E-Rate FAQs - Application Process

Where can I find an overview of the E-Rate application process?
What staff person(s) within my organization should be responsible for applying for E-Rate?
What are the start and end dates for the E-Rate funding year?
When should applications or forms for a funding year for E-Rate be submitted?
How often must I apply for E-Rate?
Where do I get the forms to apply for E-Rate?
Will participation in E-Rate require Head Start grantees to conduct a separate verification of income for parents?
What is a Letter of Agency?
Are Head Start Grantees required to coordinate E-Rate requests through their State Education Departments?
What is an entity number?
How do I obtain entity numbers for my organization?
How do I know if my organization is a school, school district or consortium?
How many entity numbers does my Head Start program need?
Do I need an entity number for each Head Start Center?
Do I need entity numbers for centers or classrooms located on a public school campus?
What is a billed entity number (BEN)?
What is Form 470?
What are eligible services and what is the eligible services list?
How many Form 470s should be submitted?
What is an RNL? What is a “Notification of Form 470 posted”?
What is Form 471?
How many Form 471s should be filed?
What is a RAL?
What is PIA?
What are Selected Reviews?
What is the FCDL?
What is an NCES Number or Code?
Is my organization guaranteed reimbursement or discounts?
What records must I retain when applying for E-Rate and how long must I maintain them?
Will my application or records be audited?
Who will audit records?
Where can I find help to complete forms, technology plans and provide assistance with E-Rate?

Q: Where can I find an overview of the E-Rate application process?

A: The E-Rate Application Process Flow Chart provides Head Start staff with a brief overview of the E-Rate application process. Contact Head Start Knowledge and Information Management Services at 1-866-763-6481 if you need assistance.

Q: What staff person(s) within my organization should be responsible for applying for E-Rate?

A: The person ultimately responsible is the person authorized to sign or certify the forms submitted to USAC/ SLD however E-Rate impacts several systems within Head Start. Think in terms of a team being responsible for E-Rate. The team includes the stakeholders within your organization who provide input into the Technology Plan (HR, Fiscal, IT, Leadership etc.). A consultant can be hired to submit forms on your behalf; however, USAC/SLD requires a letter of agency.

The authorized person on the Form 471 - the person whose signature appears in the Form 471 Item 38 - certifies that he or she is the person authorized to submit and certify to the accuracy of the application. This person must be authorized to represent any and all of the entities for which discounts are sought in the funding requests featured on the application. During its review of the Form 471, the SLD may require copies of the documentation that confirms this person's authorization to represent all of the entities featured on the Form 471.

The evidence that establishes this authorization - and therefore, that establishes the relationship between the authorized person and the entities featured on the form - is generally a Letter of Agency (LOA).

Q: What are the start and end dates for the E-Rate funding year?

A: The funding year begins July 1 and ends June 30 however there are exceptions to the end of the funding year.

Q: When should applications or forms for a funding year for E-Rate be submitted?

A: Applications are filed each year. Now is the time to learn, train, prepare, and begin work for 2008-2009.

Form 470 (Services Requested) (Oct-Jan) Form 470 must be filed at least 28 days prior to filing Form 471. The last date to file Form 470 for the 2007-2008 year was January 10, 2007.
Form 471 (Services Ordered) (Nov-Feb) Each year a filing window for Form 471 generally begins mid November and continues through the first week in February prior to the start of a funding year. For funding year July 1, 2007 to June 30, 2008 the window for Form 471 was November 14, 2006 through February 8, 2007.
Form 486 (Services Confirmed) (July – June once services begin) Form 486 is filed once services begin usually in July. The Form 486 must be postmarked no later than:
120 days after the Service Start Date featured on the Form 486, or
120 days after the date of the Funding Commitment Decision Letter, whichever is later.
Forms 472/474 (Billed Entity Reimbursement/Service Provider Invoice) (July – June once services are received) Form 472 should be filed after services are received. Form 474 is an Invoice, submitted to USAC for the services you have received.

