February 27, 2014 

FY2014 FUNDING DECISIONS – HELP US HELP YOU

1. Filing Review-Ready Applications

March 26, the close of the FY2014 application filing window, is fast approaching. While applicants are working to finish all of the activities to get their applications in the door by this deadline, USAC is also hard at work. In fact, we start reviewing applications before the window closes.

However, for us to start the review of an application, it must be review-ready. By that we mean that the FCC Form 471 is certified, all FCC Forms 470 cited on Block 5 funding requests are certified, and all Item 21 attachments have been submitted. You can help us get your decisions out much more quickly if you make sure that the information you have provided on each form is correct and complete, you have met the program deadlines, and all of your documentation is in order.

Applications that are not review-ready cause significant delays.

How can you help speed the review of your application?

• Gather the documents you will need. To complete your application, you may need copies of contracts, National School Lunch Program information, approval letters from certified technology plan approvers, and so on. Don't just keep your documents long enough to complete your forms – you may also need them during our review of your application so remember to RETAIN those documents.
• Fill in the details.
  • Do you have a new entity? Then Submit a Question or call the Client Service Bureau now to get an entity number.
  • Does your service provider have multiple Service Provider Identification Numbers (SPINs)? Then contact your service provider now to ascertain which SPIN to enter on your FRN.
  • Do you need an FCC Registration Number (FCC RN)? You must have this number if you are the Billed Entity featured in Block 1 of FCC Form 471. If you don't have one, go to the CORES section of the FCC website now to obtain one.
• File early. If you wait until the last minute to file, you are more likely to be in a hurry and make mistakes which will take time later to correct, or may affect your funding. Also, because we can start reviewing applications even before the window closes, applications filed in the last week of the window – when many other applicants file – are much farther back in line for review.
• File online. The online system notifies you of inconsistent or missing data, so that you can provide correct and complete information on your application the first time.
• File your Item 21 attachment(s) online. Some information – such as category of service and amount of funding requested – are pre-populated from the online FCC Form 471. The system also notifies you if certain data are missing.
• Ask for assistance. If you have questions, please contact our Client Service Bureau earlier rather than later. In addition to program information, they can provide information on the status of your forms.
  • Call us toll-free at 1-888-203-8100
  • Submit a Question by email
  • Fax us toll-free at 1-888-276-8736

2. Filing Item 21 Attachments

The Item 21 attachment is a required part of each FCC Form 471 Block 5 funding request. It contains a detailed description of the products and services you are requesting. When you file an FCC Form 471, the online system assigns a Funding Request Number (FRN) to each funding request. You provide an attachment number in Item 21 of each Block 5 funding request that will correspond with your Item 21 attachment, and then you submit that Item 21 attachment separately from the application.

You may choose to number your attachments #1, #2, etc. or use a descriptive name for each. Regardless of the method you choose, be sure to identify each Item 21 attachment with the number or name you indicated in its associated Block 5 funding request.

NOTE: You must provide an Item 21 attachment for EACH FRN on your FCC Form 471.

We can only start to review your application when it is certified and includes all of the associated Item 21 attachments. Below are the number of FRNs for which Item 21 attachments were successfully filed at specific points in time during the last two filing windows:

Following are some specific tips for Item 21 attachments for each of the four categories of service – Telecommunications Services, Internet Access, Internal Connections, and Basic Maintenance of Internal Connections. If you include the information suggested in the tips, your PIA reviewer will be able to more easily make determinations of the eligibility of the components of each of your funding requests.

- Telecommunications Services

Provide the specific type(s) of service requested. For example, instead of "Telecommunications" or "Telephone service," state "Local and long distance service." If the specific type of service is not identified, PIA is required to ask for this information.

Provide the number of lines, including the number of extensions. Many entities have a single billed telephone number with several lines or extensions associated with the main billing line. Be sure to include those lines and extensions in your line count. For example, if your school or library has a main line and 12 extensions, enter "13" for the number of lines.

For digital transmission services, provide the bandwidth. While some services have a set bandwidth – e.g. a T-1 circuit is 1.544 Mbps – the bandwidth of other services such as wireless or fiber service is variable. If you are not sure of the speed of your service, check your bill, review your contract (if applicable), or ask your service provider. This information is very important for data collection purposes; as above, PIA must ask you for this information if it is not listed in your Item 21 attachment.

