The Dirty Dozen: Top 12 Mistakes to Avoid This E-Rate Season


The E-Rate Program provides discounts on IT and telecom services and equipment for schools and libraries.

Recently, I attended a training session conducted by the Universal Service Administrative Company (USAC), the organization responsible for administering the E-Rate program. The training provided updates on the program and included a great session with tips on how to avoid the top twelve mistakes that are commonly made during the E-Rate application process.

  1. Submitting paper forms containing errors. If you can complete your application online, that’s really your best bet for smooth application process. But if you need to submit paper forms, it’s important to pay close attention to each required form in order to avoid delays or potential errors. Review each form for accuracy before submitting, and refer back to the source documents as you complete them (Funding Commitment Decision Letter, FCC Form 486 Notification Letter, etc.).
  2. Missing deadlines. Most of the E-Rate forms have deadlines for submission, and missing one of those dates can result in a denial of funding. Mark your calendars—don’t wait until the last minute to file forms, submit requests or respond to questions. By tracking upcoming deadlines year-round, you’ll have a better handle on those critical dates.
  3. Not following competitive bidding rules. By posting a Form 470, you’re opening the competitive bidding process—one that’s governed by strict program rules. To avoid violations and funding denials, make sure to review the competitive bidding and bid evaluation guidelines and documents available on the USAC website to allow for an open and fair bidding process.
  4. Not communicating with service providers after the competitive bidding process. Communication with service providers after the competitive bidding window closes is crucial for a successful E-Rate application process. USAC offers many tools to help you find the information you need (SPIN information, contact information for your service provider, application status, etc). Make sure to review all contract documents to ensure that service delivery, solutions and invoicing all are finalized before the annual filing process ends.
  5. Mixed bucket funding requests. Combining Priority 1 (telecom services and Internet access) and Priority 2 (Internal Connections and Basic Maintenance) on the same funding request or application can cause delays in the funding approval process, since Priority 2 requests are last in line for funding consideration. Review the Eligible Services List for the applicable funding year to understand the products and services that are considered Priority 1 and Priority 2; then be sure to file the correct forms for the services selected.
  6. Incorrect discount calculations. The discount review process carefully calculates based on documentation you provide and school and library data. Poor documentation or incorrect or outdated data can delay funding decisions. Reviewing the “Calculating Discounts” guide can provide a better understanding of how discounts are calculated and the documentation required when submitting.
  7. Incomplete PIA responses. E-Rate’s Program Integrity Assurance (PIA) team reviews all applications for compliance. Lack of or incomplete responses to PIA questions will result in a funding decision based solely on the initial information provided. Review all PIA email questions carefully. If you fully understand, respond quickly, but if you don’t—contact the initial reviewer immediately. They’ll help clear up any confusion.
  8. Missing or incomplete Item 21 attachments. Item 21 Attachments provide a detailed description of the services in each funding request. A Form 471 is considered incomplete until the Item 21 Attachment is submitted. Carefully follow the Item 21 Attachment guide to make sure you’ve got everything you need before submitting.
  9. Ignoring USAC letters. Each time you file an E-Rate form, USAC responds with a letter, containing helpful information and next-steps. To put it simply—just read anything you receive from USAC—even if you’ve already seen it, it can’t hurt to review one more time.
  10. Poor invoicing practices. USAC must be invoiced through the applicant Form 472 (BEAR) or service provider Form 474 (SPI Form) for discounts on services actually delivered and installed. To avoid common mistakes during the invoicing process, review the guidelines, check and double-check your work, and submit your invoices on time.
  11. Inadequate document retention. E-Rate has strict document retention requirements. Failure to retain documents for the required period (a minimum of five years from the last service delivery date) may result in funding reductions, denials, adjusted service start dates, invoice rejections or commitment adjustments. Hang on to all forms, invoices, contracts, emails— anything that pertains to E-Rate and your organization.
  12. Not managing your own E-Rate process. The best way to avoid mistakes throughout the entire E-Rate process is to manage every phase very closely. By understanding the process, you can prepare the proper forms accurately, respond to questions quickly, be on top of upcoming deadlines, and prepare documentation for potential audits. Make a checklist, keep a separate calendar, set reminder alarms, attend monthly USAC calls—do whatever it takes to organize a successful E-Rate year for your school or library. 

And one of the best ways to avoid any confusion surrounding E-Rate is to maintain communication with your USAC representative and contract with a service provider who knows the program inside and out. Windstream’s smart solutions, personalized service for K-12 schools and libraries, combined with our successful history as an approved E-Rate service provider, can help you learn to avoid the “E-Rate Dirty Dozen.” Contact one of our trusted E-Rate Advisors today to learn more.

(PS – don’t forget to take our quick E-Rate survey, if you haven’t had a chance to already!)