USAC has begun sending out Form 471 Receipt Acknowledgment Letters (“RALs”) for applications that have been submitted and certified for FY 2015. Although this year’s Form 471 is dramatically different from the previous version, this year’s RAL is strikingly similar.* It shows only the most basic information on each FRN (see sample FY 2015 RAL).
The primary purpose of the RAL is to allow applicants to review the discount rate and funding requests contained in their filed applications, and to make certain allowable corrections of Ministerial & Clerical Errors (“M&C” errors).
Simple corrections to the basic FRN information shown can be made on the RAL itself by making changes to the information on the applicable FRN page(s), and returning the corrected RAL to USAC by e-mail, fax, or mail (see instructions in the M&C errors link above).
Unfortunately, the Form 471 application for FY 2015 is much more complicated, particularly with respect to Item 21 details. This information does not appear on the RAL (nor does it appear in USAC’s Data Retrieval Tool (“DRT”). According to the RAL instructions (unchanged from previous years), “to request a correction to a field that does not appear in the attached Report, print a copy of your FCC Form 471 and clearly note your requested correction.” The RAL can then be returned to USAC together with corrected application section(s).
The biggest problem with the RAL correction process this year is that it is no longer possible to view in detail, much less print out, many important sections of a completed Form 471. As a result, applicants may have trouble even determining that there is an error that needs to be corrected.
As an example, suppose that a school district files an FRN for Internet used by six schools and its administrative building, but mistakenly forgets to include its middle school in the list of managed entities when completing the associated Item 21. The “Display” copy of the completed Form 471 doesn’t show the entity list for an Item 21, so how is the applicant to recognize that a mistake was made?
There are several possible answers to this question, all requiring additional actions by the applicant before or after the application has been submitted. Before submission, the applicant has two opportunities to collect application details that will not appear on the “Display” version of a completed application. The applicant can either take screen shots of the various steps along the way during the online application process, or can use the “Review Application” function available just prior to submitting the application. If the “Review Application” function is used, it is important to fully expand all sections and subsections (which can only be displayed one at a time) of the application before printing out copies. To get the entity list for a specific FRN, for example, the applicant needs to:
- Expand “Funding Requests.”
- Click on the appropriate Item 21 button.
- Click on the little “+’ symbol at the left-hand side of the Item 21 data line.
Note that service providers are also sent RALs showing only the same basic information for the specific FRNs associated with their SPINs. The service providers will not have access to the optional pre-submission information discussed above unless it is provided by their customer.
After the application has been submitted, there appears to be only one way for applicants (and service providers) to get additional application data not found in the “Display” version of a completed Form 471 (or DRT). A new Download Form 471 Information tool is available to generate additional FY 2015 application data. Although apparently designed to collect aggregate data, it can be used to pull data on specific applications, albeit requiring a certain amount of data manipulation. The tool works on a state-by-state basis creating the following seven spreadsheets with filed application data for each state:
- Basic Information and Certifications
- Billing Account Numbers
- Connectivity Questions
- Discount Calculations
- Funding Request Key Information
- Item 21 Entity Cost Allocations
- Item 21 Services and Costs
Entity lists, for example, are included in the “Item 21 Entity Cost Allocations” file. The entity data, however, is provided by FRN and there are no data fields in this file for either application number or billed entity number. The applicable funding request numbers can be obtained from the RAL. Another easy source for obtaining the FRNs for a given application is to use the Funding Quick Search tool available in the upper left-hand count of each State Information page on the E-Rate Central website, drilling down to the DRT-based FY 2015 data.
Given the lack of detailed application data included in the RALs and in the “Display” versions of completed FY 2015 applications, it will be interesting to see what data is made available to PIA for application review and how the PIA reviewers will interact with the applicants.