Today I used profanity at the office.
This isn’t entirely uncommon to those who work with me. It’s decidedly unprofessional, but it’s nonetheless a part of working with me. I’ve frequently apologized to my office mates (and more frequently felt like I should apologize – sorry, John, Alfred, and Stephen.) So, for perspective, when I say something has me worked up to swearing-in-front-of-my-boss levels, you should understand that this happens frequently enough that while it’s one of the more quirky aspects of our corporate folklore, it typically isn’t cause for sounding the klaxon.
But something has me worked up.
By a very rough estimate, I’d estimate that at least $1.5 million in funding requests were denied in Funding Year 2014 due to violations of the E-rate program’s 28-day bidding requirement. And anecdotally, it feels like the 28-day bid period is one of the more stringently enforced regulations on the books. Schools can miss out on an entire year’s funding simply because they signed a contract less than 24 hours before their Allowable Contract Date – we’ve seen it happen. It’s one of those cardinal rules we harp on during our training presentations: know your ACD, and do not award contracts until it passes!
I don’t have a beef with the 28 day requirement. It’s a sensible rule – if you’re going to require a competitive bid, it stands to reason that you will have to require a minimum time period for that bid to be open. What gets my shorts in a bunch is when you have a rule (valid as it may be) but don’t give folks the information they need to follow it.
If you haven’t noticed, the FCC Form 470 has changed a lot for FY2016. Not only is much of the information collected on the Form new, but the process by which it is filed (using USAC’s new EPC system) is also a first. And in my mind, one of the most significant changes to the Form is that no matter how you access a posted Form – via EPC, USAC’s public-facing website, or data feed – there is no Allowable Contract Date in the fields displayed.
That’s frustrating to me. The Allowable Contract Date is important – you’re sure to face funding denial if you don’t observe it, so I’d put it up there with some of the more significant aspects of maintaining compliance with the rules. So why is it no longer listed prominently on the Form?
It’s not just applicants who need to know the ACD. Service providers depend on that date to determine a “deadline” for preparing bid responses for applicants. Sure, some applicants leave their bids open for longer than 28 days, but we know of few vendors who prioritize preparing responses to 470s after the ACD has passed – especially during ‘crunch time’ when there may be more 470s being filed each day than the vendor has resources available responding in the first place.
So what can I do about it? Well, I can swear. (That much is a given.) I can also whine about it in a commentary article (if you’ve read this far, check that one off your list too.) But third, I can help you! Today I asked our developers to move our delightfully handy E-rate Date-O-Matic tool over to the free tools section of our website. Put it in your bookmarks! When you need to know your (or someone else’s) Allowable Contract Date, you can pop in the date the 470 was certified, hit the button, and have 28 days counted forward for you just like magic!
So I know most of y’all haven’t gotten around to filing your 470’s. But when you do, remember: the 28 day bidding period is still an important requirement! Since you don’t have 28 fingers and toes to count on*, use our tool for quickly calculating your ACD so that you’re sure not to award contracts too early. Your funding just might depend on it!
*If you do have 28 fingers and toes, you have an ACD calculation advantage and probably don’t need our tool. But we’re always looking for ways to build in failsafes in case our website breaks down. If you meet this criteria and are interested in an exciting career opportunity, send your resume – and photos – to firstname.lastname@example.org.