I'm going to try and put myself out of a job. You see, our company
spends a great deal of time shepherding school districts through the
entire E-Rate process. But with approximately 15,000 public schools (and
almost twice as many private schools), we can't be everywhere and we
don't want any schools to miss out on the E-Rate money. So without
further ado, here's a list of things you have to do as well as things
you have to not do:
If You Want an Extension Call the IRS
there's one thing the conscientious bureaucrats at the Schools and
Library Division are agreed on, it's that if you miss the deadline you
lose. Period. End of story. You'd have better luck with the IRS so get
the all timelines right.
Form 470: Name, Rank and Serial Number Only
struggle with this form; it's a piece of cake. Basically it's just a
wish list, an expression of interest in all the things you might possibly
ever have thought about. Make it as general as possible. There's no
prize if you only list the specifics of what you will probably end up
getting. If you do try to be too specific, you will run the risk of
forgetting something or something new will come along and if you haven't
laid the foundation by including sufficiently general information on your
Form 470, you may be out of luck for another year in terms of getting
discounts. Goods and services change quite a bit between the beginning of
the application process and when you are going to be purchasing them.
Salesmen Will Call; They're Allowed
of the only "strings" attached to the E-Rate program is that vendors
are not only allowed but also encouraged by the E-Rate program to
participate in the process. The information you supply on your Form 470 is
posted on the E-Rate web site for vendors to use to contact you. The
purpose is to let you know what is available so you can get the best, most
So if you receive e-mail, phone calls and faxes, please remember they are
not unsolicited. It may be irritating to you especially if you believe you
already know exactly what you want and from whom you want to buy it.
However, the E-Rate is an open program and the vendors are doing nothing
wrong by contacting you., so try to be patient. You just might change your
plans after you hear other proposals.
The Rules Change Every Year; Work the Angles
Most public schools and many libraries are finally getting their
E-Rate act together and applying for ever-increasing amounts of eligible
services and equipment. But because the total amount is capped at $2.25
billion, the applications far exceed the amount available. Under the FCC
rules currently in effect, the higher priority categories of
telecommunications services and Internet Access are going to end up using
all of the money. Assuming those rules don't change, your strategy
should be to accomplish as many of your technology goals with services
that fall within the high-priority categories of telecom and Internet,
which are still completely funded for all schools.
For instance, where two years ago, any district no matter what their
discount level could have applied for and been granted their full discount
on purchasing a mail server, buying mail server software, hiring an
outside contractor to set it up and a contractor to maintain it, last year
only districts with a discount of 83% or higher could get that funding and
as we speak, it looks like only districts with 90% discount will get such
funding for this year. BUT, if instead of buying a mail server yourself,
you contracted with an outside party to supply e-mail accounts, then your
e-mail would fall under the fully funded Internet Access category. So you
would still be able to get funding to accomplish the same objective.
Form 471: Keep Your Story Straight
Forget what I said about the Form 470. Now you can, and you must, be
specific. Very specific. There will be a quiz. On this form you must
provide details of the services you are buying. Who, what, when, and where
to be precise.
The rules say you can't agree to buy any services or file the Form 471
until after the required 28-day waiting period following the filing of the
Form 470. Make sure all your pieces of paperwork (contracts, proposals,
invoices, purchase orders) are consistent with each other. Not doing that
is just about the easiest way to lose your discount. Unlike dealing with
the IRS, everyone gets audited.
Round Up the Usual Suspects
The E-Rate process does not replace the rules governing purchases in
your state. You must comply with all of them in addition to the 28-day
waiting period. You can still buy your services from your normal vendors
so long as you can legally do so. You are not absolutely required to buy
from the lowest cost vendor unless your state requires it. You do have to
buy the most cost-effective solution to satisfy the E-Rate rules. It gets
a little murky but "cost-effective" is not considered to mean exactly
the same thing as cheapest.
Don't Go Out on a Limb
The E-Rate people have been absolutely horrible about making timely
funding commitments. If you won't have the money or won't want to buy
a service if you don't get the E-Rate discount, be sure and make your
contract contingent on the discount. Reserve the right to cut back or
completely do away with the purchase in the event you don't get the
discount. And get it in writing.
