Demonstrating Compliance with Program Rules
The Universal Service Administrative Company conducts audits of beneficiaries
under the Schools & Libraries Support Mechanism, as well as beneficiaries
under other Universal Service Support Mechanisms. In the Schools and Libraries
case, "beneficiaries" can be recipients of service, Form 470 applicants,
or Billed Entities; they may assume more than one of these roles during the
course of the application process. The following practices have been identified
during these beneficiary audits as being important for: (1) successful completion
of the application process, (2) compliance with program rules during the period
of service delivery and invoicing, and (3) the ability to demonstrate compliance
with program rules in a beneficiary audit.
The Schools and Libraries Division urges beneficiaries to incorporate these
practices in their participation in the Schools and Libraries Support Mechanism.
- Establish a Technology Plan using staff expertise or an outside technology
expert. Update the plan on an ongoing basis. The Plan should include, but
not be limited to, the following:
- Clear goals and a realistic strategy for achieving those goals
- A professional development strategy to ensure that staff know how to use
these new technologies to improve education or library services
- An assessment of the telecommunication services, hardware, software, and
other services that will be needed to improve education or library services
- A detailed budget which supports the Plan and features the acquisition and
maintenance of equipment, staff training and other needs addressed in the
- Methods for evaluating the progress of the Plan and for making changes or
corrections to the strategy outlined in the original Plan in response to new
developments and opportunities, including a description of the approval process
for such changes and corrections.
- Designate a specific individual to be responsible for oversight of the E-rate
application process in order to take accountability and responsibility to
ensure that it is accurate and that the equipment and services are eligible
for funding. Ideally, this person should also be the contact person listed
on forms filed with SLD.
- Maintain a file of the Form 470 and Form 471 applications. This file should
include, but not be limited to, the following:
- A copy of the Form 470 application
- A copy of the Form 471 application
- Request For Proposal, if applicable
- Copies of all bids
- Documentation on the award process and the rationale for the bid award
- Copies of all related contracts
- Copies of all service provider invoices
- Copy of the board resolution for any contract award
- Maintain a log of all communications with SLD. This includes communication
between SLD and any contact person who is not the responsible individual.
Each entry should include the name of the person who placed the call, the
time of the call, the name of the person who responded, and the substance
of the communication.
- Maintain an updated list or file of the status of all work, in order to
monitor both the progress of the project and the expenditure of approved funds
related to the project.
- Maintain and update detailed asset registers (including make, model, serial
number, and location) for all sites to facilitate the tracking of equipment
purchased with E-rate funds. In addition, diagrams that clearly show how equipment
is actually connected and used should become part of the registers if those
diagrams are available.
- If the applicant seeks reimbursement via the Form 472, review and approve
the form to ensure that the work has been completed, that the service providerís
bill has been paid in full, and that the reimbursement amount requested is
- Alternatively, if not filing Forms 472 for reimbursement, review the Quarterly
Disbursement Report provided by the Schools and Libraries Division to ensure
any payments to service providers are consistent with work actually performed
and discounts provided on bills received.
- Maintain a file for each Form 472 (BEAR) submitted to SLD. This file should
contain a completed copy of the Form (including the signature of the Service
Provider) and all supporting documentation.
- Maintain a spreadsheet which tracks either the Form 472 (BEAR) requests
for reimbursement or the discounts (in the form of discounts on bills, checks,
or credits) provided by the Service Provider to ensure the committed amount
on the FRN(s) has not been exceeded.
- Verify ó either through an approved internal process or by an independent
third party: that all work has been completed and that all equipment is operating
USAC has created a suggested Compliance
Documentation Checklist that applicants can use to track their collection
of documentation about the process of applying for, using, and invoicing of
Schools and Libraries discounts.
Content Last Modified: November 6, 2001