News of the Week

The closing date for the FY 2003 Form 471 application window has been extended from January 16th until Thursday, February 6, 2003.

The primary reason for the extension relates to problems that the SLD experienced with its online filing system when the window opened November 4th. A new system platform was initially used, but proved to be unstable. After two weeks, the SLD reverted to the previous platform. In order to assure full, unimpeded, online entry for at least 74 days - the length of the original application window - the SLD extended the window an additional three weeks.

SLD Warning on Form 470 Process

A serious warning was posted on the SLD Web site this week concerning violations the SLD has been seeing in the application and competitive bidding patterns of certain applicants and associated service providers. The SLD indicated that it has started denying related applications.

The following patterns and practices were discussed in the SLD's warning:

(1) Applicants cannot file a Form 470 indicating there is no RFP (i.e., by checking Item 8b, 9b, or 10b) when, in fact, there is a RFP available for the services being requested.

Note: If, for a given category of service, there is a RFP for one type of service and no RFP for other services, the applicant must file two Form 470s - one checking the "YES" box and one checking the "NO" box (and listing the non-RFP services sought).

(2) The Form 470 (or referenced RFP) must define the specific services or functions being sought.

Note: The original warning (posted 12/3/02) appeared to require that the Form 470 list a very precise description of "specific services" needed. The revised posting (on 12/4/02) added the words "or functions." Form 470 instructions give several examples of descriptions of "Service or Function" that indicate the broad nature of acceptable functional descriptors (e.g., "videoconferencing services," "high speed direct access to the Internet," or "local area network"). This should be combined with an appropriate indication of quantity or capacity (e.g., 5 buildings, 100 classrooms, or 50 users).

(3) Service providers cannot assist an applicant in developing a technology plan after a Form 470 has been posted.

Note: More precisely, the SLD expects an applicant to have a technology plan - although not necessarily an "approved" plan - before posting a Form 470.

(4) Winning proposals cannot provide "free" ineligible services.

Note: A minor clarification is provided in the SLD reference section dealing with bundled services that include ineligible components on a purely ancillary basis (see minor clarification).

(5) RFP and winning proposals cannot be designed merely with the goal of "maximizing" funding.

(6) RFPs and other solicitation methods must be tailored to the needs of each applicant.

SLD Provides Item 21 Attachment Examples

A Form 471 Item 21 Attachment section has been added to the Reference Area. This document explains what an Item 21 Attachment should contain, details the acceptable methods for submission, and provides sample attachment formats for: outlining Telecommunications, Internet Access, and Internal Connections services; describing ineligible functionality; using representative bills; amortizing large installation charges; justifying on-premise Priority 1 services; and certifying non-use of remote access services.

Upcoming E-rate Deadlines - Updated

While most applicants are focusing on the new February 6th deadline, the last day of the Form 471 application window for FY 2003, there are actually several other earlier deadlines that apply to the FY 2001 and FY 2002 filings.

The first is the extended deadline for filing invoices (BEAR reimbursement or supplier invoices) for recurring services received in FY 2001. These invoices must be postmarked by Monday, December 9. The invoice deadline for non-recurring services, that must have been installed by September 30th, is January 28, 2003. Invoices postmarked after these deadline 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. Most applicants funded in Waves 1-6, with FCDL dates on or before July 1, were subject to the well publicized Form 486 deadline of October 29, 2002. Applicants funded in subsequent waves, have later Form 486 deadlines. Here are the next few: