If you’re preparing for a Program Integrity Assurance (PIA) review on your Category Two funding request, it may help to know exactly what a reviewer is checking, and why. Here’s a walkthrough of what typically comes up, based on what we’re seeing this cycle.
FY2025 marked the end of the first five-year Category Two budget cycle. With a full cycle of data now available, reviewers have a stronger baseline for comparison. As a result, applicants should expect closer scrutiny of three key areas: enrollment counts, entity data, and library square footage.
What reviewers look at:
A PIA review isn’t a random audit. It is a structured check against a handful of specific data points:
- Enrollment Numbers. Reviewers compare what you reported against third-party documentation. A mismatch, even a small one, tends to generate a follow-up question.
- Entity status in EPC. Your E-rate Productivity Center (EPC) account needs to reflect the current status of each entity. If it is open and active, it should show as active in EPC and linked to your district/library system. If it is closed, it should show as closed and unlinked from the district/library system. Each entity should have the most up-to-date information.
- Library square footage. For library systems, square footage drives the budget calculation directly, so it’s worth double-checking against your own records rather than assuming EPC has it right.
Where applicants get tripped up:
A few things are catching people off guard this cycle in particular: Community Eligibility Provision (CEP) documents expiring, uncertainty about how grace-year rules apply, new school sites opening mid-cycle, difficulty tracking down state or third-party documentation to support a budget number, and thin bid evaluation documentation showing how a vendor was chosen.
The takeaways
- The most common issues are enrollment mismatches, missing or inactive entities, square footage errors, and uncommitted prior commitments not being accounted for.
- Don’t rely solely on EPC’s budget calculation. Run your own numbers independently.
- Reviewers increasingly want to see documentation behind how a budget was calculated, not just the final figure.
- Small inconsistencies can trigger additional PIA questions, even when the underlying number is close to correct.
- Validating your data early and keeping your own records reduces how often that happens.
Have questions about your Category Two budget? Join our next free My E-rate Guides (MEG) webinar on August 6 for live training and a Q&A with your E-rate Guides. Register here.
About the Author: Sheauna Brown has been part of the Funds For Learning team for nearly five years and is based in Edmond, Oklahoma. Outside of work, she enjoys spending time with family and friends, and she puts real value on building strong personal relationships and making space for the people who matter most.