Q: How often must I apply for E-Rate?

A: Applicants must apply each year. The process requires applicants to file more than one form. The forms are filed over a period of more than a year. Applicants must also respond to letters and other correspondence from the SLD and their service providers.

Q: Where do I get the forms to apply for E-Rate?

A: It is recommended you apply on-line. Applicants can use the USAC web site to file required forms, certify forms, and check application status.

Paper copies of all the required forms may be downloaded from the USAC web site.

Q: Will participation in E-Rate require Head Start grantees to conduct a separate verification of income for parents?

A: No. Additional income verification is not required. Head Start Grantees are required to perform income verification prior to the child being selected for Head Start. The Head Start Performance Standards require at least 90% of enrolled children be at or below poverty guidelines. The income verification Head Start Grantees conduct meets or exceeds the verification required for the National School Lunch Program (NSLP). Head Start Grantees may automatically enroll children in the NSLP based on the income verification conducted prior to enrollment. See ACYF-IM-HS-95-29 concerning Head Start’s automatic enrollment in the free lunch program.

Q: What is a Letter of Agency?

A: The authorized person on the Form 471 - the person whose signature appears in the Form 471 Item 38 - certifies that he or she is the person authorized to submit and certify to the accuracy of the application. This person must be authorized to represent any and all of the entities for which discounts are sought in the funding requests featured on the application. During its review of the Form 471, the SLD may require copies of the documentation that confirms this person's authorization to represent all of the entities featured on the Form 471.

The evidence that establishes this authorization - and therefore, that establishes the relationship between the authorized person and the entities featured on the form - is generally a Letter of Agency (LOA).

Q: Are Head Start Grantees required to coordinate E-Rate requests through their State Education Departments?

A: Head Start programs are not required to coordinate with State Education Departments prior to submitting applications for E-Rate. Some State Education Departments have active E-Rate Coordinators for public schools. These are usually state employees while other states have contracted with consultants to perform E-Rate Coordinator functions for public schools. State law or contractual agreements may prohibit these persons from working with Head Start or schools which do not fall under the jurisdiction of the State Education Department.

Q: What is an entity number?

A: An entity number is an identification number assigned by USAC/SLD for each address where services are received. Head Start grantees who have not participated in E-Rate in previous years need to request an entity number from USAC/SLD.

Q: How do I obtain entity numbers for my organization?

A: To obtain an entity number contact the Schools and Libraries Program at Universal Service Administrative Company Schools and Libraries Program
P.O. Box 7026
Lawrence, KS 66044-7026
Toll-Free: (888) 203-8100
Fax Toll-Free: (888) 276-8736
Via E-Mail Web site: http://www.universalservice.org/sl
How you setup your entity numbers will impact your entire application. Before you request entity numbers get prepared. Know the type of applicant you are: (school, school district, consortium, or library). Contact Head Start Knowledge and Information Management Services at 1-866-763-6481 if you need assistance. Be prepared to provide your legal name, type of agency, E-Rate point of contact, telephone numbers, addresses and contact information for each location/entity.

Q: How do I know if my organization is a school, school district or consortium?

A: Head Start Grantees providing one center and no other services should apply as a school. Head Start Grantees providing several centers, with separate administrative offices processing the telephone and internet bills for all the centers should apply as a school district. Head Start Grantees who have more than one administrative office processing telephone and internet bills should apply as a consortium.

Please contact USAC before you file Form 470 to insure your filing status (school, school district, and consortium) is correct.

Q: How many entity numbers does my Head Start program need?

A: Entity numbers are assigned for each address where services are received. Each center and Administrative Office where eligible services are received must have an entity number.

Q: Do I need an entity number for each Head Start Center?

A: Entity numbers are assigned for each address where services are received. Each center and Administrative Office where eligible services are received must have an entity number.

