SLD Publishes More Instructions on Item 21 Attachments
The Schools and Libraries Division has recently provided more details of its expectations for the so-called Item 21 Description of Services attachments, the additional documentation that E-rate applicants must provide to explain the details of their funding requests.
The SLD said that several formats are possible, but said that the attachment usually consists of three parts: a narrative overview or description, line item detail of the products and services requested, and additional details such as where the equipment will be located or "other information needed to support the request." The SLD said that attachments can be either "applicant-provided documentation," a quote or bill from the vendor, or a copy of the contract for the service. The full reference is available at http://www.sl.universalservice.org/reference/Form471item21Attachments.asp.
Here are further details:
Narrative Description: This should help the SLD "understand the objective of the funding request." Among the examples provided were "additional E-mail servers for three locations" or "new data distribution equipment to replace old equipment."
Line Item Detail: Regardless of the format, the SLD said the attachment should include the quantity of items, the product or service description, a unit cost, and then the total cost, broken down by whether it is recurring or non-recurring. (The latter distinction is actually included on the application itself, and will impact when an applicant will be permitted to use the funds.)
Additional Details: The SLD noted that the Item 21 attachment is "the applicant's opportunity to provide sufficient information so that SLD staff can make a determination about whether the applicant's proposal meets FCC eligibility rules."
Location Information: The new Form 471 application requires that internal connections funding requests include information about where the physical components will be located. IN some cases, the components may be installed at a location that is different from the entity being served, such as, for instance, when components installed at a district office serve the needs of one or more schools. The SLD provided examples about how such installations could be described, without addressing issues related to the discount rate used or the application of the new "two years out of five" restriction on internal connections.
The SLD provided examples of acceptable Item 21 attachments for various categories of services. The SLD noted that a "representative telephone bill" could be provided as a back-up for telephone services, and optionally a listing of the previous year's charges could be provided to substantiate the charges for the next funding year. Additional explanation should be provided for funding requests that are above the amount indicated by the historical evidence.
The SLD noted that "in many instances, additional information is useful or necessary." As an example of what it described as "insufficient information," it listed "five routers @16,000 each" and "Technical services for above products @ $48,000." The SLD said that for "complex configurations" or "relatively high-end components," applicants may wish to include "copies of vendor quotations, a specific listing of the modules or specifications for a product, and/or copies of contracts."
The SLD provided some examples of how applicants could anticipate issues that would lead to additional questions and address them. These included content creation as part of Web hosting, memory upgrades for servers, multiple T-lines that are necessary for an applicant's bandwidth needs, and the nature of eligible training.
The SLD provided the text of certifications that applicants will be required to make in certain specific cases, including remote access equipment, equipment that could establish a Virtual Private Network, file servers, extensive file storage, wireless access points, cost-allocating ineligible functionality, amortization of upfront-service provider infrastructure costs, and on-premise Priority 1 equipment.
In cases where a funding request is limited to equipment included in the SLD's pilot online data base of eligible internal connections products, applicants can use an online tool to generate their Description of Services Attachments. The tool is designed to be used after a funding request number has been generated through the creation of an online Form 471 application. The tool can be accessed at https://slpin.universalservice.org/mfpin/epdpublic/BENFRN.aspx.