Step 2 Competitive Bidding

Ministerial & Clerical Errors

Ministerial and clerical (M&C) errors are defined as data entry errors or mistakes applicants made on the FCC Form 470 or FCC Form 471. “Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error.” (Order FCC 11-60, released April 14, 2011). USAC can process requests to correct M&C errors up until the time that a Funding Commitment Decision Letter (FCDL) is issued.

For information on submitting late form certifications, refer to the Missing or Late Certifications page on this website.

Allowable & Non-Allowable Corrections

USAC can process allowable corrections to M&C errors, and the applicant does not need to file a new form. See below for examples of allowable corrections.

Applicants must file a new form to correct non-allowable corrections. See below for examples of non-allowable corrections. Remember that, if you must file a new form, your new form must still meet program deadlines.

• A new FCC Form 470 must be posted for at least 28 days before the close of the filing window because the applicant must wait at least 28 days before closing its competitive bidding process, selecting the most cost-effective bid, signing a contract (if applicable), and signing and submitting an FCC Form 471.
• A new FCC Form 471 must be filed before the close of the application filing window to be considered as timely filed.

Program Integrity Assurance (PIA) processes requests for allowable corrections to FCC Forms 470 and 471. In many cases, the PIA reviewer can determine whether the correction is allowable and, if so, complete the correction without requesting additional information. However when the nature of the correction is not apparent to the PIA reviewer, the PIA reviewer may request the appropriate source documentation to determine whether the correction is allowable. Source documentation is the documentation containing the information used to prepare the form (e.g., Item 21 Attachment, contract, vendor quote, NSLP data, etc.).

During PIA review, you will be informed if your FCC Form 471 correction was allowable and if it was processed. The FCDL comment for each Funding Request Number (FRN) will also contain this information.

Examples of Corrections

Allowable Corrections

• Spelling errors
• Simple addition, subtraction, multiplication or division errors
• Transposed letters and/or numbers
• Misplaced decimal points
• Other punctuation marks (hyphens, periods, commas, etc.) included or not included or misplaced
• Failing to enter an item from the source list (e.g., NSLP data, uploaded Block 4 data, FRN, etc.)
• Incorrect citations such as:
• FCC Form 470 number
• Discount percent
• Urban/rural status
• Contract number
• Billing Account Number/Multiple Billing Account Numbers
• FCC Form 471 Block 4 worksheet entries
• Updates or changes to contact person and/or consultant information
• Errors in dollars figures on an FRN
• Adding or removing entities accidentally omitted or included in FCC Form 471 Block 4
• Accidental omission of FRNs from the FCC Form 471
• Changing the amount budgeted for ineligible services (Item 25d, “necessary resources”) in FCC Form 471 Block 6
• Changing the service delivery time period (e.g., month-to-month to contractual, recurring to non-recurring)
• Mis-keying the Service Provider Identification Number (SPIN) or Service Provider Name
• Corrective SPIN changes
• Correcting the annual charges for recurring charges
• Incorrectly identifying ineligible charges and/or services or products

Additional allowable corrections can be found in the FCC’s Order DA 10-2354, released December 16, 2010.

Non-allowable Corrections

• Operational SPIN changes
• Changes to the services on the Item 21 attachment and FCC Form 471 Block 5 that are not a result of an M&C error (e.g., renegotiated contract terms or pricing)
• Adding an entity to Block 4 that was not listed in the original source document
• Revising NSLP data dated after the close of the filing window
• Adding a category or categories of service on the FCC Form 470 after it has been posted
• Adding new services or changing service descriptions on FCC Forms 470 and/or RFPs after the forms have been posted
• Changes based on vendor documentation that was not used in the applicant’s competitive bidding process or that is dated after the close of the filing window

Submitting Corrections

Requests to correct M&C errors should be submitted to USAC as soon as the errors are detected by the applicant. USAC will accept and process requests until an FCDL is issued. To request a correction, follow the submission instructions on the letters listed below.

FCC Form 470 corrections can be submitted via Receipt Notification Letter (RNL). Always include a signed and dated copy of page 3 of your RNL together with your FCC Form 470 application number, billed entity name, Billed Entity Number (BEN), and your name and contact information (email, fax, and/or phone).

To email corrections, scan the appropriate pages of the RNL and email the resulting document to USAC.

To fax corrections, use the following fax number:
(973) 599-6526

To mail corrections, use the following address:
RNL Corrections
Schools and Libraries - Correspondence Unit
30 Lanidex Plaza West
PO Box 685
Parsippany, NJ 07054-0685

FCC Form 471 corrections can be submitted via Receipt Acknowledgment Letter (RAL) and/or during PIA review. Always include a signed and dated copy of page 3 of your RAL together with your FCC Form 471 application number, billed entity name, Billed Entity Number (BEN), and your name and contact information (email, fax, and/or phone). You can also submit corrections during PIA review.

To email corrections, scan the appropriate page(s) of the RAL. Go to Submit a Question and follow these steps:

• Click “Continue.”
• Under “Topic Inquiry” choose “Other” and click “Go.”
• Choose “Other” and click “Continue.”
• Complete your contact information.
• Select the “Yes” radio button to indicate you want to submit an attachment.

USAC will send you a reply email. Follow the instructions in that email to attach your scanned document and submit it to USAC.

To fax corrections, use the following fax number:
(973) 599-6526

To mail corrections, use the following address:
RAL Corrections
Schools and Libraries - Correspondence Unit
30 Lanidex Plaza West
PO Box 685
Parsippany, NJ 07054-0685

PIA Detected Errors

Your PIA reviewer may detect a discrepancy between your FCC Form 471 and your source documentation (e.g., your Item 21 attachment or other source documentation provided during review). If so, your PIA reviewer will ask if you would like to make a correction to the application and give you 15 days to respond. Remember that if you do not respond within the 15 days, PIA will process your application with the information available which may result in a reduction or denial of funding.