| In a recent book, Who Says Elephants Can't Dance? Inside IBM's Historic Turn-around, Louis Gerstner makes the point that employees do not always do what management expects, but that they do respond to what management inspects. So too, the SLD is learning that applicants do not always behave as the SLD expects, but that they do pay attention to the actual enforcement of program rules. As a result, an understanding of SLD expectations may help applicants anticipate new rules, interpretations, or procedures.
With the new funding year less than three months off, therefore, it is useful to focus on the gap between SLD expectations and many applicants' interpretation of the E-rate rules governing technology plans. Too many applicants seem to believe that all that matters is having an approved technology plan; that a plan does not have to be approved until it is time to file a Form 486; and that an approved plan is automatically good for three years. With these myths in mind, it's worth reviewing the SLD's true expectations and procedures.
(1) First and foremost, the SLD expects an applicant to have a technology plan before a Form 470 is filed requesting services. Although the rules do not require an approved plan at this time, the SLD's expectation that there be a plan is clearly stated in its program overview that identifies "preparing a technology plan" as the first step in the application process (see Overview).
(2) Because an approved plan is not required during the application process, the certifications required on both the Form 470 and the Form 471 permit an applicant to state only that a "technology plan(s) will be approved." During the Form 471 application review process, and particularly during a Selective Review, an applicant may be asked to provide "a copy of your technology plan." The plan need not be approved at this time, but there should be a plan (and it should be reasonably related to the funding requests being made).
(3) The first time that an applicant must affirmatively certify that it has an approved plan is when a Form 486 is filed after funding is awarded. Again, it is important to understand that this does not mean that applicants have until they file their Form 486s to get their plans approved.
Specifically, the SLD's rules require that, "[b]efore discounts are provided to applicants, their technology plans must be approved by an SLD-certified technology plan approver" (see Tech Plan). If, as is often the case, discounts are being requested from July 1, this means that the SLD expects the applicant to have an approved technology plan by that date - even if funding for that year is not awarded, and the Form 486 is not filed, by July 1. For example, if an applicant's plan is not approved until October 1, discounts should not be requested for any services received for the July - September quarter.
(4) SLD guidelines permit technology plans to be approved for a three year period. To be approved for three years, however, the plan should in fact cover all three years (including a three-year budget).
(5) The SLD does not require approved technology plans if an applicant is only requesting discounts on basic telephone service. Be aware, however, that the definition of "basic" telephone service is strictly limited. It includes individual line local telephone service, cellular service (essentially individual line mobile service), and long distance. Any other telecommunications services - Centrex and PBX-based services, ISDN, DSL, T-1, etc. - are considered non-basic and do require an approved technology plan.
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On March 31, as is done at the end of every quarter, the SLD mailed Quarterly E-rate Payment Authorization Reports to every applicant for which actual payments had been authorized during the period January 1 - March 31, 2003.
The total payment authorized for disbursement against any FRN can also be found using the SLD's online "Data Requests" database which is (see Open Data Search). The quarterly report, however, provides additional information. It indicates whether the payment was based on an applicant's BEAR or on a Service Provider Invoice ("SPI"), and it shows the exact date on which the invoice was authorized.
Here is a little additional information on these reports:
(1) Unlike most other SLD correspondence, the Quarterly Disbursement Authorization Reports are addressed to the person who signed the associated Form 471 application, not to the person listed as the E-rate contact. If these two individuals are the same, there is obviously no problem. But if the signer is different, the E-rate contact may have to make special arrangements to get a copy.
(2) The "Disbursement Authorization Date" shown is not the actual payment date. It is the date on which the invoice was approved by the SLD. In the case of a BEAR reimbursement, the invoice payment to the vendor is usually made about 20 days after the authorization date, and the vendor is then supposed to pass the payment on to the applicant within 10 days of receiving the payment. Thus, the applicant should start looking for a BEAR reimbursement payment from the vendor about one month after the Disbursement Authorization Date.
(3) If the report shows a SPI authorization, it means that the supplier has submitted an invoice for that FRN and is presumably discounting the applicant's service charges. The applicant should check that its bills are actually being discounted.
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