• FY 2003 Filing Window Is Open
• Responding to Vendor Form 470 Inquiries
• BEAR Deadline Extension for FY 2001
• AT&T Wireless E-rate Status

FY 2003 Filing Window Is Open

The Form 471 application window for FY 2003 opened on Monday, November 4, 2002. The Form 471 online filing system is operating on a new platform this year and there are still some early technical problems; the SLD Web site recommends waiting a few days before beginning the online filing process. Applicants experiencing problems with the system, including large applicants attempting to use the Copy Block 4 option, should call the SLD Client Service Bureau at 888-203-8100.

The Form 471 window will close at 11:59 p.m. E.S.T. on Thursday, January 16, 2003. Applications mailed or completed online after that time are unlikely to be funded. Please do not wait until the last minute to file.

Applicants, who have not yet filed Form 470s for FY 2003, should do so now. The Form 470s must be posted on the SLD Web site for a minimum of 28 days before vendors are selected, contracts are signed, or Form 471s are signed and submitted.

Responding to Vendor Form 470 Inquiries

The Form 470 is considered by both the SLD and the FCC to be a critical part of the E-rate application process. The 28-day posting requirement is designed to give all service providers access to applicant needs so that they can compete for an applicant's business in a fair and open competitive environment. It is important, therefore, that every applicant understand its obligations and responsibilities for responding to sales inquiries from vendors generated as a result of a posted Form 470.

In many cases, vendors simply use posted Form 470s to expand their prospect lists for sending general sales material. An applicant receiving general vendor information may learn something by reading it, but is under no obligation to proactively respond.

However, if a vendor responds specifically to a posted request for service, either to ask for more details about service needs or to propose a specific product or service, then the applicant should respond appropriately. Here are a few practical suggestions for responding to vendor inquiries:

(a) Be polite. This is not an E-rate rule, but is an admirable social grace.

(b) Recognize that a vendor can access posted Form 470 information either by viewing a specific applicant's Form or by downloading summary data for multiple applicants. Vendors using summary data do not know what preferred mode of contact has been specified or any details of posted service requests. In response to an inquiry made on this basis, you might suggest that the vendor review your specific Form 470.

(c) If a vendor calls, but your Form 470 indicates that the preferred mode of contact is written (i.e., mail, fax, or e-mail), it is acceptable to simply ask the vendor to respond accordingly.

(d) If there is someone else in your organization best equipped to deal with a specific vendor inquiry - perhaps the alternative contact listed in Item 11 - refer the vendor to the correct person.

(e) If you have a formal (or even informal) RFP available for a requested service, make sure the vendor is given or can procure a copy.

(f) Keep a file of vendor material and/or a log of vendor inquiries. Even if you don't select a specific vendor for FY 2003 services, the vendor's material may be useful as future needs develop. It also documents a serious effort to respond to vendor inquiries as required by the Form 470 competitive bidding process.

BEAR Deadline Extension for FY 2001

As of FY 2001, the SLD set a new invoicing deadline for applicant BEAR forms and supplier invoices. In most cases, applicants filing BEAR forms for FY 2001 recurring services had to have such forms postmarked by October 28, 2002, which was 120 days after June 30, 2002, the last day to receive services. In apparent response to applicant confusion on this new deadline, and a number of requests for extensions, the SLD has extended the FY 2001 recurring service invoice deadline until December 8, 2002.

The SLD has stressed the point that this is a one-time deadline extension just for FY 2001 recurring services. More generally, the basic invoicing deadline remains 120 days after the last date to receive services or 120 days after the date of the Form 486 Notification Letter, whichever is later.

Note, in particular, that the invoice deadline for non-recurring services for FY 2001 has not been extended. Therefore, for most applicants and vendors, the non-recurring invoice deadline will be January 28, 2003. (120 days after September 30, 2002, the normal last date to receive non-recurring services).

AT&T Wireless E-rate Status

Many schools using AT&T Wireless for cellular services received a postcard last week notifying them that the company would no longer be participating in the E-rate program after this funding year and advising them not to list AT&T Wireless on their FY 2003 applications.

By week's end, AT&T Wireless notified the SLD that it was retracting this decision, will continue its participation, and will so notify all customers who had received the first postcard. Current customers, therefore, can again select AT&T Wireless for cellular services for FY 2003.

As a general rule, suppliers of Internet Access and Internal Connection services are free to participate or not participate in the E-rate program as they chose. As a result of this recent AT&T Wireless confusion, however, the FCC is examining whether E-rate participation by a telecommunications carrier is mandatory.