Form 470 Deadline:
Applicants, who have not already done so, should do themselves a favor and file their Form 470s for FY 2014 as early as possible in the New Year.
Technically, this year’s deadline for filing a valid FY 2014 Form 470 and/or RFP is February 26, 2014. However, waiting until the deadline leaves no room for error. Since a Form 470 must be posted for 28 days, a February 26th filing would mean that on March 26th the applicant would have to:
- Select vendors
- Sign contracts, if required
- File a Form 471 — the final day of the FY 2014 application window!
Applicants filing Form 470s on paper are reminded to use the revised version which became effective December 20th. The revised paper version can be identified by the “December 2013” date in the bottom right-hand corner of each page. A type-in PDF version of the revised Form 470 is available in E-Rate Central’s Forms Rack.
USAC sent out warning e-mails last week to applicants who had started, but who had not completed, the older version of their Form 470s online before December 20th. Those Form 470s may still be completed online, but with care. Previously entered data on the old version of the Form 470s have been carried over into the incomplete new version — except for any services listed in the old Item 9 for Internet Access services. The old Internet services must be reentered into Item 8, the combined Priority 1 list of services.
Form 486 Deadlines:
Typically, a Form 486 must be filed no later than 120 days from FCDL issuance or the start of service, whichever is later. Assuming services started July 1, 2013, the deadlines for FY 2013 funding waves 1-17 have already passed. The remaining Form 486 deadlines for January are:
Wave 18 01/16/2014
Wave 19 01/23/2014
Wave 20 01/30/2014
Form 486s filed on paper on or after December 30th must use the revised “December 2013” version (see SLD News Brief discussion below). A type-in PDF version of the revised Form 486 is available in E-Rate Central’s Forms Rack.
E-Rate Audits:
Applicants have begun reporting a new round of Payment Quality Assurance (“PQA”) audits — although USAC doesn’t like to call them “audits.” This is a program required by the Improper Payments Information Act of 2002 (“IPIA”) and the Improper Payments Elimination and Recovery Act of 2010 (“IPERA”). Under the program, USAC randomly selects paid invoices, then asks the associated applicants to provide the following type of information (if applicable) specifically related to those FRNs:
- Any document indicating the beneficiary’s eligibility status
- Technology Plan Approval Letter
- Service provider bills related to disbursement under review and documentation showing proof that discount was received
- Letter of Agency (“LOA”)
- Documentation related to service provider selection
- Proof of payment to service provider
- List of entities that received services
- Budget statement for funding year under review
- Documentation supporting Children’s Internet Protection Act (CIPA) compliance
Those who are or have been audited by USAC may be pleased to know that USAC itself is audited annually. USAC’s 2013 audit is now underway. As a part of this process, a limited number of applicants and service providers received e-mails last week asking them to confirm funding balances as of November 30, 2013. The e-mails were sent by either DP George and Company or Kearney and Company.