Annexes for Multi-Location Schools and Libraries:
USAC has traditionally relied on the states to define individual schools and libraries. This is usually a straight-forward exercise as long as a single school or library is contained within a single building. In some cases, however, a school or library, as defined by a state, has two or more locations. Most often, we have seen this situation arise with private/parochial schools in urban areas when, for example, the school might house K-5 grade students in one building and 6-8 grade students in another. We refer to these types of situations as “multi-location schools.” Multi-location libraries also exist, but less frequently. In either case, we are discussing instructional school or library facilities.
For E-rate purposes, USAC has historically addressed these situations by assigning separate entity numbers to each school or library location. Thus a multi-location school, for example, would have multiple entity numbers (unless they were on the same “campus”). Note that in either a multi-location school or library case, the aim is to designate separate instructional facilities (as opposed to an eligible non-instructional facility, or “NIF”). This gives USAC the ability to track and validate that E-rate services are being delivered to eligible locations.
In particular, it is important to recognize that there is a difference between the way multiple locations were previously treated for Priority 2 services, and the way they are being handled as of FY 2015 for Category 2 services. The limiting 2-in-5 rule for Priority 2 treated each school or library location separately. Multi-location schools and libraries, therefore, had separate 2-in-5 accounts for each location. Category 2 budgets, on the other hand, refer to individual state-defined schools and libraries. Although USAC still needs to know and track where services are being delivered, a multi-location school or library has a single Category 2 budget.
The big change under the EPC portal is that a multi-location school or library will have one main listing, using its primary address. All other instructional facilities — as opposed to NIFs — will be treated as “annexes.” A Category 2 budget for a multi-location entity covers expenditures for its main location and any annexes.
To view existing annexes within EPC, use the “Annexes” link in the activities list shown on the left-hand side of the school or library page reading:
Currently, since “annexes” is a new designation, what you are most likely to see is the following:
Annexes can be added or deleted using the “Manage Annexes” button in the top right-hand corner of the associated school or library page. Assuming the user has the requisite permission, this button leads to the following:
To add an annex, click the green “Add New Annex” button, then complete the following information:
The good news in this process is that a user can manage annexes within EPC without creating a Customer Service Case and/or calling the Client Service Bureau (“CSB”). Under the new system, annexes are not even assigned entity numbers. This is clearly advantageous for applicants adding new annexes.
What is not yet fully understood is how an existing multi-location school or library should treat any existing entities that are now being redefined as annexes. Because these entities (or locations) were not distinctly identified in USAC’s entity database, they were not automatically carried over as annexes into EPC. As a result, it appears that:
- Applicants will have to individually enter these associated multi-location sites as annexes into their EPC accounts.
- Multi-location applicants will have to check that their EPC accounts properly show only the main locations as being individual schools or libraries.
- Corrections may require CSB assistance to cancel the entity numbers for locations currently listed as individual schools or libraries in EPC, but which should now be listed as annexes.
- USAC will presumably have to validate annexes during PIA review to make sure that E-rate services are delivered only to eligible locations. To assist in this process, E-Rate Central will continue to maintain the New York State Multi-Location School database.
Multi-location applicants can begin adding annexes to their EPC accounts now. Additional USAC guidance on annexes is expected shortly.