Guidance 100% of the schools who call seek guidance on Erate rules. The FCC’s new five-year budget appropriation for the Erate program in 2015 significantly changed the program and 2019-2020 is the last year of that five-year appropriation. The FCC will have a new appropriation for 2020-2021.
What funding is available? How do I get it? The first thing we do when a new client calls is to do a full analysis of their Erate history. This allows us to provide you with information specific to your school/ school district. If you are new to the program, we will work with you and explain the program. We will review the program eligibility, potential discount, and the application process.
Businessmap will set up or modify the school’s Erate Productivity Center (EPC) account. It is critical that the EPC be current and accurate.
We work with our clients and help them understand the complexity of the Erate rules. A few of which include:
• No statute of limitations
28 days minimum --Competitive Bidding Process
Competitive bidding is the foundation of the program and often the most problematic. Given the complexity of the process, we are providing a link to the Universal Services Administrative Organization’s (USAC) website.
Form 471: can be filed on the 29th day following the date of the Form 471 At the time the Form 471 is ready to be filed, vendors are selected. If a service requires a contract, it must be submitted and signed prior to the Form 471 submission.
What’s next? When do we get the award? After the Form 471 applications are submitted to USAC through EPC, USAC reviewers will review each application for compliance.Program Integrity Assurance (PIA) reviewers at USAC check the information on your form for completeness and accuracy and may have additional questions for you to answer. Awards often begin in the late spring but can vary during each funding year.
How do we get the funds? There are two methods for disbursements.
If a school chooses the Service Provider Method (SPI) Erate funds are paid directly to the service provider who was approved for the service on the Form 471. The school will pay the percentage of which they are required,and the serviced provider will bill USAC the remainder. If the school chooses the Billed Entity Applicant Reimbursement (BEAR)method, the school pays the bills upfront and seeks reimbursement from USAC. This process is an ongoing process during the Funding Year and often doesn’t finish for months after the end of the Funding Year.
If USAC denies an application, the school has the opportunity to appeal the decision to USAC and to the FCC. The appeals that we have filed to both USAC and the FCC on behalf of our clients have been very successful.
Payment Quality Audit (PQA)
USAC is acting under the direction of the FCC’s Improper Payments Information Act of 2002. The purpose is to providethe FCC with information about improper payments to program beneficiaries.
The Beneficiary and Contributor Audit Program (BCAP)
USAC is committed to collecting universal service contributions and disbursing payments to program beneficiaries that are accurate, properly documented, and in compliance with rules established by the (FCC).The audit program is designed to measure rates of program compliance among universal service beneficiaries and contributors.
For the 2019-2020 fiscal year, the process will start in November 2018. The application process goes from November through March. Following the application process is the Program Integrity Assurance reviews. During this review we will address questions of the reviewer substantiating the needs for the funds. Once the review is completed, USAC provides the award letter. The letter indicates that federal funds have been appropriated for this application. Depending upon who the school opts to receive their award the will either receive the money directly or receive a bill credit. For more information about disbursements, contact us. We have worked with many vendors for years and are familiar with their individual E-Rate processes. Since each vendor has a different way of processing these funds, having those relationships in place has been critical. If awards are made after July 1 of the fiscal year, as is usually the case, awards are retroactive to July 1. Most awards are made from May through November of the fiscal year.
Businessmap has an in-depth data process. A thorough analysis is completed on the school(s) before a meeting with the District Contact. This information provides a history that can be used as input into the next year. This analysis speeds up the application process and provides a mechanism for communication.
A critical component of a successful program is the school’s finance liaison. To ensure correct and adequate funding, we work with the business manager (or an individual who serves in this capacity) to ensure we have the bills to substantiate funding and other tasks that arise.
A 470, which is actually a Request for Proposal, can be filed anytime during the year according to FCC rules. The 470 for the school is submitted as soon as the district defines the school needs, usually when the National School Lunch Program statistics are available. If there is a need for a contract change during the school year, a 470 is submitted at that time to fulfill the competitive bidding requirements. If the district develops a Request for Proposal, we will support the district in the development of that document.
All records are retained for ten years as required by USAC. During the competitive bidding phase vendor communications are kept in the form that they are received. Vendor documents that do not include specific information to the district are not considered as competitive bids. We will provide a file with all vendor and client communication.
After the 28 day waiting period from the 470 submittal date, the final application (471) can be submitted. Businessmap follows the direction provided by the District Contact. We ensure compliance and completeness.
Businessmap addresses all PIA requests in a timely manner. The goal is to reply within 72 hours. There may be situations where it may take longer to gather the information. If information is needed from a vendor, the PIA request is sent to the vendor within 24 hours of receiving the review request. The goal is to have the 471 and the attachments complete to the degree where there are zero questions!
We monitor the USAC website closely and will contact the reviewer every three or four days if the application status is sitting in the Await Applicant Documentation or any other status except Final Review and Awaiting Quality Assurance.
This form is completed within 48 hours of the electronic indicator that the FCDL has been issued. We do not wait for the paper copy. We are also very careful to ensure that the service has started. If it is a new service we will work with the Point of Contact to obtain that information.
We have one individual dedicated to the disbursement process. Almost every vendor has their own vendor reimbursement process. Many of the vendors now have a process that starts soon after the 471 window closes. They assume that the school will get funded and have the information ready to submit when the award is made. This is great progress because it allows reimbursements to start quickly. In previous years, reimbursements can’t be expected for 90 plus days. We work closely with the vendor Erate coordinator. Currently we work with over 40 vendors.
There are many activities that can occur during the disbursement phase. USAC frequently does random audit of vendor invoices which we will handle. Another form of audit is more prevalent as of last year and it is the Payment Quality Audit. USAC requires the school to show evidence of receiving a payment for which the vendor has invoiced USAC. Work on audits is billed as time and material.