URGENT: PY4 filing deadline and procedures
The deadline for filing PY4 Form 471s within the application window is next Thursday, January 18. Please note the following:
- Unlike last year, the January 18th deadline is the date by which all required material (see below) must be postmarked (as opposed to being received by the SLD).
- Unlike last year, applicants filing online are NOT being given extra time to mail their signed 471 certifications and Item (21) attachments.
- Applicants, who previously filed their Form 470s online, must make sure that their signed 470 certifications have also been sent by the January 18 deadline.
- We strongly recommend that all application material be sent to the SLD via an express mail service that allows tracking of shipments. If the material is simply mailed, even with a return receipt request, but never arrives at the SLD, it may be impossible to prove when it was sent and to convince the SLD to accept, as timely, a replacement filing.
- The SLD will accept an express mail pickup date as the equivalent of a “postmark” date. If there is any question as to when a package was picked up, the SLD intends to use the courier service’s online tracking record to confirm the date.
- Technically, applicants could save a few dollars by using second day express services. If mailing on Thursday, we recommend using NEXT DAY service. Second day shipments, sent on the 18th, may not arrive until Monday. As such, they may be placed in a slower processing queue while the SLD confirms the Thursday “postmark.”
- As in past years, the SLD has posted driving directions from the Kansas City airport to their Lawrence facility. Applications that are hand-delivered must be received by 11:59 p.m. EST. It’s hard to envision a situation under which an application would have to be delivered to Lawrence by midnight on the 18th because it could not be postmarked earlier in the day, but the directions are there for your use. A better safety strategy would be to pre-determine when your local post office or express mail office closes on Thursday night and allow plenty of time to beat that closing.
- Note: If sending an application package late on Thursday, do NOT simply drop it into a box. Make sure it is formally postmarked or logged.
- Please review the SLD’s Web site for instructions on the Form 471 filing deadline.
Telephone help from the SLD’s Client Service Bureau (888-203-8100) will be available from 8:00 a.m. – 8:00 p.m. every day of this three-day holiday weekend.
The eligibility of schools for E-rate purposes is defined by individual state law definitions of primary and secondary education. Based on an analysis of the various state laws, the SLD has determined that, under New York’s (and about 20 other states’) laws, pre-K students are eligible. Somewhat perplexingly, the determination is that, although the pre-K students are eligible, separate pre-K facilities are NOT!
As such, the SLD is now telling us that New York applicants should include pre-K students in their discount rate calculations for schools that include pre-K and higher grades. Pre-K only schools remain ineligible, so student counts for those schools are irrelevant.
The inclusion of pre-K students in school counts can positively or negatively impact the discount rate calculation (depending upon the availability of data on pre-K eligibility for free and reduced price lunches, free milk programs, etc.). Since the SLD has not yet publicized these state-by-state rulings, we are not currently anticipating problems for NYS applicants submitting PY4 applications that do not include pre-K student counts. It is possible, however, that this situation may change by the time these applications are reviewed; applicants may want to begin planning now to compile pre-K eligibility data.