Best Practices

USAC has prepared this list of “Best Practices” to assist applicants and service providers to comply with program rules. USAC encourages all program participants to review this document and implement the recommended practices. Note that the Fifth Report and Order (FCC 04-190, released on August 13, 2004) requires both applicants and service providers to retain all records related to the application for, receipt and delivery of discounted services for a period of five years after the last day of services delivered for a particular Funding Year.

Competitive Bidding Issues

Applicants

• Retain copies of bidding specifications and/or requests for proposals (RFPs), all bids received (both winning and losing), and all contracts.
• Follow state and local procurement laws and regulations and maintain documentation of compliance with these requirements. These requirements may include, but are not limited to, advertising and bonding requirements.
• Maintain documentation of the process and any related analysis leading to the selection of the winning bid; including selection criteria and the weighting of those criteria.
• Select service providers and sign contracts ONLY after the 28-day Form 470 posting period has passed (allowable contract date).

Service Providers and Applicants

• Maintain documentation indicating the details of any advice supplied by the service provider to the applicant. Remember that a service provider is permitted to supply general advice to an applicant in preparing Form 470, BUT CANNOT SIGN OR PREPARE THE FORM 470.

Invoice Documentation Issues

Applicants

• Submit BEAR Forms to USAC only after receiving customer bills (bills from service providers to applicants) and paying them in full.

Service Providers

• Submit invoices to SLD only after services have been delivered unless progress payment provisions are included in the contract with the applicant.
• Submit Service Provider Invoice Form (Form 474) to SLD only after issuing customer bills.
• Include on customer bills sufficient detail to identify the specific services provided, when the services were provided, and the cost of the services. A customer bill that indicates an amount with a description such as “eligible E-rate services” is not sufficient.
• Indicate on the customer bill the make, model, and serial number for any equipment provided.
• To the extent possible, use the same nomenclature on the customer bill as on the Item 21 Attachment for the Form 471.
• On customer bills, indicate the full pre-discount cost with the discount (if provided by the service provider) shown as a credit.

Service Providers and Applicants

• The submitter of an invoice should maintain an analysis relating the SLD invoice (using the Invoice Number on Form 474 or the Reimbursement Form Number on Form 472) to the invoice numbers of the customer bill.
• Maintain copies of customer bills and invoices submitted to SLD to facilitate any requested reconciliation.

Disbursement Issues

Applicants

• Establish internal control procedures to assure that BEAR invoices are not submitted until payment has been made to the service provider.
• If 45 days have passed since the receipt of the BEAR Notification Letter without receipt of payment from the service provider, contact the service provider and request payment. If payment is not forthcoming, contact the Customer Resource Center at 1-888-641-8722 to request assistance.
• Establish controls to track specific payments of the non-discount portion of services provided. If reimbursements are requested, include an identification of the specific BEAR Form relating to each payment.

Service Providers and Applicants

• Include only services provided within the funding year on invoices submitted to USAC.
• Deadlines differ for recurring and non-recurring services. Submit requests for extensions for delivery or installation of non-recurring services on a timely basis. Always verify the date of an extension by referring to the “FRN Extension Status” available on the SLD web site.
• Refund to USAC the appropriate portion of disbursements made by USAC for equipment that is returned.

Services and Equipment Issues

Applicants

• Good internal control requires detailed fixed asset records. Such records should include:
  
  • Make
  • Model
  • Serial number
  • Physical location (including room number and the history if equipment was moved)
  • Date installed
  • FRN
  • Customer bill reference number(s)
  • Pre-discount cost
  • Non-discount portion
  • Reference number (e.g., check number) of the payment of the non-discount portion
• Test the equipment on a periodic basis to confirm that it is functioning and maintain documentation of the results.
• Be aware of the definitions of eligible uses under program rules and be sure that services are not requested or ultimately used for ineligible purposes.
• Ensure you have secured the resources and have obtained the services necessary to make effective use of E-rate discounts. (Example: the budget must show the non-discount share and reflect the ability to pay for required services not support by E-rate.)
• Use discounted services only for educational purposes.
  

Service Providers and Applicants

• Document the delivery and installation of equipment using a completion certificate signed by the applicant. Maintain completion certificates in a permanent file.
• Submit service substitution requests on a timely basis. The request should be submitted no earlier than the date of the Receipt Acknowledgment Letter and no later than the last day to receive service.
  

Technology Plan Issues

Applicants

• Retain a copy of a budget or other documentation to verify access to the resources to make effective use of E-rate discounts.
• Retain a copy of the technology plan approval letter. Make sure the approved plan(s) cover the complete funding year — i.e., if a plan expires in the middle of a funding year, have two approved plans so that the entire funding year is covered.
• Retain documentation that the evaluation process has been implemented as defined in the approved technology plan.

Entity Eligibility Issues

Applicants

• Contact your state department of education for information on the eligibility of juvenile justice, adult education or pre-kindergarten facilities and/or students under state law.
• You may also contact the Customer Service Bureau before preparing Form 470 and Form 471 if you have questions concerning entity eligibility.

Service Providers and Applicants

• After receiving the Receipt Acknowledgment Letter (RAL), verify that all Block 4 data are correct. Report any errors within the three-week RAL correction period.

Discount Percent Issues

Applicants

• Retain documentation that agrees with and supports the discount percent requested on Form 471. This documentation includes, but is not limited to, the free and reduced lunch report or other documentation. If an alternative discount mechanism was used, retain documentation that supports the information on the Form 471 Block 4 worksheets.