Here are five things to keep in mind that will help your school stay in compliance and keep your sanity intact:
1. Document every detail
As they say, “the devil is in the details,” and when it comes to E-rate, if you don’t document every last detail, you’ll have a devil of a time maintaining compliance. As part of E-rates documentation and retainment requirements, both you and your service providers must document all information that pertains to your E-rate funding and retain that documentation for 10 years. This includes information on:
- Technology plans
- Pre-bidding, bidding, and contracts
- The application process or provision of services
- Financial records of any kind
- Anything else related to the administration of the universal service fund
Also, make sure your documentation is thorough. For instance, for meetings or phone calls, you’ll need to show who attended and provide notes on the meeting discussion. You’ll also need to keep copies of any drafts of documents related to the process, documentation of any service downtime, logs of maintenance performed, receipt and delivery records, and financial records such as invoices, purchase requisitions, POs, packing slips, and customer bills.
2. Be prepared for an audit
When it comes to the E-rate program, it’s not a question of if you’ll be audited, but when. Accountability is an important part of any SLED funding, including E-rate, and audits are one way to ensure funds are used appropriately. Your first audit will likely be a Program Integrity Assurance (PIA) review of your 471 filing to ensure your application is complete, compliant, and cost-effective. Look at this audit as a helpful way to ensure you’re on track to maintain compliance rather than as something to fear.
Other common audits you might encounter include:
- Payment Quality Assurance (PQA) reviews
- Agreed-Upon Procedures audits
- Investigatory audits
3. Know when you need to file separate 471s and when you don’t
When you have more than one funding request, the E-rate application process can feel even more complex. If you’re wondering whether you need to submit a new Form 471 for each request, the answer is, “it depends.”
If you are only filing Priority 1 requests, you can put all of your Priority 1 funding requests on a single Form 471. However, if you have Priority 1 and Priority 2 funding requests, you’ll need to file separate forms. Also, if you’re applying for different discount levels in Priority 2, then you will also need to file those on separate 471s as well.
4. When you make a mistake, be sure to correct it
Given that you’re merely human, the chances of making a mistake with your E-rate application process is likely – even for the most seasoned IT directors. But, there’s no need to panic when you encounter an error. If you’ve already submitted your application and need to make a correction, you can make changes using the Receipt Acknowledgement Letter (RAL). If you’ve made a major mistake to your submitted 471, complete a new 471 before the submission deadline and then cancel the original one when the RAL comes.
5. Don’t be afraid to ask questions when you don’t know the answer
Because the E-rate process is complex, there are often questions that pop up that you can’t easily find an answer to. Fortunately, the Universal Service Administrative Company is an excellent resource for E-rate participants. It offers a variety of training events and online resources and a weekly news brief. You can also contact the organization directly to get specific questions answered, but make sure you document your contact with them and their response.
E-rate compliance may never be easy, but if you follow these five tips, you can at least stop having panic attacks at the thought of an audit and instead feel confident that you’ve taken the right steps to ensure compliance.