For the Fourth year in a row, the SLD is w-a-a-a-y late making awards,
once again after promising to be more timely and once again putting school
in the Russian Roulette position of either waiting to make sure they have
funding before proceeding or taking a chance so service won't be
interrupted. The SLD's handling of the process is quite like the famous
yearly Peanuts cartoon where every year Lucy promised she would hold the
football for Charlie Brown to kick and every year as he ran up to kick the
ball, she would quickly snatch it away, and he would end up flat on his
Play Nicely With the Other Children
The E-Rate program is capped at $2.25 billion. Just because your
district has a high discount is no reason to buy more of something than
you need. You will still be wasting some of your local money and you will
be depriving other districts of funds that they can use.
You Have to Have a Plan
To participate in the E-Rate program you have to have an approved
technology plan. But, and here's the gotcha, the approval is only good
for three years. Watch out for that. And new for this year, you also have
to have a plan for how you will comply with the Children's Internet
Protection Act (CIPA).
Their Dog Will Eat Your Homework
It happens. They routinely lose all or parts of your paperwork. They
seem to specialize in losing the signature pages but just for a change of
pace they occasionally misplace the entire application. Be sure to retain
a complete copy of the fully executed document and send via FedEx or
postal mail with proof of mailing and receipt. Oh yes, also sign the
documents you send them with colored ink. They have in the past rejected
paperwork that they were convinced didn't have a manual signature. (Of
course later, they accepted faxed documents but we won't mention that.)
One Year at a Time
You are allowed to sign multi-year contracts but we don't recommend
it because there's no multi-year funding guarantees so you might end up
on the hook for the entire cost after the first year. And in case you
haven't noticed it most telecommunications and technology areas (and
especially their pricing) change so fast you may very well regret having
signed the multi-year contract. Our advice: DON'T!
Don't Change Horses in the Middle of the Stream
According to the FCC, you are allowed to change vendors after funding
has been awarded. All it takes is a doctor's certificate, a notarized
note from your mother and then it may take the SLD a year or two to
respond to your request. The aggravation is usually avoidable because the
reason for these requests is often carelessness in that the change could
have been timed to coincide with the E-rate funding year. Save yourself a
lot of aggravation; if you want a new vendor, July 1 is a great time to
start. In fact, any time you make a telecommunications, Internet or
technology decision, you really should stop to consider its effect on the
E-Rate funding it might be eligible for.
"You Screwed Up, You Trusted Us"
The SLD is just like the IRS in this respect: if they give you advice,
they won't stand behind it. To make it worse, they employ a great number
of people who do not have a clue what the items on your forms are so be
prepared for inane and dumb questions. To make it even worse, they
frequently won't identify themselves or give you any way to contact them
again. You should try and get anything they say in writing. Good luck!
Form 486: Don't 86 it
If you don't send this form in, the vendor can't get paid and if
the vendor doesn't get paid, you don't get your money. But if the
service is unsatisfactory or delayed, don't be in a rush to file this
form; it's your leverage over the vendor (assuming you haven't already
paid the full amount).
Form 472: They actually call it the BEAR Form
you are unsuccessful in getting your vendors to give you your discount
upfront then you will have to pay them in full and then get reimbursed
later. The way that works is they have to collect the money from the SLD
and you will have to collect it from them. The BEAR form is how you do
that. The sooner you file it, the sooner you get your money. (Don't ask
me why the FCC decided you can't get the money directly. Makes no
sense.) Nuff said.
Making a List and Checking it Twice
might think that if you made a simple clerical mistake on one of the forms
you would be allowed to fix it. WRONG! But you might still think that if
they made a clerical mistake in handling your application that they would
fix it. WRONG AGAIN. They may tell you that you have to file an appeal in
writing. Who do you think you file the appeal with? If you guessed
"them" you are correct. If you're not happy with the result, you can
appeal to the FCC in Washington.
An Appealing Strategy
carefully. It is crucial --I'm not kidding about this --that appeals be
filed within 30 days or you lose. Simple as that. Of course, they have
taken years (literally) to respond to appeals so don't hold your breath.
Best strategy; don't make clerical mistakes. Measure twice, cut once as
the old-time carpenters used to say.
Me the Money
you have it folks; you too can be an E-Rate consultant. On a more serious
note, if you follow the directions on their web site http://sl.universalservice.org
and use what you've just read, you should be able to get through the
whole E-Rate process without developing high blood pressure. And how many
grant applications do you fill out where you know the effort will pay off?
Don't Just Go Though the Motions
you don't follow through all the way to the end, you will have wasted
your time and have nothing to show for it. As the Yoda character
said in the Star Wars movie, "Do or do not. There is no try."