Q: Do I need entity numbers for centers or classrooms located on a public school campus?

A: You must have your own entity number for each location where you plan to receive services. If your agency pays the bills for the Pre-K class located within the public school you will need an entity number for the classroom/center, even if the public school has an entity number. Grantees with Pre-K classrooms in public schools should coordinate E-Rate requests and consider partnering with the school. Since the reimbursement rate for Public Schools is usually much less than Head Start (90%), the school may prefer to pay for services to the classroom and include your Head Start children in with their request, to improve their level of reimbursement.

Q: What is a billed entity number (BEN)

A: The BEN is the same as an entity number. An entity number is an identification number assigned by USAC/SLD for each address where services are received. The billed entity number is the entity number assigned to the entity that pays the bills. Typically it is the entity number assigned to the Head Start administrative office. Most Head Start Grantees have one location that processes the bills (Administrative Office) for several other locations (Head Start Centers). Each location will have an entity number. The term used to describe the entity number assigned to the location where the bills are processed and paid is called the BEN.

Q: What is Form 470?

A: Form 470 is a Description of Services Requested and Certification. The form serves the same purpose as a publicly posted request for proposal (RFP). The Form is the first form to be submitted to USAC/SLD and must be posted for at least 28 days prior to submitting Form 471. The form describes the service(s) a Head Start Grantee applicant is seeking. Posting the Form 470 is the way telephone service providers and internet service providers find out you are interested in their services and E-Rate reimbursement. Form 470 is normally submitted between October to early January, and aligns with the Form 471 filing window (November – early February).

Form 470 allows applicants to describe requested services from the Eligible Services List such as telecommunications, internet access, internal connections, basic maintenance of internal connections, and miscellaneous services.

Q: What are eligible services and what is the eligible services list?

A: Only certain products and services, used in certain ways, are eligible for Schools and Libraries Program support. Eligibility is based on criteria established by statute and Federal Communications Commission (FCC) rules. The FCC publishes an Eligible Services List each year. The following is an overview of product and service eligibility and includes references to other documents that provide additional details. Product and service eligibility highlights include:

How a product or service is used can affect whether or not the product or service is eligible.
Each of four separate categories of service (telecommunications, Internet access, internal connections, and basic maintenance of internal connections) has its own rules for eligibility.
Details about funding priorities, competitive bidding, and internal connections eligibility should be understood by applicants.

The Eligible Services List contains further information to guide applicants and service providers.

The Conditional Nature of Eligibility
Eligibility for support requires not only that the product or service is eligible, but that it is put to an eligible use and that it is used by an eligible school or library entity at an eligible location.

The Eligible Services List is one of the key documents that indicate the products and services that can receive funding and the acceptable uses for those products and services. For example, the Eligible Services List indicates that some types of software - such as software for a network operating system - can be eligible for support, while other software - such as application software for word processing - is not eligible. Another example on the Eligible Services List indicates that cable for connecting classrooms to a network can be eligible, but cable for electrical wiring is not eligible.

An entry on the Eligible Services List indicates whether a product or service is eligible and under what conditions that product or service is eligible.

Q: How many Form 470s should be submitted?

A: You may submit as many Form 470s as needed to describe the services requested. USAC/SLD recommends separating Priority 1 and Priority 2 services. Head Start Grantees should separating requests for services on more than one Form 470

if the Grantee serves children at multiple locations
if requested services will include multiple service providers
to avoid mixing Priority 1 and Priority 2 services.

Many Head Start Centers have few phone lines in each center. Combining all Plain Old Telephone Services (POTS) on one Form 470 could make your request for services more lucrative for potential bidders/service providers.

Q: What is an RNL? What is a “Notification of Form 470 posted”?

