March 5, 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.

TIP OF THE WEEK: You must wait at least 28 days after you certify your FCC Form 470 before you can choose a service provider, sign a contract, or certify and submit your FCC Form 471. We strongly encourage you to submit your FCC Form 471 as soon as you are able to do so.

Commitments for Funding Year (FY) 2020

FY2020. USAC released FY2020 Wave 45 Funding Commitment Decision Letters (FCDLs) on March 4. As of March 5, FY2020 commitments total over $2.30 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).

Reminders on Evaluating Bids

Now that the February 25 deadline for certifying an FCC Form 470 for FY2021 has passed, applicants should be working on evaluating the bids they have received and choosing their service provider(s) if they have not already done so. Here are some thoughts to keep in mind as you are making your decisions:

Constructing an evaluation

To evaluate the bids you receive, you must construct an evaluation. Preparing a bid evaluation matrix helps you evaluate bids and also provides documentation of the process you followed to select your service provider. You decide what factors you want to consider in your evaluation and how important each factor is to you. You can use as few or as many evaluation factors as you like, and you can assign percentages or points to the factors you use to reflect their relative importance.

You must always include the price of the products and services eligible for E-Rate discounts as the primary factor, and that factor must be weighted more heavily than any other single factor in your evaluation.

For each bid, you can evaluate how well it meets each of the factors and assign a point value or percentage as appropriate. By totaling the scores for each bid, you can arrive at the most cost-effective bid.

We have updated the sample bid evaluation matrix featured on our website. Note that the factors we chose for this sample are for illustration purposes only; you need to decide what factors are important to you.

Disqualifying bids

You may have decided that you will only accept bids that meet certain requirements, and disqualify bids that do not meet those requirements. Disqualification reasons must be binary – i.e., the bidder or the bid either meets the requirement or does not meet the requirement. Bids that do not meet your requirements can be disqualified and not evaluated further.

You must have stated the reasons that you will disqualify bids in your FCC Form 470 and/or request for proposal (RFP). You cannot decide on your bid disqualification reasons later. If a bid meets the requirements you provided and cannot be disqualified based on the reasons for disqualification you included in your FCC Form 470 and/or RFP, you must evaluate it along with the other bids you have received.

Receiving one bid – or no bids

If you receive only one bid – or no bids – you can keep your competitive bidding process open and solicit bids, then review and evaluate any bids you receive as a result. Send yourself an email or write a memo to the file noting that you received only one bid or did not receive any bids in case questions come up later (e.g., during a review or an audit). Even if you receive only one bid, the bid must still be cost-effective (see below).

If you have a current service provider for your recurring services and that service provider has not submitted a bid, you can use a recent customer bill from that service provider as a bid response. You should ask for an email or other documentation from that service provider that they intend to continue to provide services to you at their current rates (or note any changes to those services or those rates) that you can retain as documentation.

Determining cost-effectiveness

Applicants certify on the FCC Form 471 that they selected the most cost-effective service offering from among the bids received, and that the selected offering was the most cost-effective means of meeting educational needs and technology goals.

• The first reference indicates a comparison between the chosen bid and the other bids received pursuant to the FCC Form 470 and/or RFP.
• The second reference indicates a comparison between the chosen bid and other offerings that could adequately meet the applicant's educational needs and technology goals.

Applicants can demonstrate cost-effectiveness through the bid evaluation matrix and other competitive bidding documentation showing 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.

However, 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 both cost-effectiveness standards. Applicants should be able to produce information and/or supporting documentation to demonstrate that the services are indeed cost-effective.

For a detailed discussion of cost-effectiveness, you can refer to the February 7, 2020 SL News Brief.

Choosing a service provider who doesn't have a SPIN

Applicants can consider bids from service providers who do not yet have a Service Provider Identification Number (SPIN). However, USAC cannot make a funding commitment decision without a valid SPIN associated with the funding request.

We understand that some service providers may be new to E-Rate, and we encourage them to certify and submit an FCC Form 498, Service Provider and Billed Entity Identification Number and General Contact Information Form, as soon as possible.

About two weeks before the application filing window closes, USAC will activate the "interim SPIN." This is a placeholder SPIN that will allow the applicant to complete an FCC Form 471 featuring a funding request for a service provider that has not yet received a SPIN. The applicant can then provide the SPIN before or during the application review process.

Document retention

As a reminder, all program participants are required to retain receipt and delivery records relating to pre-bidding, bidding, contracts, application process, invoices, provision of services, and any other documentation demonstrating compliance with program rules for a period of at least ten years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request.

You can refer to last week's SL News Brief for more information about documents to retain related to the competitive bidding process.