New SLD Web Resources
This week, the SLD posted a four-page summary of the E-rate program on its Web site (see E-Rate Summary). It provides a succinct review of the major steps, filing requirements, and deadlines in the E-rate process.
Next week, the SLD has announced that it will begin providing detailed Form 471 and FRN data in a Web-enabled database format. As a first step, users will be able to input selection criteria by service type, application type, discount percentage, 471 number, and/or FRN. The SLD's system will build a tab-delimited file of funding status data that can be downloaded for applicant use. Future versions of the system will include funding disbursement data which will allow applicants to track actual BEAR or supplier payments in a usable way. This is information that is currently available only in the Quarterly Disbursement Reports.
One interesting aspect of this development is that the SLD had previously avoided releasing detailed funding information by applicant or service provider on privacy grounds. As indicated in the SLD's announcement, however, the FCC has now determined that the federal Privacy Act of 1974 pertains only to individuals and, thus, does not apply to E-rate applicants.
We have noticed a trend among service providers to request additional information from E-rate applicants to assist them in processing discounts that are being awarded for FY 2002. Typically, the vendor requests are being made to determine applicant preferences for discounted billing vs. BEAR reimbursement or to gather additional information on service eligibility that the SLD does not otherwise provide to the vendors. Generally, we view these requests as valid and encourage applicants to respond accordingly. Several examples of vendor requests are summarized below.
AOL: America Online has developed a special rate for E-rate participants for an annual period coinciding with each funding year (7/1/2002- 6/30/2003 for FY 2002) and will discount that rate for each account listed on their request form (designated "AOL E-rate Account Agreement Program Year 2002"). The AOL request form asks for contact and billing address information, and for a list of existing and new accounts (with screen names).
Nextel: Nextel's request form asks its E-rate users to choose between Monthly Adjustments (i.e., discounted bills) and the 472 BEAR Process. It also asks applicants to specifically acknowledge that equipment and voice mail charges are not eligible for discounts, and that the users are responsible for all service charges beyond their funding commitments. Interestingly (unlike Verizon Wireless - see below), Nextel does not ask for any identification of eligible vs. ineligible units; presumably, if the Monthly Adjustment option is selected, Nextel plans to discount all service usage charges up to the funding commitment level.
Verizon Wireless: Verizon's "SLC (sic) Customer Information Form" requests funding, contact, and account information, and asks users to choose between discounted monthly billing and BEARs. For the first time this year, Verizon is asking its E-rate customers to identify their eligible accounts or, if their accounts include both eligible and ineligible users, to identify individual eligible mobile numbers. This will permit Verizon to correctly discount eligible services only. Applicants completing the Verizon Wireless request form should review any eligibility allocations made in their original Form 471 applications (and any adjustments made by the SLD) to ensure that discounts are applied consistent with approved funding.
A recent USAC Billing and Disbursement newsletter sent to service providers includes a reminder that each vendor is required to submit an Annual Certification Form (Form 473) for each funding year. The SLD will be unable to process either BEAR or SPI invoices for any vendor that has not filed a Form 473 for a given funding year. Copies of a Form 473 and instructions can be downloaded from either the SLD or E-Rate Central Web sites (see Forms ).
One way to check if a vendor's Form 473 has been submitted and has been processed is to query Service Provider Information by SPIN in the SLD's Web site (see Service Provider Area). Enter the vendor's SPIN, selected the funding year in question, and click "Search." If a Form 473 has not been received for that year, Item 4 of the search results page will show "Not received."
The same Billing and Disbursement newsletter also noted that if a vendor's contact or address information has changed, a revised Form 498 must be filed. Please note, as per the last page of the Form 498 instructions, that a separate certification letter on company letterhead must accompany each Form 498.