February 19, 2021

Funding Year (FY) 2021 FCC Form 471 Filing Window Countdown

The Funding Year (FY) 2021 application filing window is open. The application filing window will close on Thursday, March 25, 2021 at 11:59:59 p.m. EDT.

Note, the last day to post an FCC Form 470 for FY2021 and still be able to timely certify and submit an FCC Form 471 is Thursday, February 25, 2021.

TIP OF THE WEEK: The bulk upload template user guides will be available next week on the USAC website. Although we provided basic tips for completing bulk upload templates in the January 22 SL News Brief, these user guides contain detailed information for each service type and all of the fields in each template.

Commitments for Funding Year (FY) 2020

FY2020. USAC released FY2020 Wave 43 Funding Commitment Decision Letters (FCDLs) on February 18. As of February 19, FY2020 commitments total over $2.27 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).

Reminder: Next Week's February 25 Invoicing Deadline

In the April 1, 2020, COVID Order (DA 20-364), the FCC extended the deadline to submit invoices that were originally due on October 28, 2020 – which includes many FY2019 recurring service and special construction Funding Request Numbers (FRNs) – to February 25, 2021. The Order allows program participants to request a 30-day extension if more time is needed due to the pandemic.

Program participants who did not already request an extension are also eligible to request a single 120-day extension of the February 25 deadline.

You can refer to the COVID Order and the January 29 SL News Brief for more information.

Update on Invoice Deadline Changes Due to RFCDLs

On December 10, 2020, the FCC issued an Order (FCC 20-178) amending the invoice deadline rule to permit applicants and service providers up to 120 days to submit invoices after USAC issues a Revised Funding Commitment Decision Letter (RFCDL) approving a post-commitment request or granting an appeal of a previously denied or reduced funding request.

The Order became effective on Thursday, February 11, 2021, upon publication in the Federal Register.

For all RFCDLs issued on or after February 11 and approving a post-commitment request or granting an appeal of a previously denied or reduced funding request, USAC will update or create a new invoice deadline date that is 120 days after the date of the RFCDL if the existing invoice deadline is less than 120 days away.

Note that applicants and service providers appealing partially approved FRNs should submit invoices for the partial funding before the original deadline expires because USAC will not provide additional time if the appeal is denied.

The Order also provided a one-time waiver opportunity for certain program participants facing similar circumstances that were unable to timely submit an invoice because they were awaiting a post-commitment decision. Applicants or service providers in this situation who did not file a waiver request with the FCC may do so within 60 days of February 11, 2021. In their waiver request, they must demonstrate that they were unable to timely invoice due to a delay in the processing of a post-commitment change or resolution of a successful appeal decision for FY2014 or later and they must also provide good cause for not filing a timely waiver request with the FCC.

FCC Form 470 Reminders

Applicants begin the process of applying for discounts on eligible services by completing and certifying an FCC Form 470 (Description of Services Requested and Certification Form) in EPC. This opens the competitive bidding process, which is a formal process to identify and request the products and services needed so that potential service providers can review those requests and submit bids for them.

February 25, 2021, is the last day that you can submit and certify your FY2021 FCC Form 470 and still wait the required 28 days before timely filing your FY2021 FCC Form 471 before the application filing window closes on March 25, 2021, at 11:59 p.m. EDT.

Below are some reminders to help you meet the February 25, 2021 deadline.

It is the responsibility of the applicant to run an open and fair competitive bidding process.

• All bidders must be treated the same. No bidder can have advance knowledge of the project information, there are no secrets in the process – such as information shared with one bidder but not with others, and all bidders know what is required of them.
• With limited exceptions, service providers and potential service providers cannot give gifts to applicants.
• The value of free services (e.g., price reductions, promotional offers, free products) generally must be deducted from the pre-discount cost of services.

Describe the services you need accurately and completely on the FCC Form 470.

You can use the narrative field in each of your service requests to clearly describe the size and scope of your project and/or the services you are requesting. If you need more space or your requests are large and/or complex, you can issue an RFP or similar document (see below) so that you can describe your project in sufficient detail.

