E-rate Filing Window Closed: 5 Tips for Getting Through PIA Review Season

Congratulations to all applicants who filed for E-rate funding support during the e-rate filling window!

Most of you are now anxiously waiting for questions from a Program Integrity Assurance (PIA) reviewer on the applications submitted. This can be a hectic time as organizations try to stay on top of everything. Here are five tips to help entities hit the ground running.

1. GET FAMILIAR WITH THE PIA REVIEW PROCESS

The PIA review is a 3-step process to verify information on the FCC Form 471s for compliance with program rules and policies. Not all applications will go through all three steps. The steps are:

• Initial Review
• Final Review
• Quality Assurance

Though the name “Program Integrity Assurance” sounds onerous and is exactly that for many organizations, being familiar with the process can help you better organize the necessary information and make the process much more manageable.
Regardless of the step in the process, be prepared to answer questions pertaining to:

• The eligibility of the entities receiving services
• The eligibility of services requested
• Discount calculations
• Category 2 budget calculations
• The competitive bidding process
• Contracts

During the PIA review process, a lot of time will be spent gathering supporting data and documents requested – so organize the records related to your FCC Form 470, competitive bidding process, and FCC Form 471 now!

2. GATHER AND ORGANIZE SUPPORTING DOCUMENTS

Given the length and the multiple steps involved in the application process, it is common for documents to have been produced or received by several individuals in your organization. These records may be stored on PC hard drives, Google Drive, Dropbox, or file drawers (yikes!). We suggest storing all related documents in a centralized location for consistency and ease of access.

There are many options for document storage. However, ErateSync ™, a cloud-based documentation retention app by EdTechnologyFunds, is specifically designed to help E-rate applicants easily store and retrieve records by funding year and category. 

Here is a list of documents to collect and store now, as it might be more difficult to find them later:

1. Competitive Bidding:

• Request for Proposal (RFP), RFP documents, and Addendums
• Public notice of RFP issued (if required)
•  Winning and losing bids
• Questions and answers provided to potential bidders – emails, supporting documents, or other correspondence produced as part of the competitive bidding process
• Completed bid evaluation matrices or other documents that show how the received bids were evaluated and the winning bid was chosen
•  Contracts and/or legally binding agreements, with evidence of board approvals if board approvals are required by your state or local procurement laws
• If a restriction prevents services and costs from being made public, a copy of the precise cite of the law, statute, local rule, or court order identifying the restriction

2. Discount calculations:

• National School Lunch Program (NSLP) data sources
• Income surveys or other surveys
• Direct certification documentation and other documents related to participation in CEP or other provision(s) of NSLP
• Other documentation used to compute student counts

3. Supplemental Documentation

• Consulting agreements and/or letters of agency
• Draft and/or final budgets
• FCC Form 470 modifications submitted
• RAL modifications submitted

Please note that the list above is not exhaustive.

ErateSync™ allows for files to be stored by categories such as Competitive Bidding. Each record can also be tagged by function such as RFPs, contracts, and more to make future access more manageable.

3. REVIEW FCC FORM 471s SUBMITTED

Let’s be honest – FCC Form 471s are difficult to complete correctly. Data entry and clerical errors happen frequently. The amount of detail needed for each funding request can seem overwhelming and the dropdown menu selections are confusing to many.

Fortunately, the Universal Service Administrative Company (USAC) recognizes this and allows applicants to correct ministerial and clerical (M&C) errors on an FCC Form 471 through the Receipt Acknowledgment Letter (RAL) modification process. RAL modifications can also be used to update entity/organization data that was not entered before E-rate Productivity Center (EPC) profiles were locked.

With a large cup of coffee (or tea), sit down and carefully review your FCC Form 471s using the following steps:

1. Verify the FCC Form 470 application number cited for each funding request. The establishing FCC Form 470 can be from the current funding year or a prior funding year, in the case of multi-year contracts.
2. Verify your entities’ 10-digit FCC Registration Number using the FCC’s Commission Registration System (CORES).
3.  Review contract and the start of service dates, two areas where M&C errors are typically made, and correct as needed.
4.  Review costs and cost allocations for each funding request. You may need a refill for this step. Check the math. The pre-discount costs of your funding requests should match the information in the contract(s) or other documentation used to prepare the form.

4. MONITOR EPC NEWS FEED AND EMAILS FOR PIA OUTREACH ATTEMPTS

PIA reviews questions can come any time after the FCC Form 471 is submitted. However, be prepared to wait a couple of months to receive the first inquiry.

After preparing the necessary questions, the initial reviewer will issue questions via the E-rate Productivity Center (EPC) portal. You will be notified by email and in the EPC News feed that there are PIA questions to be answered. Your state E-rate coordinator will also be notified.

5. AVOID PROCRASTINATION

Applicants usually have up to 15 days to respond to PIA review questions. It seems like a lot of time, but trust us, it goes by quickly.

Given that most of you are working on many projects for your school or library, we recommend reviewing requests as soon as they are received. This will ensure that you have enough time to organize responses, as delays in funding awards or funding denials are often caused by a lack of timely responses.

You can always ask the reviewer for more time if needed.

Using these tips will help you better prepare for and navigate through the PIA review process.

If you have any questions about the E-rate filling window or would to discuss your E-rate needs, feel free to contact us by e-mail at edtechnologyfunds@gmail.com

For an entity to be eligible for an E-rate funding discount, it must meet the program’s definition of a school or library.