By Peter Kaplan
As hard as it is to believe, the eRate process is not rocket science, nor does it involve calculus. This article explains the steps you need to take to “survive” another application season. For the eRate novice, this will serve as a starting point to demystify the process–and for program veterans, it will strengthen your understanding of the eRate rules and regulations.
Conceptually, the process is not hard to understand. eRate applicants will conduct their competitive-bidding process this fall, apply for funds in early 2006, have their applications reviewed in the spring, receive their funding commitment decision letters in early summer, and have their services start on July 1. The devil, of course, is in the details.
Before you post or file any forms, you need a technology plan. Your plan doesn’t need to be approved, however, until your services start the following year. The SLD has outlined five criteria for approved technology plans. They must (1) state goals and objectives; (2) detail a professional development plan; (3) contain a needs assessment; (4) outline a budget; and (5) include an evaluation process. Remember that service providers can give “technically neutral advice” in helping you with your plan.
Once your technology plan has been drafted, you can begin procuring products and services. To start the competitive-bidding process, you must post a Form 470 to the SLD web site, which tells the eRate vendor community which services and products you’re looking to procure, for at least 28 days before signing any contracts. You also need to follow your own state and local procurement regulations, which means you’ll often need to submit a formal Request for Proposals in conjunction with posting a Form 470. Once your Form 470 is posted, the SLD will give you an “allowable contract date”–and it’s imperative that you don’t sign contracts until that date, or your request will be denied. Your Form 470 will need to be certified before the Form 471 filing window closes.
Applicants must choose their service providers by selecting the most “cost effective” solution. There can be many factors when deciding who your vendor will be, but price needs to be weighted the most. Applicants and service providers both need to sign and date the contract before the Form 471 filing window closes, or the SLD will deny the application.
So, you’ve conducted the competitive-bidding process, waited 28 days, and signed your contracts. Now what? The FCC will open a filing window beginning sometime in November or December and lasting until possibly early February. During this window, you must file your Form 471 application. Form 471 tells the SLD which vendors you’ve selected, which products or services you’ll be purchasing, and how much in eligible discounts you’re requesting. Most typos or clerical mistakes cannot be corrected. For example, let’s say you requested $10,000 per month, but you meant $100,000 per month. Once the Form 471 filing window closes, the SLD will not let you request more money than what was originally listed on your Form 471.
Once you’ve filed your Form 471 with the SLD, the next step is to send the SLD your “description of services.” Based on this information, the SLD will determine what you are using eRate funding for and ensure that what you’re requesting is an eRate-eligible solution.
You must remember to request only eligible services. Literally millions of dollars in funding requests are denied every year because 30 percent or more of a particular funding request was for ineligible products or services. So, you must either request only eligible services or subtract the ineligible costs from your request. Your service providers can help you create your “description of services” attachment–and I would urge you to share this document with your service providers.
During the spring and summer months, the SLD starts reviewing applications, and applicants will receive multiple questions from the SLD’s Program Integrity Assurance team. It’s critical to be responsive to their requests for more detailed information, or they will decide the fate of your application based on the information they have. You can request extensions if you need more time.
Even when your funding finally is approved, you’re still not done yet. For either you or your service provider to receive funds from the SLD, you need to file a Form 486. This form tells the SLD your services have started, you are CIPA compliant, and your technology plan is now approved. Form 486 is due 120 days after your services start or after you receive your funding commitment letter, whichever is later. If you miss this additional deadline, your funding will be reduced.
After your Form 486 is processed, you or your vendors can start billing the SLD. If you’ve paid your vendor the full cost of the service up front, you’ll need to file a BEAR Form with the SLD to get reimbursed. If you’ve requested discounted invoices from your vendor instead, then your vendor will need to submit a Form 474 to the SLD for reimbursement.
eRate applicants and service providers should work together to ensure a successful eRate experience for all.
Peter Kaplan is the director of regulatory affairs for eRate consulting firm Funds For Learning LLC.
eRate Survival Resources:
E-rate Manager (www.eratemanager.com) is a free, web- based tool that Funds For Learning designed to help eRate applicants manage and track their eRate dollars and meet all critical deadlines associated with the eRate program.
Funds For Learning (www.fundsforlearning.com) is a nationally recognized expert on the eRate and other funding sources.