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Internal Connections Equipment Transfers

Over the last few weeks, Funds For Learning has received a number of questions about when and how the transfer of eligible Internal Connections should take place when the three-year installation threshold has not been attained. We have compiled some highlights from these questions below:

As a reminder, an applicant can transfer equipment to another eligible entity within three years of its original installation only if the site(s) that it serves close either temporarily or permanently. An equipment transfer is generally needed when a multi-site organization, such as a school district, chooses to close one or more sites–either temporarily or permanently–and the equipment must be moved to other eligible sites within the organization. But an organization can transfer the equipment to another organization that is also eligible for E-rate discounts, provided that it is not sold, resold, or otherwise transferred for money or anything of value.

Equipment doesn’t need to physically move to be considered transferred.

Changing the physical location of the installed equipment doesn’t necessarily initiate a transfer. One must examine a list of entities that are receiving service from the equipment. Take the following example: a school district is moving various pieces of equipment that are installed at different schools to a central location. As long as the equipment continues to serve the same entities, the SLD does not need to be notified of the move. But in all cases of physical moves, records should be kept to ensure that you and auditors can locate the equipment and identify the eligible entities receiving service from the equipment.

Anytime the equipment provides service to entities that were not included on the approved funding commitment, a transfer has occurred. And, if this transfer occurs within three years from the date of its original installation, one or more original sites must have closed. This is when the SLD must be notified about the transfer.

Equipment can be transferred to a site with a different discount rate.

It’s a common misconception that when transferring equipment, it must be to a site that has the same discount rate or grade level(s) as the original entities. This isn’t the case. It can be transferred to an entity with a lower discount rate or different grade levels

Equipment must be installed before it can be transferred.

As simple as it sounds, equipment must be installed before it can be transferred. Take the following example: A district applicant requested Internal Connections funding for networking equipment for a school. In the time between the original application and the funding commitment, the site associated with the funding request closed. The district did not install any equipment prior to the school’s closing. Since no equipment was installed at the now-closed facility, the equipment that was originally intended for this site cannot be installed a different location and consider it ‘transferred.’

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