There is a desperate need for a standard Form 471 filing deadline, allowing applicants to plan for each year. It has previously been recommended that the FCC establish a set annual deadline for the Form 471 filing window - and for good reason. The lack of a set date leaves much uncertainty and often results in delayed planning and late application submissions.

In late October, the SLD recommended opening the window no earlier than January 5, 2012 and keeping it open for 70 days. This places the estimated deadline on or around March 15, 2012. This is similar to the late March filing date last spring. According to an informal analysis conducted by a popular U.S. Spring Break destination, approximately 30 percent of U.S. schools are on Spring Break the second and third week of March. This was problematic for many school district E-rate staff last spring, because many school contacts were out on vacation and unavailable to answer questions or provide documents necessary to complete the Form 471. Filing E-rate applications may be tasked to one school staff member, but they always involve support from multiple staff and various departments within the school district. Closing the filing window during Spring Break created unnecessary challenges for applicants.

We encourage the SLD to close the window no later than March 8, 2012. This time period will allow adequate time after holidays and potential inclement winter weather, but also close before many schools leave for Spring Break. If announced soon, this would still allow schools over 100 days to prepare for the Form 471 deadline.