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E-rate News for the Week
November 26, 2001
The following is a summary of the E-rate News for the Week of November 26, 2001, prepared by E-Rate Central. Official SLD news appears in the “What’s New!” section of the SLD’s Web site . Additional and archived information appears elsewhere on the E-Rate Central Web site .

PY4 Wave 9 Released

Wave 9 of Funding Commitment Decision Letters (“FCDLs”) was mailed on Friday, November 30. Total funding in this wave was $50 million. Cumulative funding for PY4 now stands at $1.694 billion, with an estimated 15-20% of available funding yet to be awarded.

Funding for internal connections is still being awarded only to applicants at the 90% discount level. Applicants at the 85-89% level are currently being funded for telecommunications and Internet access, but are being advised that their internal connection requests are as yet unfunded.

FCC E-rate Audits

Approximately 8-10 E-rate applicants received letters from the FCC’s Office of Inspector General this week advising them that they have been selected for on-site audits of their PY2 funding. In total this year, the FCC expects to conduct an estimated 80 PY2 audits. FCC audit targets have been selected on a random, dollar-weighted, basis that makes highly funded applicants much more likely to be audited. The FCC audits will be in addition to similar audits yet to be scheduled this year by the SLD itself (using either Arthur Anderson or SLD staff personnel). Overall, we expect well over 100 on-site audits to be held this year (compared with only 17 last year).

The FCC audit selection letters are instructive because they indicate a number of key areas of concern and set forth certain preliminary document requests. The areas to be assessed were listed as:

  1. Establishment of a process to select the most cost effective service provider. In situations where alternative service providers were selected (i.e., other than the most cost effective), sufficient reasons have been documented.
  2. Equipment and services are purchased in accordance with applicable procurement rules and regulations.
  3. Services rendered are consistent with what was presented on application for E-rate funds and were installed before the Funding Year Two installation deadline.
  4. [Applicant] has adequate resources, as certified, to use the discounted service for which funding has been provided.
  5. [Applicant] has an approved technology plan as certified.
  6. Approved funding and corresponding service are provided to the correct recipient.
  7. Payment to [applicant] via BEAR Form 472 or to its Service Provider(s) via Service Provider Invoice Form 474 are made in accordance with approved funding requirements and do not exceed amounts approved per the associated funding commitment letter.
  8. The services obtained are used for the purpose for which funding has been provided as certified on the [applicant] application.

In preparation for the audit, and prior to the initial “entrance conference,” the FCC is asking the applicant to mail the following materials:

  1. Copy of technology plan and approval letter.
  2. Copy of Fiscal Year 1999-2000 technology budgets.
  3. Copy of OMB A-133 Report for FY 1999 and FY 2000, [if applicable].
  4. Copy of FY 1999 and FY 2000 financial statements.
  5. Basis for Discount Calculation – rural vs. urban and eligibility for National School Lunch Program.
  6. Overview of Service Provider’s selection process at your school.
  7. Copies of all Year 2 contracts with your Service Providers.
  8. General description of the information technology environment and a high-level network diagram. The description should include how Schools and Libraries Funding (E-Rate) for internal connections is being used in the IT environment at your school.
  9. Copies of local and state procurement regulations as they relate to contracting for the purchase of internal connections, telephone service and Internet access.
When reviewing these lists of audit criteria and document requests, remember that all applicants certify that they will maintain E-rate records for a period of five years. It should be noted that the FCC document list is not necessarily indicative of records that may be required, for example, in a SLD audit. In particular, the FCC may place a greater emphasis on an applicant’s competitive procurement processes.

Upcoming E-rate Deadlines

A combination of the recently announced PY3 Form 486 and BEAR deadlines, the PY4 Form 486 deadlines, and the PY5 application window, has established a number of critical dates for E-rate applicants. The following is a list of key deadlines that must be met over the next few months:

12/14/2001 PY3 Form 486: All FRNs for recurring services for the period ending June 30, 2001.
12/20/2001 PY5 Form 470: Absolute last day for posting a PY5 Form 470 online. (Note: Waiting until this deadline will require the applicant to sign all contracts and submit a Form 471 on the last day of the application window. A Form 470, submitted by mail, must be filed well before this date to allow time for SLD data entry and posting.)
01/17/2002 PY5 Form 471: Last day of the application window.
01/28/2002 PY3 Form 486: All FRNs for non-recurring (installation) services for the period ending September 30, 2001.
01/31/2002 PY3 BEAR: All FRNs covered by PY3 Form 486s postmarked by November 12, 2001. (PY3 BEARs for a Form 486 submitted later than this date should be filed within three months thereafter.)
02/28/2002 PY4 Form 486: All FRNs for existing services funded in Wave 7.
03/16/2002 PY4 Form 486: All FRNs for existing services funded in Wave 8.
03/30/2002 PY4 Form 486: All FRNs for existing services funded in Wave 9.
Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.
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