Important Dates

You can file your form 470 for FY2012 at any time now on the USAC Website.

E-rate Audioconferences/Trainings with Valerie:

Date / Time
10/20/2011 3:30pm
11/3/2011 3:30pm
11/17/2011 3:30pm
12/1/2011 3:30pm
1/2/2012 3:30pm
1/26/2012 3:30pm
2/2/2012 3:30pm

Call in # is 1-800-315-6338
Conference code is 4051

Item 21 Attachments
Alaska State Library > E-rate

Attachments and Documentation

You may plan to send an entire packet of Attachments or to do an online Item 21 attachments, depending upon the amount of information you feel must go in to explain your requests. If you have already sent documents of the types listed below for a particular request in a former year, you may want to try the much less comprehensive ONLINE form this year. It is recommended that you submit an online attachment for your services unless your circumstances have changed greatly (new school, different method of determining student eligibility, very large increase in services, etc.), you may want to file documentation to support your request. In either case, keep all the documentary information listed below handy. You may get inquiries that demand you produce it on short deadlines.

Online Item 21 Attachments can done by going to going to the USAC website and selecting the last blue link in the Form 21 column. Any of the documentation mentioned below can be cut/pasted into the “additional information” box of your online Item 21 attachments. Online Item 21 Attachments are encouraged. Applications do NOT get denied because PIA needs additional information beyond what you submitted. They will reach out to you to get any additional information they need to process your application and make a decision.

Carefully planned Item 21 attachments have a purpose. They verify the funding you have requested, and provide PIA with enough information to process your application. Well done Item 21s help to avoid calls from PIA. You want to explaining anything that might prompt PIA to question your application and so slow it down in the review process.

Item 21 Attachment Overview

Several different formats are possible for the Item 21 Attachments. However, the Item 21 Attachments generally consists of these parts:

Applicants often receive the assistance of service providers in creating the Item 21 Attachments, which can be one or more of the following:

Narrative description

The narrative description should be a summary that allows USAC to understand the objective of the funding request. For example:

Line item detail

Regardless of the specific format used, the Item 21 Attachment should include the following type of information:

Mail-In Attachments

If you are mailing in an attachment packet, the first page of your packet should be a table of contents, listing all the documents you are including. On that page, be sure to list your organization name and entity number and the Form 471 application number that it goes with, and your name and phone number. If they DO have to call you, make it easy. Then keep a copy of that packet where you can find it easily…just sending it doesn’t magically guarantee that everyone who needs it will see it. Even for large funding requests, an item 21 packet of 30 pages is deemed excessive by reviewers.

You can either scan and e-mail the attachments, fax them or mail them. If you are filing more than one Form 471 (as in one for Priority 1 and one for Priority 2), don’t put the attachments in the same e-mail, fax or envelope. Each 471 should have its own attachments sent in separately, but you only need to put the extra documents in with the main form, usually your Priority 1 application.

Every document needs to have, in its top right corner, your organization name and entity number and the Form 471 application number that it goes with. Identify the pages of each document with titles and numbers and/or letters as you need, but do not staple them together. Everything you send in gets scanned, and staples just slow down the process.

Documents that Might be Included in Attachment Package

Any one of these documents could be submitted in an item 21 attachment packet or cut/pasted into the additional information box of an online attachment.

List of ID Numbers

Every site (instructional or non-instructional) that gets services, the administrative unit which controls all those sites, and any additional entity that is not eligible itself but pays the bills for an eligible entity has to have THREE ID numbers (BEN, NCES, and FCCRN). Two of these numbers get filled in on the 471 itself….assuming that you have them when you are filing. (Since non-instructional and cities don’t have NCES or FSCS, just plan to leave them blank on your Block 4.) That third number (FCCRN) needs to be sent to the SLD in some way. Because of the way that all of this data is being created and collected by SLD, you will find that they have some of your numbers and not others. To avoid piecemeal questions, you might want to make out a chart or an Excel spreadsheet (depending on the size of your organization) listing the numbers in one easy-to-read sheet.

I suggest these column headings: Site Name, Town, Type, BEN, NCES, FCCRN

  1. The first line in your chart should be used for the district or the main library of a library system. Make a separate line for EACH of your entities.
  2. For SITE NAME, enter the name of the school or city or district that SLD uses on your forms.
  3. TOWN should be the physical location of that site.
  4. TYPE should be on the order of School, Private School, Bus Garage, Admin Office, Government Agency, etc.
  5. BEN is, of course, the number SLD assigned the entity.
  6. NCES or FSCS should be found from one of the lists on the Alaska E-Rate website under News. If you cannot find it there, put in an explanation; i.e., New School, Government Agency, New Library, NIF. If you leave out the explanation for a blank…expect a call about why it is blank.
  7. An FCCRN has to match every single BEN. If you don’t have these, get them before sending in the Attachment Packet.

