Background

The only way an E-rate applicant can submit a Form 471 without first competitively bidding the E-rate eligible service/item using a Form 470 is when another entity submits the 470 on the applicant’s behalf. Such is the situation with the state's PEPPM contract for internal connections and maintenance (www.peppm.org/pa/default.htm).  The PA Department of Education files Form 470s to align the E-rate competitive bidding process with the official procurement process for the state PEPPM contracts.

Schools (both public and nonpublic) and libraries that would like to purchase and take receipt of an E-rate eligible item from PEPPM on or after July 1, 2013 may simply file one form, the Form 471. The Form 471 filing window is currently open and Form 471 applications may be submitted on or after that date. The final day that applications can be postmarked or submitted and certified online for Funding Year 2013 is March 14, 2013. The pertinent E-rate information needed for the Form 471, Block 5 can be accessed by clicking on the PEPPM Product List and E-rate Contact Information link at the bottom of the page.

In the cases where PEPPM is being used, the SLD does not require a separate contract or purchase order to be issued before the 471 is filed because the PEPPM contract IS the contract. Therefore all of the information below is based on the PEPPM contract, not on your local contracts/purchase orders. Purchase orders, however, must be issued in order to actually order the products (on or after July 1, 2013).

New Requirement: If you are purchasing from PEPPM, you must obtain a vendor quote (including vendor’s letterhead or logo) before submitting your Form 471. This document then can be used as your Item 21 attachment. PIA reviewers will request to see vendor documentation dated before your Form 471 submission date.

Important Requirement:  PEPPM Mini-Bids

If the ordering instructions for your desired product line permit you to purchase from more than one reseller, you are required to conduct what the SLD refers to as a ‘mini-bid’ since more than one vendor qualifies to provide you with that product or service.

In the case of a PEPPM mini-bid, applicants should minimally document two evaluation criteria. The first, and most heavily weighted factor must be price.

The second criteria may be any other factor that is relevant to why you chose a particular vendor. For example, you may have done prior business with a particular vendor and they know and understand your infrastructure or billing systems well. Or one particular vendor is the closest in proximity to your school. Or you have references from other districts that signal one vendor is better to work with than another. Whatever the reason, you need to document it so that if asked by the SLD or by an auditor, you can easily answer and remember why you legitimately selected one vendor over another.

Purchase Orders for PEPPM Purchases

If your purchase is contingent on E-rate funding, a purchase order should be faxed AFTER your funding commitment decision has been made by the SLD, or after July 1, 2013, whichever is later. If you would like to purchase equipment regardless of E-rate approval, you should submit your purchase order to PEPPM anytime after July 1, 2013. When your E-rate approval is received later, you can then simply seek reimbursement using a BEAR form.

The purchase order should be for the full amount of the equipment, not for the E-rate non-discounted amount. Further, the P.O. should clearly state that this is an E-rate item, and include the Funding Request Number (FRN) pertaining to that piece of equipment. In addition, if the P.O. is issued after a funding commitment decision is issued by the SLD, the P.O. should specifically state whether you would like to receive a discounted invoice (where you would just pay the non-discounted portion and the vendor would seek reimbursement from the SLD).

Using PEPPM After Posting Your Own 470:

If you posted your own 470 for equipment and are purchasing that equipment from PEPPM, you must have a binding contract -- signed by both parties -- before submitting the 471 (this can be a PO signed by the District and the vendor, listing that it will not be effective until at least July 1, 2013) or it can be a memo signed by both parties, listing the equipment, quantities, prices, and effective dates. Essentially, the SLD believes that if you post your own 470, you are taking the PEPPM contract price as one of the bids, which is different than relying on the PEPPM contract entirely.

Applicants should complete the Form 471 online (www.sl.universalservice.org/menu.asp) using the “Create Form 471” option. Assistance with filing the Form 471 for PEPPM 2012 items will be provided by Central Susquehanna Intermediate Unit staff by calling (570) 523-1155 ext. 2144.

Important:

Products may have different Contract Award Dates. It is very important to use the correct information when filing your Form 471. How will you know which information to use? Click on the PEPPM Product List and E-rate Contact Information link below. Find your product line in the table and click the Product's name. The correct information to be used in the Form 471, Block 5 will be displayed.