Kudos to the folks from USAC for the presentations they made at the Minneapolis training this year. They do not have an easy job: take a complicated program like E-rate and try to explain it to the common man in one workday. But they did as well as I think anyone could.
As I was listening to the presentations, it reminded me how much good E-rate does in terms of getting schools and libraries the connectivity they need, how tricky it can be to avoid the “gotchas” and pitfalls of the program, and how some of the rules and procedures of the program just leave me scratching my head. Here are some examples.
Service Category for Dark Fiber The eligible services list for 2013 indicates that Telecommunications and Internet Access are no longer separate service categories, in theory. But apparently the forms 470 and 471 for FY2013 will not be updated to reflect this. This has some confusing ramifications for requesting Dark Fiber. On the form 470 applicants should request Dark Fiber in either the Telecom or Internet Access categories. However, when it comes time to file the form 471, it should be requested under the Telecom category if the provider is a telecom carrier, and it should be requested under the Internet Access category otherwise. Now when you double-check that application before submitting it this year, be sure you’ve selected the proper service category (okay, which one was it again?).
Retain your E-rate documents for 5 years…or more Unless you’re an E-rate novice, you are probably aware that you need to be keeping your E-rate documentation for 5 years. But take a second look at that rule. Documents supporting an applicant’s funding requests “must be kept for a period of 5 years after the last day of service delivered” (emphasis added). That means that if you are using a contract with a service provider from 2008 to support a funding request for 2013, you need to keep that contract around until 2019 (service for FY2013 would end June 30, 2014, then add 5 years…you’ll be keeping that contract for 11 years!).
Free Extensions! The good news is you may have already received a free service delivery extension. The catch is you may never know you received it! In some circumstances, extensions are granted automatically. If USAC issues an FCDL, an operational SPIN change approval or a service substitution approval, USAC should grant you an extension. You have to know to go look at the FRN extension table on USAC’s site to know for sure.
And then there’s that crazy gift rule (see title). Maybe it’s just safer not to take anything a service provider wants to give you for free. Beware strangers with candy and service providers with free gifts.