The deadline for applying for the 2003 eRatewhich provides discounts on telecommunications services and internet access to schools and librariesis Jan. 16. The eRate is a complicated program, governed by rules that can sometimes seem perplexing to school officials. Nevertheless, with approximately $2.25 billion worth of discounts available each year, it pays to pay attention.
Here are Funds For Learning’s top 10 tips for success, based on five years of experience working with the program and what Schools and Libraries Division (SLD) officials say are some of the most common mistakes applicants make. Many of these are relatively simple steps that could keep your school from losing funding it otherwise would deserve.
1. Plan ahead. This year you’ll be filing an application for discounts that your school would use from July 1, 2003 through June 30, 2004 (or Sept. 30, 2004 in the case of a one-time installation). So it’s important at the outset to review the status of all of the contracts you currently have in place to purchase eRate-eligible equipment and services. If a contract will expire during that funding year, make sure you file a Form 470 application seeking a new contract. If you would like to extend your current eRate-eligible contract, make sure the original contract included language that permits you to extend itand make the extension official in writing.
2. Understand what’s eligibleand why. The eligibility of a product or service for eRate support always rests on who is using it, where, and for what purpose. Review the materials the SLD has made available on eligible services in the “Reference” section of its web site. A new version of the formal eligible services list has been issued this fall to try to clarify some points of confusion, and a searchable version of the eligible services list is also available on the Funds for Learning web site. Pay attention to the very specific requirements for qualifying “on-premise equipment for end-to-end service” as a Priority One service. Many school districts consider this as a way to improve their chances of qualifying for support for networking components for their wide-area networks, but this approach carries with it many restrictions. SLD reviewers also are looking more closely at how servers are being used and where and to whom telecommunications services are being provided.
If 30 percent or more of a funding request is found to be ineligible, the entire request will be rejected. So, as the SLD has advised for many years, “when in doubt, break it out”apply separately for anything that is questionable.
3. Hold a fair and open competition. School leaders sometimes don’t realize that one of Congress’s goals when it reated the eRate program was to promote competition in the telecommunications market and to promote the development of new solutions. Despite the demise of so many telecom companies, that rule still prevails. Even if there is only one company that conceivably could provide you with telephone or other services, you still must go through the process of filing a Form 470 application to notify any potential bidders.
Keep good records of your contacts with vendors. You might be called on later to demonstrate that you chose the most cost-effective proposal. Don’t make a procurement decision prematurely. And don’t tell a responsive company, “I’ve already made up my mind,” if they contact you during the 28-day application posting period. They could report you to the SLD for being in possible violation of program rules.
At the same time, don’t turn your bidding process over to a vendor who ultimately could get the business. Your funding requests will be rejected. The SLD expects you to follow your standard state and local procurement rules (or the SLD’s own competitive bidding requirements if you are a private school) when you procure eRate-eligible services.
4. If it looks too good to be true, it probably is. Unfortunately, with billions of dollars at stake, bad actors are turning up in the eRate program. Under the rules, you are required to pay the non-discounted portion of the price of your eRate-eligible services and products. If a vendor says, “You don’t have to contribute anything,” you’ll be in violation of program rules, and chances are the vendor is trying to scam the program.
5. File online. The vast majority of applicants are now filing online, and there are good reasons to do so. The online form can save you from making certain kinds of mistakessuch as leaving an item blankthat could result in your application getting rejected as soon as it arrives at the SLD. Filing online also can speed up the review of your application. The SLD has made major improvements in the online filing experience since the program’s first years.
The SLD also recommends filing separate applications this year for Priority One services (telecommunications services and internet access) and Priority Two services (internal connections) to speed the review of your applications.
6. Finish the process. Don’t forget to finish your Form 470 and 471 applications. Both must be formally certified by the close of the filing window on Jan. 16, 2003. The signed certification can be submitted on paper, or completed online if you arrange to obtain a personal identification number and use the SLD’s new electronic certification procedure. Also, don’t forget to send in the Description of Services attachments that provide details on what you want to purchase. The SLD is now willing to accept these important documents by mail, eMail, and fax.
7. Meet the deadlines. Since the start of the eRate program, it’s been critical to meet the application filing deadline, but now the program has important deadlines all year long. If you don’t stay on top of these moving targets, you could lose out on funding that already has been approved.
This year, Form 470 applications must be posted online by Dec. 19, 2002 to leave 28 days before the close of the Form 471 filing window on Jan. 16, 2003. (The Federal Communications Commission generally has been unsympathetic to applicants’ last-minute crises, so it’s best to build in some extra time to make sure you can complete your applications on time.)
Once a funding commitment has been approved and the services have started, you must file a Form 486 application within 120 days of whichever date is later. When the end of a funding year rolls around, all Service Provider Invoices or Billed Entity Applicant Reimbursement (BEAR) forms must be filed within 120 days of the last possible service date (June 30 in the case of recurring services, Sept. 30 in the case of non-recurring services) or within 120 days of the receipt of a Form 486 acknowledgement letter, whichever date is later.
8. Read the instructions. At a minimum, read the instructions that accompany each form. They can be downloaded from the SLD web site. It’s also a good idea to check the SLD web site at least once a month for announcements of filing deadlines and other new program rules.
9. Remember the program may change. FCC staff members have promised they will not make any major program changes in the middle of this application season, but there might be changes in the future. In addition, the FCC has committed itself to rolling over unspent eRate commitments to future funding years, starting next spring. That means the pool of available funding may grow even larger in the futurea good reason to continue to apply, even if you have been disappointed in the past.
10. Remember that the eRate is different. The eRate program can seem frustrating at times. Nevertheless, if you follow the rules and meet the deadlines, you are pretty much assured of qualifying for discounts on at least Priority One services. At a time when government budgets are shrinking and many ed-tech grant competitions are tightening, that’s an important thing to keep in mind.
See these related links:
Schools and Libraries Division http://www.sl.universalservice.org
Funds For Learning LLC http://www.fundsforlearning.com