[Erate] Additional guidance from USAC regarding ESD consortium applications

[Carson, Sabrina]

Below is a summary of guidance from USAC regarding how ESD's can file their individual and consortium applications. There will be more information in next week's newsletter. It includes a workaround for the 471 bug that will not allow an ESA with no schools of its own to be added as a consortium member. Please note that this work around requires information to be added in the narrative of your first FRN, so be mindful to include that as you fill out your forms.


Updated Guidance for ESD Discount Calculations



ESDs have multiple ways to file their E-rate applications, depending on what services they are procuring, for whom those services are being procured, and whether an ESD has its own schools or not.  The instructions on how ESDs should file their Form 471s for each situation have generally not changed over the years, but with the new 471 filing system there has been some difficulty determining exactly how to file for each scenario.  There is also a technical problem (described in # 3) because the online application will not permit a NIF (non-instructional facility)-only entity to be a stand-alone consortium member.  USAC has provided guidance as a work-around for this year if you are in this situation.



1)  ESD FILING FOR ITS OWN SERVICES - WHERE SERVICE ISN'T BEING SHARED WITH ITS DISTRICTS

*         In the Basic Information section (Block 1), select School District.

*         In Discount Calculation section (Block 4), list the ESD's NIFs (non-instructional buildings), all of the ESD's schools (if they have any) AND all of the schools they service in their ESD's service territory (not districts), as if they were the one giant school district.  The template should list the ESD's BEN in Column A for all entities.  This will correctly calculate the discount rate.

*         In the Funding Request section (Block 5), you should select the ESD's actual buildings receiving the service in Manage Entities.



2)  ESD AS CONSORTIUM LEAD - WHERE ESD HAS SCHOOLS OF ITS OWN

*         In the Basic Information section (Block 1), select Consortium.

*         In Discount Calculation section (Block 4), upload your template where the consortium member's BENs are in Column A and all of the schools associated with that BEN in Columns B and C.  The ESD would be listed as a separate consortium member and would include their NIFs and their ESD's schools.  If the ESD only has a NIF and no schools of its own, see # 3 below for instructions.

*         In the Funding Request section (Block 5), you should select the buildings receiving the service in Manage Entities.  If service is only being delivered a District building (hub site), you should only select those buildings.



3)  ESD AS CONSORTIUM LEAD - WHERE ESD HAS NO SCHOOLS

As it currently stands, the new Form 471 application will not permit the filing of a consortium application in which the ESD is a consortium member but has no schools.  Although not perfect, the following is USAC's guidance on how to file in these situations:

*         In the Basic Information section (Block 1), select Consortium.

*         In Discount Calculation section (Block 4), upload your template where the consortium member's BENs are in Column A and all of the schools associated with that BEN in Columns B and C.  Because the ESD cannot be listed as a NIF-only consortium member, do NOT list the ESD's BEN in Column A, but rather add the ESD's NIFs to one of the school districts on the application.  Be sure to identify it as an ESA under School Attributes.

*         In the Funding Request section (Block 5), the ESD must explain in the Narrative text box of the first FRN which ESD NIF(s) should be a stand-alone entity and with which school district they were placed.  Including the ESD's NIFs in a school district will not affect the discount rate as the NIFs do not have any students and they are not considered in the urban/rural status determination.

*         Using Manage Entities, you should select the buildings receiving the service.  If service is only being delivered to a District building (hub site), you should only select those buildings.


Sabrina Carson
e-Rate Coordinator | Willamette ESD
503.540.4495 - phone | 503.540.2962 - fax
sabrina.carson at wesd.org<mailto:sabrina.carson at wesd.org>
www.wesd.org

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