Explanation of Discount Numbers

If every enrollment and eligibility number on your Block 4 sheets matches (pretty closely) the numbers on the State Lunch Program website, you can skip this. If you have any different numbers, you need to explain why. It could be a simple statement “These are the numbers which the district collected in January 20xx” written at the top of a copy of the state enrollment and lunch report showing those numbers. It may be a letterhead memo signed by your superintendent stating that “47 migrant education students were added to the reported lunch numbers in accordance with the August 16, 2004, memo from the United States Department of Agriculture regarding the eligibility of migrant students for NSLP.”

If you use a survey, your document should contain a copy of the survey with the data itself blacked out, and an additional page stating that 100% of your families were surveyed and XX% of the surveys were returned, giving the following results: XX.

However you collected your lunch numbers, explain your method. If you checked the box in Block 4, Item 10 which asked if you used an Alternative Discount Mechanism, you need to address what your alternative was with this document.

Disclaimer for your NIF Buildings

Many of you received a set of questions about the buildings you claimed last year as non-instructional facilities. If you have any of these “extra” buildings on your Block 4 lists, do a pre-emptive strike. List each of the building names, locations, types, and entity numbers. Then at the bottom of the list, cut and paste this statement (WITH TRUE ANSWERS, OF COURSE):

Answer YES or NO

  1. Is the DISTRICT OFFICE located in a facility that also houses classrooms?
  2. Are all the non-instructional stand-alone Facilities are on an eligible entity’s campus?
  3. Are all the non-instructional facilities owned or leased by the school or school district, and used solely for school district business?
  4. Are all the non-instructional facilities are used only by the school or school district employees?
  5. Are the internal connections in the non-instructional facilities essential for the effective transport of data and information to an instructional building of a school or to a non-administrative building of a school?

SIGNATURE: _________________TITLE:__________DATE:_____

You may have to split your NIFs into two groups and rewrite the above statements to fit each group.

On-Premise Priority 1 Equipment Statement

If your funding request is for On-premise Priority 1 Equipment, you will need to make the following statement for that equipment, and sign/date the statement to include in your attachment. If you do not, PIA will send the questions to you to complete before your application can be approved.

  1. The leased on-premise equipment is an integral component of the telecommunications or Internet access service.
  2. The leased on-premise equipment will be provided by the same service provider that provides the associated telecommunications or Internet access service.
  3. Responsibility for maintaining the equipment rests with the service provider, not the school or library.
  4. Ownership of the equipment will not transfer to the school or library in the future, and the relevant contract or lease does not include an option to purchase the equipment by the school or library.
  5. Upfront, capital charges of the on-premise equipment are less than 67% of total charges in the funding year. See below for this calculation.
  6. The equipment will not be used by the school or library for any purpose other than receipt of the eligible telecommunications or Internet access service of which it is a part.
  7. The applicant's internal communications network is functional without dependence on the equipment.
  8. There are no contractual, technical, or other limitations that would prevent the service provider from using equipment that would normally be shared in other similar arrangements with other customers.

Additional Documentation or Notation

Remember that you need an Item 21 attachment for every single Block 5 that you fill out. In a mail-in attachment packet you may use the same one for multiple Block 5s, assuming the information fits, or you may put 5 different documents as the Attachment for a single Block 5 if you need to explain that much. Each of them has to have, up in the top right corner, the ubiquitous organization name and entity number and the Form 471 application number, and also needs an Attachment Number (which you have listed in Block 5 Item 21.) If there are multiple pages, label them with a system like Attachment #1a, Attachment #1b, etc..

Remember that the amounts verified by the attached documents have to match the amounts you are requesting in the Block 5. If there are items listed in billing that are ineligible (charges for unlisted numbers, or for a filtering service, or for lease payments on a video camera, etc.), be sure to circle or otherwise note those charges and identify them as ineligible. The online attachment has a place for you to enter ineligibles that appear on a bill. Redo your math and be sure you are only asking for eligible amounts.

In particular, anything purchased under Internal Connections needs to be laid out in great detail with respect to model numbers, where it will be located, and specific costs. If you send in a contract for 3 servers at $12,000 each and technical services for those servers at $8,000, you are just begging for PIA to call to chat with you. Add the details about make/model, where you plan to put them, what they will be used for, what kind of services those technical sorts encompass and any breakdown of costs for components of the service and it may slide through. If anything you buy is listed as Conditionally Eligible in the Eligible Services list, be sure to explain upfront how you meet the “condition”.

Remember that your Attachment Packet on online 21 attachments do not have to be submitted by the deadline for filing. However, your application will not go into the queue to be reviewed until they are received. If you have a problem getting any of the information for the Attachment Packet, you may decide to go ahead and submit what you have to get the review started, knowing that you will be getting calls about the missing info.

Creating a Document Trail

Retain the following for 8 years, in case of an audit