TIP OF THE WEEK: The first run of FY2010 Form 486 Urgent Reminder Letters was mailed earlier this week (see below). If USAC has issued you a funding commitment and services have started for one or more of your FRNs but you are not sure when your Form 486 is due, you should review the Form 486 Deadlines guidance and the Deadlines Tool on the USAC website.

Commitments for Funding Year 2010

Funding Year 2010. USAC will release FY2010 Wave 36 Funding Commitment Decision Letters (FCDLs) February 1. This wave includes commitments for approved Priority 2 requests (Internal Connections and Basic Maintenance of Internal Connections) at 81% and above and denials at 79% and below. As of January 28, FY2010 commitments total over $2.15 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

First FY2010 Form 486 Urgent Reminder Letters Issued

On January 24, USAC issued just over 2,350 Form 486 Urgent Reminder Letters for FY2010. These letters notify applicants whose Forms 486 may be late and give them an opportunity to file and certify Forms 486 without penalty.

In general, the deadline for certifying a Form 486 is:

• 120 days after the date of the FCDL or
• 120 days after the service start date reported on the Form 486, whichever is later.

USAC calculates the date to issue a Form 486 Urgent Reminder Letter based on:

• the date of the FCDL and
• the service start date reported on the associated Form 471.

Note that if you have already filed a Form 486 online but have not yet certified that form online or on paper, USAC will issue you a Form 486 Urgent Reminder Letter to remind you to certify your form.

If USAC issues you one of these letters in this first letter run for FY2010, you must certify a Form 486 featuring that FRN no later than Monday, February 14 to avoid an adjustment to your service start date and possible reduction in funding.

• Note that if your actual service start date is (or will be) later than the date you reported on the Form 471, you should refer to the Deadlines Tool on the USAC website to calculate your deadline for filing a Form 486. Keep in mind that USAC will not issue a second Form 486 Urgent Reminder Letter because the calculation for the letter is based on the service start date reported on the Form 471.

USAC will continue to issue a Form 486 Urgent Reminder Letter for each FRN that appears to have missed its Form 486 deadline, based on the FCDL date and the service start date reported on the Form 471.

If you do not certify your Form 486 by the deadline, USAC will adjust your service start date to 120 days before the date your Form 486 is received or postmarked and adjust your funding commitment as necessary to be consistent with your adjusted service start date.  

Technology Planning and Form 470

In the January 21, 2011 SL News Brief we discussed technology planning. You should review that issue of the SL News Brief and its links to USAC website guidance carefully because, beginning with FY2011, some of the technology plan requirements have changed. It is also important to keep in mind the relationship between the technology plan and the Form 470. Below are several questions that you should consider as you write your technology plan and prepare to file a Form 470.

What is the relationship between the technology plan and the Form 470?

Your technology plan, if properly done, forms the basis for the acquisition and use of the products and services featured on your Form 470. By describing your current and future needs and your goals and strategies for using technology, you can prepare reasonable funding requests and evaluate and monitor your progress toward reaching your technology goals.

The services you request on your Form 470 should follow from your goals and strategies and your current and future needs as described in your technology plan. This helps to ensure that the products and services for which E-rate provides discounts will be put to good and effective use.

How do I avoid an overly broad Form 470?

An overly broad or "encyclopedic" Form 470, instead of being tailored to your technology plan, covers a wide and unconnected range of services that may be eligible for discounts but that do not truly advance or support the specific goals and strategies articulated in that technology plan.

Instead, you should prepare a Form 470 with a level of detail appropriate to the size and complexity of your technology plan that features services that you actually plan to use. Your entries in the "Service" and "Quantity and/or Capacity" fields on the Form 470 should be consistent with both the overall goals and the specific details included in your plan.

For some examples of acceptable and unacceptable descriptions in fields on the Form 470, you can refer to the December 3, 2010 SL News Brief.

How long and how detailed should my technology plan and Form 470 be?

There is not a minimum or maximum requirement for the length or complexity of a technology plan. We suggest that you keep the following general guidelines in mind:

• A small entity will probably have a smaller, less complex technology plan than a large entity.
• An entity with limited technology needs will probably have a smaller, simpler technology plan than an entity with more complex needs.
• Your current situation may affect the detail and the degree of complexity in your technology plan and your Form 470. For example, a school with no infrastructure in place could explore a variety of technological solutions, while a school planning a buildout of an existing infrastructure might have more limited options because any new equipment would have to be compatible with existing equipment.
• Technology Plan Approvers (TPAs) can set requirements of their own for the technology plans that they approve. For example, TPAs may add requirements to ensure that the technology plan complies with the requirements of other federal or state programs. The TPAs may ask for a level of detail beyond that required by the E-rate program.

You should also make sure your technology plan is not overly narrow but could cover more that one solution to your needs. That way service providers that might not otherwise bid on your services may be encouraged to offer cost-effective solutions you may not have considered.

What effect should my needs assessment have on my Form 470?

The needs assessment element of your technology plan should address more than just the number of computers or other hardware you intend to acquire in order to make use of discounted services. For example, an old building with limited electrical capacity may not be able to support your requests for services unless you first make substantial modifications to its electrical system. If this is the case, upgrading your infrastructure may precede your request for all of the services you have included in your technology plan and your Form 470 should take this into account.

It is important that you make an accurate and complete needs assessment and begin taking the appropriate steps to secure resources in a timely manner.

How specific should I be about the scope of my project?

When completing your Form 470, you should give service providers an accurate understanding of the scope of your project. For example, if your library system has nine branches and your plan is for all of them to receive Internal Connections in FY2011, make that fact clear in your Form 470.

That does not mean, however, that you have to be overly specific in the "Quantity or Capacity" field on the Form 470. For example, if your school district is comprised of three elementary schools and one junior/senior high school and the local student population has not changed much in the last several years, you can enter "For my entire school district" in this field. Service providers who are not familiar with your area could easily get a clear idea of the scope of your project. However, if your school district is either growing or shrinking rapidly, you should make that clear as well.

The Quantity or Capacity fields on the Form 470 could therefore be short or very detailed, depending on the information you want to convey to give potential bidders a clear idea of your project’s scope.

What effects could minor or major changes to my technology plan have on my Form 470?

Some technology plans are revised or updated before they expire. Although technology plans are usually approved for three years, situations can change. For example, you may accomplish all of the goals and strategies included in your plan in the first two years of the plan. Alternatively, a reduction in funding may have prevented you from accomplishing your goals according to your original schedule.

• Minor revisions or updates are those that remain within the scope of the original version of the technology plan and any related Forms 470. USAC does not require such revisions or updates to be re-approved, but you should check with your TPA for any processing requirements.
• Major revisions or updates are those outside of the scope of the original version of the technology plan and/or the Form 470. A major revision would require the issuance of a new Form 470 because the provision of the new or expanded products and/or services is significant enough to require a new competitive bidding process. If you make a major revision or update to your technology plan, you can have the revised technology plan approved for the period of time remaining on your original technology plan or you can ask for it to be approved for up to three years as a new technology plan. Again, if you are in this situation, talk to your TPA.

As you get ready to file your Form 470, you should review any revisions or updates that you have made to your technology plan and consider any other changes that may be necessary. If you have revised or updated your technology plan, don’t just copy the Form 470 you filed last year. Think first if those revisions or updates will affect the Form 470 you file for the upcoming funding year.

Erratum

In last week's SL News Brief, the number of days to window close was erroneously reported as 69.  The correct number was 62. The archived copy of the SL News Brief on the SL News Briefs page has been corrected.
 

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