A: A Form 470 Receipt Notification Letter (RNL), also described as a “Notification of Form 470 posted letter”, is mailed to the E-Rate applicant by the SLD once a Form 470 has been posted. The letter and attached report provides a way for applicants to make certain corrections to a Form 470 for allowable fields. If corrections cannot be made and time permits, the applicant may post another Form 470 to request services. The letter is normally received by E-Rate applicants within one week after posting the Form 470. Applicants should immediately check the letter and attached report for accuracy and clerical errors. A sample RNL is available on the USAC web site.

Q: What is Form 471?

A: Form 471 is a Description of Services Ordered and Certification and is the second form to be submitted to USAC/SLD. Form 471 is completed after Form 470 has been posted for at least 28 days. Form 471 is used to notify SLD that you have selected a service provider and ordered services. The form and its attachments provide the details of the service(s) a Head Start Grantee applicant has ordered, the anticipated dollars budgeted and all costs associated with E-Rate including but not limited to eligible costs, ineligible costs and pre-discount costs. It describes in detail the number of children served, the number of children participating in the National School Lunch Program (NSLP) and the location of each participating entity.

The Form 471 filing window is normally mid-November – early February. Once a Form 471 has been received by the SLD a Receipt Acknowledgement Letter (RAL) is mailed to the applicant from the SLD.

Q: How many Form 471s should be filed?

A: Applicants requesting Priority 1 and 2 funding should complete at least two Form 471s. USAC/SLD recommends applicants avoid mixing Priority 1 and 2 services on the same form because funding will be held until Priority 2 money has been released. It is best to file as many Form 471s as is necessary to ensure the description of services ordered is easily understood.

Q: What is a RAL?

A: When a Form 471 has been received by the SLD a Receipt Acknowledgement Letter (RAL) and report is mailed to the applicant from the SLD. The RAL to Form 471 is similar to the RNL for Form 470 in that it provides applicants the opportunity to make corrections if they respond quickly. Applicants should check the letter for accuracy and clerical errors. A copy of the RAL is sent to the applicant’s service providers. If errors are found applicants should immediately annotate corrections on the report and submit the corrections to the SLD. A sample RAL is available on the USAC web site.

Q: What is PIA?

A: USAC reviews all Services Ordered and Certification Forms (Forms 471) to verify the accuracy of discount percentages and ensure that support is committed only for eligible products and services. This review program is intrinsic to the application process and is called PIA (Program Integrity Assurance). USAC is committed to issuing timely Funding Commitment Decision Letters (FCDL) but its ability to meet that goal depends on efficient processing of application reviews.
Applicants can help speed up application reviews by:

Submitting a complete Form 471 including required certifications and Item 21 Attachments for each funding request
Responding to requests for additional or clarifying information within seven days and
Verifying that USAC has correct contact information.

Q: What are Selective Reviews?

A: USAC selects some applicants for a Selective Review to ensure that they are following certain FCC program rules. Applicants are asked to provide the following information covering all of the billed entity's Forms 471 for the funding year:

Documentation regarding their competitive bidding and vendor selection process
Documentation of their ability to pay their share of the cost of the products and services eligible for schools and libraries program support and
Proof that they have obtained the (ineligible) hardware, software, professional development, electrical capacity or other retrofitting, and maintenance necessary to make effective use of the requested discounts.

View a sample Selective Review Information Request. Service providers may not provide responses to Selective Review Information Requests. The result of a Selective Review may be that funding is approved or denied.

The applicant may also receive a Resource Deficiency Advisory that advises applicants of insufficient resources to use the services requested correctly. The letter explains the areas USAC finds to be deficient. Applicants receiving this letter are not denied funding but should consider increasing their level of investment in identified areas since USAC may follow up in subsequent years regarding the necessary resources. Applicants may not receive direct or indirect help from service providers to pay their non-discounted share.

Q: What is the FCDL?

A: The FCDL is the Funding Commitment Decision Letter. Once a Form 471 has completed PIA, a FCDL and report is sent to the applicant from USAC/SLD. The FCDL features the funding status for each of the applicant’s request on Form 471. The FCDL lists the amount of funding approved, the amount not yet funded, and the amount of funding denied.

