October 28th is the last day to invoice the SLD for FY 2003 recurring service discounts. Applicants, who have been paying in full for monthly telecom, Internet, or other eligible services, must submit BEAR (Form 472) forms by this deadline or lose all retroactive funding. Please remember that BEAR forms must be acknowledged and signed by the associated service providers before they can be submitted so applicants shouldn't wait until Wednesday or Thursday to seek vendor signoff. Vendors, who have been discounting bills for their customers, must file Form 474 Service Provider Invoice ("SPI") forms by the same date.

October 29th is the deadline for filing Form 486 funding confirmations for FY 2004 awards that were issued in Waves 1-7. The failure to meet the Form 486 deadline will result in a reduction in funding. This reduction in funding will become progressively worse as the Form 486 remains un-filed.

The mid-December window opening this year will be 5-6 weeks after the early November openings that had been the practice in recent years. Since very few applications have ever been filed in November, however, the delayed opening this year is not expected to adversely impact many, if any, applicants.

The real question is when the window closes. This is the critical deadline for most applicants. Historically, the closing has occurred early in February, roughly 90 days after the window opened. This year, however, to still allow the SLD more than four months for application review before the start of the funding year, we expect the SLD to shorten the application window to about 60 days. While the SLD may actually allow a few more days, we do not expect the window to extend beyond mid-February. For planning purposes, our best guess for the closing date is Thursday, February 10. This would mean that the window would be open exactly 60 days. A formal announcement on the window dates is expected from the SLD in the next few weeks.

For all practical purposes, assuming the window closes by at least mid-February, the application cycle for FY 2005 will be similar to those of the recent years. This means that an applicant should not - we repeat, should NOT - postpone filing its Form 470 just because the window is opening later. It is still important to get the Form 470 filed early enough to have it posted for the required 28 days, to carefully evaluate all competitive bids, to select vendors and sign contracts, and to begin working on the all-important Form 471 application.

(1) Under the DCIA, all E-rate participants must have at least one FCC RN. This includes schools, libraries, consortium leaders and members (indeed, any entity that files a Form 470 and/or Form 471), service providers, and consultants.

(2) FCC rules will eventually require a FCC RN for each applicant entity. A school district, for example, would require a FCC RN for the district itself, corresponding to its Billed Entity Number, and separate FCC RNs for each of its schools and non-instructional sites, corresponding to each of its Entity Numbers.

(3) By November 1st, however, the FCC is requiring only one FCC RN per applicant or Billed Entity Number (or, more precisely, one FCC RN per Federal Taxpayer Identification Number ("TIN") or Employer Identification Number ("EIN")).

(4) Applicants with only a few entities may want to go ahead and get FCC RNs for each now, just to complete the process. The SLD indicates, however, that it expects to provide a procedure to assist applicants in obtaining multiple FCC RNs sometime before the Form 471 window opens in mid-December.

(5) Although the new Form 471 has no fields for recording FCC RNs, the SLD has indicated that it will require applicants to provide these numbers for all its entities during PIA review. Hint: To forestall a call asking for this information, an applicant can include a complete FCC RN list as a part of its Item 21 attachments.

(6) Obtaining a FCC RN is a relatively simple process. It can be done online at CORES Registration (see CORES Registration). Note that this site also allows a participant to search the FCC database to determine if it already has a FCC RN and/or to update contact information. Our analysis of over 100 public school districts indicated that just over half already had FCC RNs (as a result of FCC licenses they held for mobile radio systems or instructional television). Hint: Even if you already have a FCC RN, you may wish to get a separate one for E-rate control purposes.

(7) FCC RNs are tied to specific TINs/EINs, however, each TIN/EIN can have multiple FCC RNs. A school district, for example, will typically have only one EIN for tax reporting purposes but, as indicated above, will ultimately need multiple FCC RNs. When an applicant applies for a new FCC RN, the registration system will display a warning if there is already another FCC RN associated with that EIN. The warning can be easily bypassed.

(8) FCC RN registration requires the selection of a business type and subtype. For public schools and libraries, use "State or Local Agency" and "State or Local Commission," respectively. Most other entities, including private schools, should probably use "Private Sector" and an appropriate subtype from the pull down menu.

(9) Hint: Most of the information required to obtain a FCC RN is entity contact information. Since E-rate contacts tend to change over time, and since contact name is not a required field, we suggest that applicants leave the name field blank, but fill in the contact's position field with something like "FCC E-Rate Contact." If the FCC ever tries to reach the FCC RN contact, this would at least provide some hope of the inquiry being routed to the current E-rate contact.

(10) The FCC maintains a separate helpline for FCC RN registration. The number is 877-480-3201. If you can't get an E-rate specific answer at this number, we suggest using any of the SLD's inquiry tools including the general SLD helpline, 888-203-8100.