Transfers of Equipment
The FCC allows for the transfer of equipment from one entity to another; however the circumstances to allow for such a transfer are very strict and specific.
What are Transfers of Equipment?
A transfer of equipment occurs when equipment provides a service to an entity not included on the original FRN. It does not necessarily mean that the equipment has been physically moved from one location to another, nor does it mean that the original entities listed on the FRN are no longer using it.
What are the rules for equipment transfers?
As with all things E-rate, one must pay close attention to program rules when dealing with transfers of equipment:
- Equipment is only eligible for a transfer after three years from the purchase date unless the transfer is because the location it served has closed.
- Transfers that occur within five years of the installation date cannot be for money or anything else of value.
- Equipment may only be transferred to other eligible entities within the same district or consortium. The discount rates of the entities do not matter when transferring equipment or services, so for example an 80% school can transfer to a 20% school.
- In conjunction with the normal ten year document retention requirements, if equipment is transferred, applicants must maintain documentation of the transfer for ten years from the date of the transfer.
- If the equipment transfer occurs less than three years after purchase, applicants must notify USAC by filing an FCC Form 500.
When would I need to transfer equipment?
Suppose that you have equipment from an FRN currently serving two entities. It has been three years (or longer) since the purchase date of the equipment. You want to have a third eligible entity, which was not listed on the original FRN, also use the equipment. This is allowed, and it requires a transfer of equipment.
In another scenario, suppose you have equipment serving an entity which has closed. The normal requirement of equipment being used for three years does not apply, and a transfer can occur to another eligible entity.
When does a transfer of equipment not occur?
An equipment transfer only happens when an entity not on the original FRN uses the equipment.
Say you have equipment serving an entity on-site. The equipment needs to be moved to an off-site location (such as a network facility), but will continue to only serve the one entity. In this case a transfer of equipment has not occurred because the equipment still only services that one entity. However, applicants should continue to document the current physical location of the equipment, which is information that is often requested in the event of an audit or review.