Applicants continue to be subject to audit and other reviews that USAC or the FCC and others may undertake.

The FCDL report describes the details of the funding request(s). Once the FCDL is received the applicant may appeal. Appeals must be post marked or received by the SLD within 60 days of the date on the FCDL. A sample FCDL is available on the USAC web site.

Q: What is an NCES Number or Code?

A: The NCES Code is entered into Block 4, Column 2 of Form 471. Many Head Start not associated with a traditional public school do not have an NCES Code and should place zeros in block 4, column 2. The National Center for Education Statistics (NCES), located within the U.S. Department of Education and the Institute of Education Sciences, is the primary federal entity for collecting and analyzing data related to education. The NCES method for identifying schools within each state includes assigning each school an “NCES Code”. Many Head Start Grantees and non-traditional public schools may not have an NCES Number or Code. It is not something a school requests from NCES. The number is assigned when schools within a geographic area are surveyed. Surveys occur approximately every two years. USAC/SLD recommends leaving the NCES Code blank for Head Start Grantees not having an NCES code or enter zero. Head Start Grantees who are also public school districts should have a code.

Q: Is my organization guaranteed reimbursement or discounts?

A: No. Funds are not obligated merely because of an application. A Funding Decision Commitment Letter (FDCL) will be sent by USAC/SLD which specifies the amount of money a Head Start program may anticipate saving should the Head Start Grantee fulfill its obligations and meet deadlines.

Q: What records must I retain when applying for E-Rate and how long must I maintain them?

A: Documentation for E-Rate must be maintained for 5 years from the last date services where received. A Head Start Grantee making application for the 2007-2008 funding year should retain records until June 2013. Most documents, methods, procedures, quotes and bids, including responses to the Form 470 which were rejected must be maintained. Technology Plan(s) and copies of the Forms, attachments and letters submitted and received from the SLD and service providers also should be maintained. A documentation checklist is available on the USAC web site.

Q: Will my application or records be audited?

A: Oversight of the Schools and Libraries Program has increased because of complaints the FCC Office of Inspector General (OIG) has received alleging improprieties within the program. The alleged improprieties include the submission of false claims, failure to comply with appropriate procurement regulations and laws, conflict of interest, forgery and securities related offenses. In order to maintain program integrity, the OIG is working with local and federal law enforcement entities to investigate the complaints and follow-up with prosecution were appropriate. Furthermore, the OIG has developed the USF Strategic Audit Plan to provide overall goals and implementation strategies for oversight of this program. The process is described in the Audit of Beneficiaries Fact Sheet.

Q: Who will audit records?

A: Beneficiary audits may be performed by USAC internal audit staff, the FCC Office of Inspector General, Inspector General, Offices of other federal agencies, or a firm under contract to USAC or the FCC. Please feel free to contact the USAC Internal Audit Department at (202) 776-0200 if you have any concern as to the proper identity of any individual contacting you regarding an audit. Typically a beneficiary will be contacted by USAC two to three weeks prior to the start of an audit to assure that the appropriate personnel and documentation will be available. The anticipated duration of an audit can vary depending on the quantity, size, and dollar value of the applications involved.

Q: Where can I find help to complete forms, technology plans and provide assistance with E-Rate?

A: The Head Start Knowledge and Information Management Services (HSKIMS) provides telephone support at 1-866-763-6481.

The Universal SErvice Administrative Company Schools and Libraries Program help desk can be contacted by mail, email, fax or telephone. Contact information is found at:

Universal Service Administrative Company
Schools and Libraries Program
P.O. Box 7026 Lawrence, KS 66044-7026
Toll-Free: (888) 203-8100
Fax Toll-Free: (888) 276-8736
Via E-Mail Web site: http://www.universalservice.org/sl