USAC needs to set a deadline for the Form 471 filing window. When it comes to applying for E-rate discounts, timing is everything. Dates and deadlines play a critical role in the E-rate application process. Right now, every school and library in America is having to budget and plan for their Internet access next year – without the benefit of knowing the deadline for their E-rate application. With no further delay, and before the holiday break, USAC should set a closing date for the FY2016 Form 471 filing window.
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It is no secret that E-rate applicants must comply with a host of deadlines, regulations, and mandatory processes. Forms must be submitted; bids must be released; boards must meet to approve contracts (sometimes at both a committee-level and the full board), contracts must be signed; equipment and services must be ordered and delivered – and all of this must happen in the proper sequence with precise timing. To do this well requires an almost surgical level of project planning. If an applicant dots an “i” too late, or crosses a “t” too early, they are likely to lose their funding.
For example, each year, hundreds of applicants lose out on millions of dollars in E-rate support because of a simple mistake: signing a contract too soon. Already, in FY2015 we have seen 125 applicants denied more than $6 million in support because of it.
Clearly, keeping a close eye on the calendar is important. The most successful E-rate applicants understand this reality and strive to work within these constraints, diligently preparing a plan and carefully executing it.
Which brings us back to the Form 471 deadline. The central figure in all of the planning – the main actor that sets in motion all of the E-rate activities – is the due date of the Form 471 application. Using the 471 due date, we calculate backwards and estimate the required release date of RFPs, the posting date of a Form 470, the earliest date to award contracts, and so on, all while taking into consideration the normal operational calendar of a library system or school district.
The Form 471 deadline is absolutely essential. Unfortunately, the Funding Year 2016 due date has not yet been set. Imagine if you did not know when your taxes would be due next year. It might be March. It might be April. Who knows? (Thankfully, there is a set due date of April 15 which allows you to plan your taxes — and to hopefully get a refund!) The lack of a dependable deadline for the 2016 Form 471 is troublesome. It creates uncertainty and increases the odds that something will go wrong for an applicant. Libraries and schools deserve better than this.
We all know that USAC is working through issues with its new EPC system and there may be reasons why the Form 471 window opening date may not yet be known. But that shouldn’t stop USAC from establishing the due date – the E-rate finish line – for FY 2016.
In FFL’s E-rate 2.0 Proposal, we suggested using the second Tuesday of March as a permanent deadline. (See pages 55-56 and Exhibit A, page 4.) Others have suggested the last day of March. But the details of the specific date don’t matter nearly as much as simply having a specific date. Put quite simply: USAC needs to set a 2016 deadline. This will give schools and libraries the ability to create and finalize their E-rate filing calendar, thus increasing their chances of E-rate success. (And while they are at, USAC should consider setting a permanent deadline, too.)
USAC, set the filing window deadline. Please.
