, you must list the underlying service provider.
6. Listing the wrong Form 470 number, or USCN, in Column 2 of Items 15 and 16.
7. Providing the wrong contract number, award date, or expiration date in Columns 3, 4, and 5 of Items 15 and 16.
8. Providing the wrong service start date in Column 7 of Items 15 and 16.
9. Leaving Columns 8, 9, or 10 of Items 15 and 16 blank, or filling them in incorrectly: Since these columns are where you specify the pre-discount cost of your requested service, the SLD can’t process a discount for you without the correct information.
10. Failing to attach Item 17: The SLD needs a clear list of services in order to approve your application. You can use information provided by your vendor, the optional pre-discount cost calculation grid, or create a list yourself.
Once the data from your application has been successfully entered into the SLD’s system, you’ll get a Receipt Acknoweldgement Letter (or, for acronym lovers, a “RALLY”) that tells you what information the SLD has about you and your requests.
The receipt acknowledgement letter, which is new this year, doesn’t indicate approval of your applicationit’s just a checkpoint to assure you that your application has been received and to make sure the SLD entered the correct information from your Form 471. The letter also assigns an application number to your Form 471, so you have a common reference point when you’re talking to the Program Integrity Assurance staff.
There will be a system in place for you to notify the SLD of any information that is incorrect in the letter. This system will be announced at a later date.
Next comes the Program Integrity Assurance (PIA) phase, which is handled by the staff in Whippany, N.J. The PIA staff checks to make sure that you’re eligible for discounts and have asked only for eligible services.
This year, if any part of a funding request number (FRN) asks for a discount on an ineligible service, that entire request will be denied. (Last year, because the program was new, the SLD approved a funding request if at least 50 percent of the request was for an eligible service.)
Once the FCC has set the funding level for Year Two of the eRate, the SLD can begin to approve discounts on applications that have passed through the PIA phase.
Funding commitment letters will go out in waves again this year. The SLD’s goal remains to let applicants know of all funding decisions on each Form 471 they file at the same time, with a single letterso if you submitted a Form 471 asking for discounts on “priority one” services only, you’ll be notified sooner than if you sent in a Form 471 asking for discounts on priority one services and internal connections on the same form.