February 7, 2020

Funding Year (FY) 2020 FCC Form 471 Filing Window Countdown

The Funding Year (FY) 2020 application filing window is open. The filing window will close on Wednesday, March 25, 2020 at 11:59:59 p.m. EDT.

Note, the last day to post an FCC Form 470 for FY2020 and still be able to timely certify an FCC Form 471 is Wednesday, February 26, 2020 (see January 3 SL News Brief).

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Commitments for Funding Years 2019 and 2018

Funding Year 2019. USAC released FY2019 Wave 45 Funding Commitment Decision Letters (FCDLs) on February 6. As of February 7, FY2019 commitments total over $2.21 billion.

Funding Year 2018. USAC released FY2018 Wave 81 FCDLs on February 5. As of February 7, FY2018 commitments total over $2.31 billion.

On the date that FCDLs are issued, you can access your FCDL notification from the Notifications section of your landing page in the E-rate Productivity Center (EPC).

Documentation of Cost-Effectiveness

On the FCC Form 471, applicants make the following certification:

I certify an FCC Form 470 was posted and that any related RFP was made available for at least 28 days before considering all bids received and selecting a service provider. I certify that all bids submitted were carefully considered and the most cost-effective service offering was selected, with price being the primary factor considered, and is the most cost-effective means of meeting educational needs and technology goals.

Notice that the words "most cost-effective" appear twice. The first instance refers to a comparison between the chosen bid and the other bids received pursuant to the FCC Form 470 and/or request for proposal (RFP). The second refers to a comparison between the chosen bid and other offerings that could adequately meet the applicant's educational needs and technology goals.

In the first case, the applicant can demonstrate through the bid evaluation matrix and other competitive bidding documentation that all bids were considered (or disqualified, if disqualification reasons were included in the FCC Form 470), the bid chosen received the highest point value in the bid evaluation, and the cost of the eligible products and services was the evaluation factor weighted more heavily than any other single factor.

In the second case, the bid that the applicant chose for services and/or equipment may not appear to be cost-effective based on the information provided in the FCC Form 470 and/or RFP. In other words, other available services and/or equipment may have satisfied the needs of the applicant at a lower cost. The chosen bid should also be consistent with the overall educational needs and technology goals of the recipient(s) of service.

In either case, USAC may request additional information to show that a chosen service meets the cost-effectiveness standard. If so, applicants should be able to produce information and/or supporting documentation to demonstrate that the services are indeed cost-effective. Here are some examples of situations where additional information may be needed (this list is not exhaustive):

• Entities in remote areas. It may be physically challenging for the service provider to provide service in a particular geographic area, where the provision of services may cost more. Also, rural locations with large distances between schools may need more powerful equipment to connect all the sites represented on the application.
• High teacher-to-student ratios. To meet the educational requirements of some students – specifically, students with special needs – the school may require more equipment or more expensive equipment than might appear to be justified based on the number of students and/or teachers.
• Consolidation of equipment. The applicant may be able to demonstrate savings in maintenance costs with a larger, single piece of equipment rather than multiple smaller units, or that the total cost of multiple smaller units combined would be greater than the cost of the larger unit when both options meet the requirements specified in the FCC Form 470 and/or RFP.
• Entities acting as network hubs. If a high-capacity piece of equipment is installed in a single location that serves multiple school or library buildings, the applicant should be able to demonstrate why that larger-capacity equipment is necessary. Appropriate documentation may include maps, network diagrams, or technical information from the service provider showing the entities served.
• Installations in older buildings. Older buildings may necessitate higher installation costs and/or special equipment due to retrofitting or other considerations.
• Planned future expansions. If the applicant is planning for a possible expansion of services over several years, the FCC Form 470 and/or RFP should include information on how the current requests for services were designed to enable that expansion. The applicant should be ready to provide supporting documentation if requested, for example, growth trends in households or population where the school district or library system is located or a capital outlay plan for expansion of existing buildings or the addition of new schools or libraries.

The following situations may also require additional clarification (again, this list is not exhaustive):

• A firewall or UPS that covers a much greater capacity than the associated service or equipment requires.
• A requirement that the applicant purchase from a state master contract when the equipment available through the contract exceeds the needs of the applicant.
• The services on the funding request result in a lower net cost to the applicant when taking into account the applicant's E-rate discount level but are not the most cost-effective option available.