The FCC Form 471 application filing window for FY 2015 opened last week at noon EST on Wednesday, January 14, 2015. It will close at 11:59 pm EDT on Thursday, March 26, 2015.
With the opening of the window, we have gotten our first look at the new online Form 471 system. We will discuss many of the details of the system’s use and the data requirements of the revised Form 471 in future newsletters. As a preliminary matter, the following two observations should be noted:
First, the online 471 system for FY 2015 is based on a completely new IT platform. It has been designed, not only to include the new data requirements of the revised Form 471, but to be more user-friendly. Overall, we have been impressed with the look and feel of the system. Not unexpectedly with a new system, however, there are some quirks and bugs. While we don’t expect these issues to prevent applicants from successfully submitting their Form 471 applications, additional fixes and clarifications from SLD continue to be provided. In general change requires adaptation, patience and flexibility. Working with the new Form 471 is no exception.
Second, the level of data required, particularly for each Block 5 funding request, is much more extensive than in earlier versions of the Form 471. Most importantly, Item 21 requirement details are now embodied in the Form 471 application itself — and in a highly structured fashion — rather than in separate attachments. Because of the added extent and complexity of the Item 21 data requirements, this year’s Form 471 is not one that you will want to start completing near the end of the application window.
Our major suggestion for this year is: Start work on your Form 471 application(s) NOW!
This is the best way to find out what information you’re going to need and to become accustomed, at least partially, to how the Form 471 online filing system works. There are three ways to start now.
- Start a real Form 471 online. Unless you have at least one valid Form 470 past the 28-day posting period, you can get only as far as the Block 4 discount rate portion, but even that is a good start. To start a 471, go to Apply Online, click on “FCC Form 471 – FY2015,” enter your Billed Entity Number (“BEN”) when requested, and click “Next.” Once you’ve completed the basic contact information, the system will assign a FY 2015 application number and security code. Write that down (or print it) because you’ll need both numbers to get back into the application for additional work later.
Note: Be careful when entering the BEN and clicking “Next.” Make sure to wait for the system to accept the data. If you get impatient and click “Next” again, the system will create a second Form 471.
- Work offline on the Block 4 discount rate information and/or the Block 5 funding requests using USAC’s Form 471 Templates. The templates include all the fields that are required for the two most difficult portions of the new Form 471. Properly completed templates can ultimately be uploaded when completing an online Form 471. There are two versions of the Block 4 template, one for schools and one for libraries. The Block 5 templates come in four versions, one for Category 1 services and three for various Category 2 services. The templates are in Excel format, and must be macro-enabled. We suggest carefully reading the template instructions beforehand. Because of the Excel macros, data must be entered left-to-right in the columns. There are also limitations on how data can be copied and pasted, if at all, from external sources or spreadsheets.
- Practice filing an online Form 471 using USAC’s Forms 470 and 471 Training Site. Dummy applicant data is provided in the test site instructions. Because USAC is making almost daily updates to the online Form 471 system, and the real filing site takes precedent over the training site, we have found that the test system is a bit more quirky and slightly different from the real site. Nevertheless, it does provide an excellent introduction to the new online Form 471.
The following are three initial comments on using the new online Form 471:
- The previous online Form 471 filing system had both direct entry and interview modes. The new system has one basic mode — except for Block 5. At that point, you have an option of proceeding on a “step-by-step” or on an “all on one-page” basis.
- Printing an online Form 471 as it is being worked on is problematic because the system condenses certain sections after they’ve been completed. To review an entire section, it must be expanded. To view and print a completed Form 471, expand and use the “Print Preview” function available just prior to the final certification stage. Printing is best accomplished using the print icon at the top right of the screen.
- Care must be taken when completing Block 5 funding requests that include both eligible and ineligible components. In the past, such a Block 5 would start with the total costs of a product or service, subtracting out the ineligible costs to get to the eligible costs. The Item 21 detail on the new Form 471 doesn’t include fields (one-time or recurring) for total costs, just for eligible and ineligible costs. We suggest using the “Narrative” section in the Item 21 detail to explain — particularly for future PIA review — that ineligible costs have been properly handled.