PIA Procedures and State Coordination:
Prior to the development of EPC for FY 2016, applicants receiving emailed questions from PIA could read them all in one document, either within the text of the emails themselves or as attachments to those emails. Halfway through the 15-day response period, if no responses were received, PIA would resend the questions to the applicants as reminders. State E-Rate Coordinators were copied on these reminder emails.
This process worked well. Applicants had a single document of outstanding questions. State coordinators had easy access to the types of questions being asked of their applicants statewide, and could, if appropriate, proactively intervene to provide assistance.
The FY 2016 PIA process is much more complex. Applicants first receive an email notifying them that questions are pending within their EPC portals. Initial EPC access leads to a list of inquiry types. Within each inquiry list, individual questions must be accessed and answered separately. If a specific question has subparts, as do most, each subpart requires an answer (whether applicable or not). Reminder emails, if necessary, are sent to applicants about a week later, directing the applicants back into the inquiry section of their EPC portals. In the case of public schools and libraries, copies of those reminder emails are sent to the appropriate state coordinators.
From an applicant’s perspective, we believe that it is important to understand how the revised EPC-based PIA process affects the review efforts of their State E-Rate Coordinator. Even in states with active coordinators, these changes will affect how much support applicants are likely to receive without proactive outreach on their own behalf. In particular:
- As with applicants, State E-Rate Coordinators must follow the same convoluted train of EPC steps to see all PIA questions for each application (and, ultimately, to eliminate the “Task” generated within EPC for each question viewed). From a workload standpoint, this is likely to limit a coordinator’s role in the PIA review process for public schools and libraries.
- State E-Rate Coordinators no longer receive any PIA notices for non-public school applicants.
To more fully understand these limitations, here’s how the PIA review process works for State E-Rate Coordinators:
- Coordinators are copied on the PIA reminder e-mails sent to applicants. One minor problem in this regard is that, depending upon the individual PIA reviewer, the email may or may not specify the applicant name or application number. In the worst case, the email simply reads:
This is a small annoyance to coordinators trying to determine which applicant is being referenced before clicking through into EPC.
- The “Click here” link doesn’t actually lead to the details, but to a somewhat generic letter in the applicant’s EPC “News” feed including a list of the types of inquiries. A link within the “News” letter doesn’t lead to the questions either, but to the applicant’s Form 471. From there, use the link to “Review Inquiries.”
- The “Review Inquiries” page still shows only the basic question types (six different Category 2 questions in the following example). To get closer to the actual questions, click on the “Respond to Inquiries” link.
- Getting closer. “Respond to Inquiries” links to a similarly formatted page, but each question “Name” is now a hot link.
- Clicking on the first “Category Two Budget” link gets you to the page addressing the first actual inquiry consisting, in this case, of three questions and/or sub-questions requiring eight responses. For a State E-Rate Coordinator, seeking only to see all questions on this application, the next step is to click on “Save and Continue,” returning to the previous list of “Pending Inquiries,” and clicking on the hot link for the next inquiry until all six sets of questions have been reviewed.
- To further compound the process, each time a State E-Rate Coordinator (or applicant, for that matter) views one set of questions, EPC generates a “Task” for that user.
In this example, there were six sets of questions. Viewing them all would have resulted in six separate tasks. If a State E-Rate Coordinator wishes to avoid a seemingly endless list of pending “Tasks,” it is necessary to clear them out one-by-one. This can be done by clicking on each “Task” individually, returning to the “Pending Inquiry” list, and clicking the “Close” button at the bottom.
Good intentioned as they are, we believe that State E-Rate Coordinators are going to be hard-pressed to keep up with all the PIA reminders they are being sent this year. Applicants (and their consultants) needing state coordination assistance this year should proactively reach out to their State E-Rate Coordinators. A list of the state school and library coordinators, as best we can determine, can be found on the State Information pages of the E-Rate Central website.