Provide specific information to help service providers submit responsive bids. For example, rather than requesting a "district-wide" internet access service, provide a list of all the individual schools in your district and their needs based on the size of their student bodies, locations, and so on.

You cannot specify make and model numbers from a specific manufacturer in an FCC Form 470 and/or an RFP without adding the words "or equivalent." The drop-down options in the FCC Form 470 already contain this language.

• If you provide a specific manufacturer's name in the narrative field or in an RFP or RFP document, it must be to indicate compatibility ("compatible with our existing Brand X equipment") or equivalency ("Brand X or equivalent").
• If you are requesting basic maintenance or managed internal broadband services, you can specify makes and models of the equipment to be maintained if you already have the equipment. However, if you are also requesting the equipment on your FCC Form 470, be sure to make that clear on your form.

Provide your best estimate of the number of items you are seeking in the "Quantity" field. Bidders are free to propose a higher or lower number in their bids based on their assessment of your needs, and you will not be held to the number you enter as an upper limit when you file your FCC Form 471 if the bids are clearly responding to your needs as you have described them in the narrative and your RFP or RFP document(s).

Be sure to post for all services you are requesting under the correct service type.

If you are not sure which service type your services fall under, post your services under both applicable service types and put a note in the narrative in each FCC Form 470 service request that explains why you have posted for both service types.

The four service types are:

• Data transmission and/or internet access (Category One)
• Internal connections (Category Two)
• Basic maintenance of internal connections (Category Two)
• Managed internal broadband services (Category Two) 

All Requests for Proposal (RFPs) and RFP documents must be attached to the FCC Form 470.

You can issue an RFP or similar document in addition to the FCC Form 470. We use "RFP" or "RFP document" generically to refer to any document you issue as part of the competitive bidding process that describes your project and requested services in more detail than in the fields provided on the FCC Form 470.

Generally, you are not required to issue an RFP unless your state or local procurement rules or regulations require you to do so, although RFPs are required for certain Category One services. All RFPs and RFP documents must be uploaded to your FCC Form 470 in EPC.

Respond promptly to questions from potential bidders.

Applicants – and consultants that act on behalf of applicants – should respond to inquiries from potential bidders in a timely manner so that competitive bidding deadlines can be met.

• You can post questions received from potential bidders along with your answers on a website or in RFP documents attached to your certified FCC Form 470.
• Service providers should also respond to posted FCC Forms 470 and RFPs with specific requests for additional information necessary to prepare responsive bids. Generic emails that do not pose questions related to applicant service descriptions do not require a response from the applicant.

Service providers: Review FCC Forms 470 and RFP documents in order to submit responsive bids.

First, review the FCC Forms 470 you are interested in – especially the narrative sections and any attachments (RFP documents). Applicants who have specific requirements on preparing and submitting bids should have provided that information. You can also contact the contact person or the technical contact person identified on the form for additional information.

FCC Form 470 data is updated immediately in EPC and updated overnight on the USAC website. The narrative section in the form and the attached RFP documents contain valuable information.

To access FCC Forms 470 in EPC:

• From the Actions tab in EPC, choose Search and Export Certified FCC Forms 470.
• Choose the search criteria you want and then click Continue.
• Click the form number of an individual form to view that form, or click the Export Search Results button to download summary information on your search results.

To view an individual FCC Form 470 and its RFP documents on the USAC website:

• From the FCC Form 470 Tools section of the Tools page, choose View an FCC Form 470 (FY2016 and later).
• Choose your search criteria and then click the Search button. Note: If you choose to export your data to HTML, scroll down the search page to locate your search results.
• Click the form number to view an individual form or the RFP document name to view an RFP document.

To download summary information from FCC Forms 470 from the USAC website:

• From the FCC Form 470 Tools section of the Tools page, choose Download 470 Information (FY2016 and later).
• Choose your search criteria and then click the Search button. You can choose to export your data to file formats HTML, XLS, or CSV.