If you include a copy of your bill as all or part of your Item 21 attachment:

• Pick a bill that represents your typical monthly costs. One month is generally sufficient. Don't send bills for all 12 months of service for the previous year.
• Make sure the dollar amount of the bill is typical of your monthly costs and supports your request. A monthly bill for $100 will not, alone, support an FRN requesting $150 per month. Also, a bill for a month when school is not in session may not accurately reflect your typical monthly costs. If you expect your expenses for an FRN for the new funding year to be greater than that reflected on the bill you include from the current year, you need to explain and justify why the amount you are budgeting is a reasonable estimate for the new funding year.
• Include the page or pages from your bill that detail any miscellaneous charges and/or credits. Your reviewer must be able to identify those costs to determine their eligibility.
• Identify any ineligible charges. You can submit a bill with ineligible charges – just make sure you clearly identify them. If they are not identified, the PIA reviewer will have to ask you additional questions.

- Internet Access

For digital transmission circuits for basic conduit access to the Internet, provide the bandwidth of the services you are requesting. As above, if you are requesting more than one circuit, include the number of circuits.

If you are requesting web hosting services, ask your service provider for a cost allocation and provide it as part of your attachment.

• Clearly identify the total cost of the service as well as the percentage of the total cost for which you are seeking funding. For example, if a web hosting company's service is 75% eligible and the service costs $100 per month, state that you are seeking discounts on $75 of the $100 per month and not requesting discounts on the ineligible 25%. By identifying the eligible and ineligible portions beforehand, you will reduce questions from PIA and ensure that you have budgeted for the cost of your share of the service.

- Internal Connections

For all Internal Connections requests, provide the make and model number and the quantity of any equipment included in your funding request. PIA will ask for this information if it is not already included.

For bundled products, in addition to the make and model numbers, provide the SKU. The SKU, or stock-keeping unit, is a unique identifying number assigned by a company to each of its products and/or services. Bundled products often contain ineligible components or features, and USAC works with many service providers to ensure that cost allocations appropriately reflect eligible and ineligible components of bundled service. If you provide the SKU, USAC can more easily identify and apply the correct cost allocation.

If equipment can be used in both eligible and ineligible ways, clearly describe how you are using the equipment. For example, a server can be eligible if used for email but not eligible if used for caching. If you are requesting a web server or terminal server, be sure to state the specific functions it will be performing and provide a cost allocation if some of the functions are ineligible.

If you are requesting discounts on equipment such as cabinets, racks, and UPSs, identify the equipment they are supporting. These types of equipment are eligible only in proportion to the eligibility of the equipment they serve or house. Although you may be ordering these types of equipment along with fully eligible internal connections equipment, PIA cannot assume that only those eligible items will be housed on the accompanying cabinet or rack or supported by the UPS.

• If only eligible equipment will be supported or housed, you should state that and provide the make and model numbers of the eligible equipment.
• If both eligible and ineligible equipment will be supported or housed, you should provide that information together with an appropriate cost allocation.

- Basic Maintenance of Internal Connections

Provide a list of all of the equipment being supported by the basic maintenance. This list should include the make, model number, quantity, and location of the equipment being supported.

State the basic maintenance tasks that will be performed and the costs associated with those tasks. As a reminder, services such as software upgrades and patches – including bug fixes and security patches – and online and telephone-based technical assistance and tools may be invoiced as a one-time charge. Other basic maintenance tasks, such as those performed on a time and material basis, can be funded; however, USAC will only process invoices for actual work performed or for hours of labor actually used.

If your basic maintenance contract includes both eligible and ineligible equipment, be sure you indicate what portion of the price reflects the price for maintenance of the ineligible equipment. Examples of ineligible equipment include desktop computers and telephones.

Non-online submissions

If you are submitting your Item 21 attachments by email, fax, or on paper, follow these tips:

• Clearly label your submission and double-check your entries. Provide summary information – the FCC Form 471 application number, the FRN(s), and your contact information – on the first page of your submission. This means the subject line or body of an email, the cover page of a fax, or the summary page of a paper submission. If you have more than one page, identify each page with the appropriate application number and FRN. Remember that if we don't have complete identifying information, you will get an Item 21 Urgent Reminder Letter.
• Submit by FCC Form 471 application number, not by FRN. We store non-online submissions by application number, so submitting by FRN causes additional handling and processing time. Also, it will be easier for us to verify that your submission has been received and processed. Again, double-check your work so that we correctly enter and store your information.
• File early. As the volume of submissions increases, it will take longer for us to complete data entry of your identifying information and store your submission.

Service provider assistance

It is entirely appropriate to involve your service provider in the process of creating your Item 21 attachment. Your service provider may have specific details that USAC needs or be able to easily provide network diagrams, SKUs, or other information not readily available to you.

After you submit your Item 21 attachment to USAC, share a copy with your service provider. If you file online, you can remind your service provider that he or she can access your submission through the E-File System. With this information, your service provider can better understand exactly what you are requesting, and this information will be invaluable during the application review and invoicing processes.

For more information

For detailed information and examples – including information on submission options – refer to the Item 21 Attachments guidance document on the USAC website.