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Shortly after the FY 2003 Form 470 deadline on January 9th, Funds For Learning, an E-rate consulting firm with excellent E-rate database skills, released an analysis of the filings. The firm reported that 24,246 distinct applicants had filed timely Form 470s, a number only slightly less than last year's total of 24,809 applicants. At least as an early indicator, this suggests that the demand for E-rate funds in FY 2003 will remain high.
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The SLD reported this week that it has already received over 10,000 Form 471 applications for FY 2003, well ahead of the pace of the past few application windows when the vast majority of the applications came in during the last week. One reason for the relatively early filings may be the extended window period this year.
FY 2003 applications that have been received are already being processed. The SLD indicated that Form 471 Receipt Acknowledgment Letters ("RALs") will start arriving next week. As with the Form 470 acknowledgements, look for this year's yellow envelopes and letters.
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E-rate wisdom according to Dilbert: "I love deadlines. I especially like the whooshing sound they make as they go by." For E-rate applicants, the most recent whooshing sound was the FY 2003 Form 470 deadline that flew by on January 9. As discussed in last week's newsletter, there are only limited situations under which applicants who missed the Form 470 deadline can now file a valid Form 471 for FY 2003 (see the Weekly News Archive on the E-Rate Central Web site).
While most applicants are now focusing on the upcoming February 6th deadline, the last day of the Form 471 application window for FY 2003, there are actually several other upcoming deadlines that apply to various earlier funding year filings.
One important date is January 28, 2003. This is the basic deadline for filing invoices (BEAR reimbursements or supplier invoices) for non-recurring services that had to be utilized by September 30, 2002, including installations funded in FY 2001 or in the out-of-the-window period for FY 1999. Invoices postmarked after these deadlines will not be processed and funding will be lost. Remember that BEAR forms must be acknowledged by suppliers before they can be submitted.
The other upcoming deadlines are for FY 2002 Form 486s which must be filed within 120 days of the start of service (normally July 1, 2002) or the date of the Funding Commitment Decision Letter ("FCDL"), whichever is later. The deadlines for applicants funded in Waves 1-11 have already passed. Applicants funded in subsequent waves, have later Form 486 deadlines. Here are the next few:
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| The penalty for missing a Form 486 deadline is a reduction in funding. If, for example, an applicant funded in Wave 6 does not file the associated Form 486 until January 29th, the SLD will adjust the start date to 120 days prior to the postmark date (i.e., to October 1, 2002) and reduce the funding accordingly (i.e., to 9/12ths of the originally approved amount). |
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Applicants will soon need to learn a new acronym. The SLD announced this week that it will shortly begin enforcing a requirement that vendors have updated Service Provider Annual Certification Forms ("SPACs") on file before BEAR reimbursement forms can be processed.
Current SLD regulations require vendors to file updated SPAC forms (designated as Form 473s) each year. The form lists all a vendor's SPINs and certifies its understanding of the SLD's invoicing rules. Unlike most other E-rate forms, there is no deadline for SPAC submission. Under current rules, the SLD will not process a vendor's SPIF (Service Provider Invoice Form) for a given funding year unless that vendor's SPAC for the same year has been filed. However, the same criteria had not been applied to the processing of applicant BEAR forms. As a result, there has been no real incentive for non-discounting vendors to keep their SPAC filings up-to-date. This will is about to change. Unfortunately, this vendor change is likely to create BEAR problems for applicants.
If, for example, an applicant files a BEAR this summer for discount reimbursement on services received from a vendor for the 2002-2003 school year, the BEAR would be approved under the new rules only if the vendor had filed a FY 2002 SPAC. Note that the SPAC requirement is funding year specific. A SPAC must be on file for the same funding year covered by the associated BEARs. We expect that often this will not be the case and that the BEARs will be rejected. The applicant's recourse, in this case, is to push the vendor to file a SPAC for the earlier year and then to resubmit the BEAR.
To avoid future problems on FY 2002 BEARs, applicants may want to check whether their vendors have filed FY 2002 SPACs. This can be done in the Service Providers section of the SLD Web site using the "Service Provider Information by SPIN" database (see SPAC Search). To use it, enter the vendor's SPIN, select the appropriate funding year (07/01/2002 - 06/30/2003), and click "Search." The resulting screen will show a lot of information (mostly meaningless to applicants) including the key indicator found in the "status" field. The status will indicate the "Certified on" date if a SPAC was filed for that year, or will indicate "Not received." If a SPAC has not been filed, we recommend that applicants encourage their vendor to do so ASAP.
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