Schools and Libraries

Step 7: Item 21 Attachments for Form 471

Each funding request on the Services Ordered and Certification Form (Form 471) must include a description of the products and services for which discounts are sought.

This page provides information on:

Each Form 471 Block 5 funding request must include a separate description of the products and services for which discounts are being sought. This description is known as an "Item 21 Attachment."

Clear and complete Item 21 Attachments allow an efficient review of funding requests so that prompt funding decisions can be made. Incomplete or unclear Item 21 Attachments may delay the issuance of an applicant’s funding commitment.

1. Item 21 Attachment Overview

Several different formats are possible for the Item 21 Attachments. However, the Item 21 Attachments generally consists of these parts:

  • Narrative overview or description
  • Line item detail  and cost associated with the eligible and ineligible products and services requested
  • Any additional details, if needed, such as equipment locations or other information to support the funding request

Applicants often receive the assistance of service providers in creating the Item 21 Attachments, which can be one or more of the following:

  • An online submission
  • Applicant-provided documentation
  • A quote or bill from the vendor
  • A copy of the contract for the service

Narrative description.  The narrative description should be a summary that allows USAC to understand the objective of the funding request.  For example:

  • "Additional email servers for three locations"
  • "Internet access for new library branch"
  • "New data distribution equipment to replace old equipment"

Line item detail.  Regardless of the specific format used, the Item 21 Attachment should include the following type of information:


Quantity

Product or Service Description

Total Unit Cost

Extended Pre-discount Cost

Extended Ineligible  Pre-discount Cost

  

Eligible Recurring

Eligible Non-Recurring

Ineligible Recurring Cost

Ineligible Non-recurring cost

             
             
             

Grand total 

            

Additional details.  Products and services that can be supported under the Schools and Libraries Program are "conditionally eligible," which means that they are eligible for support if used or functions in certain ways.  The Item 21 Attachments are the applicant's opportunity to provide sufficient information so that USAC can make a determination about whether the applicant's proposal meets FCC eligibility rules. See the Eligible Services List.

Location information - Internal Connections.  The instructions for Form 471 indicate that internal connections funding requests must include information about where the physical components will be located.  This is often the same as the location of entities that are receiving service, as indicated in Block 4 of Form 471. In some cases, components can be installed in a location different than the entity receiving service, such as when components are located at a district office but serve the needs of one or more separate schools.  Examples of information that specify the physical location of internal connections products could be:

  • "One router and associated components per school"
  • "All equipment to be located at District Office"
  • "Components to be located at entity number 12345"
  • "One file server will be located at each location specified in Block 4, except three file servers will be installed at entity number 12345"

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2. Item 21 Attachment Examples

The examples below provide acceptable layouts and relevant information for the Item 21 Attachment.

Submit a representative telephone bill.   In addition to the above examples, an applicant may submit a previous, representative bill for telephone services or may include a listing of the previous year's charges in order to substantiate these charges for the next funding year.  To avoid delays in the review of your application, please ensure that the type of service is specified on your bill (local, long distance, cellular service etc.) and the number of phone lines is given.  This information may be handwritten on the bill by the applicant if it does not already appear. View an Item 21 Attachment that is based on a representative previous phone bill.

Any ineligible components of the phone bill (such as extra costs for an unlisted number) must be removed from the funding request. Any funding requests greater than that indicated by the historical information submitted must be justified with specific information, such as: "Two additional phone lines are being installed."  General information, such as "anticipated growth" is insufficient unless accompanied by specific and verifiable rationale.  If 30% or more of the items requested are ineligible, the entire cost may be denied. See Funding Requests Containing Ineligible Products and Services (the 30% Rule).
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3. Additional Information to Include in Item 21 Attachments

The previous examples illustrate relatively straightforward funding requests. Additional information is useful or necessary in many cases.

For example, the following information submitted without further details would NOT be sufficient for USAC to make a positive funding determination:


Example of INSUFFICIENT INFORMATION:


(5) routers @ $16,000 each
Technical services for above products @ $48,000

In this example, USAC would need to request further information about the specific products (make and model) being purchased and the details of the requested technical services. USAC also may request copies of vendor quotations, a specific listing of the modules or specifications for a product, and/or copies of contracts.

For example, make sure you specify the bandwidth on all Internet Access FRN’s (e.g., T-1, T-3, DS-1, etc.).  Also, if any of your FRN’s include web hosting, please include third party documentation that sufficiently describes the exact services that are being provided as part of the web hosting service.  Applicants should check the Eligible Services List and other documents available on the USAC website to understand the eligibility requirements for the products and services being requested. The most complete Item 21 Attachments will indicate compliance with the conditions of eligibility as indicated in the Eligible Services List. For example:

  • "The Web hosting service has cost allocated x% to remove the ineligible content creation tools/services."
  • "The memory upgrade requested will be installed in an eligible email server."
  • "The multiple T-1 lines are not redundant or duplicative and are required for the bandwidth needs of the applicant."
  • "The training requested consists of basic instruction in the use of eligible equipment.  It is directly associated with the purchase of this equipment and is part of the same contract.  No end-user training is being provided."

Also, if any portion of your phone bill or other vendor documentation submitted with your Item 21 Attachments includes “miscellaneous charges”, please provide an explanation of what these charges are (e.g., wiring jacks, faceplates, taxes, or required fees).  In addition, if there are any charges on your Item 21 Attachments related to “training,” please provide a detailed explanation as to what the training involves.  For example, please explain who in your organization will be receiving the training, what exactly they’ll be getting trained on, and when the training will occur.  Providing USAC with this information up front will reduce the likelihood of you having to be contacted by a PIA reviewer.

In addition, if ineligible components or features are provided that require cost allocation, the Item 21 Attachment should include appropriate details to allow efficient review. See Cost Allocation Guidelines for Products and Services. View an Item 21 Attachment that includes a subtraction for ineligible functionality.
USAC's review process also requires further information when funding requests include the following components or configurations:

For example, if you are requesting a PBX system or other internal connections components, please make sure to include the list of components that make up the PBX along with the appropriate make and model numbers.  Also, if you are ordering server racks or equipment cabinets, please specify the make and model of the server or equipment being housed in the racks or cabinets and the intended use of the server or equipment.

The Appendix below provides suggestions for information to include in Item 21 Attachments when any of the above functions or features is included.
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4. How to File the Item 21 Attachment

An online system is available for creating and submitting Item 21 Attachments. (In the menu of choices for Form 471, choose "Item 21 Attachment."). A training site for this system is also available. Alternatively, the Item 21 Attachment can be manually submitted to USAC by email, fax, U.S. mail, courier, or as part of a Form 471 application or Form 471 Block 6 Certification submitted on paper.  It is preferable for you to use no more than one of these methods to submit your Item 21 Attachments.  For example, if you submit both an online and paper Item 21 Attachment but there are differences between the two documents with regard to items, cost or ineligibles, the processing of your application will be delayed.

The attachment should include this information:

  • A label of "Form 471 Item 21 Attachment"
  • The applicant's name
  • The Attachment Number specified for the Item 21 Attachment in the Form 471, Block 5

If the Item 21 Attachment is being submitted separately from the Form 471, then the attachment or a cover letter must also include:

  • The applicant's Billed Entity Number
  • The Form 471 application number if one was assigned through electronic filing or the Form 471 Applicant Form Identifier if the Form 471 was filed on paper

The Item 21 Attachment must be received before USAC can begin review of a Form 471 application.  While the Item 21 Attachment does not need to be submitted within the Form 471 filing window, it must be filed in a timely fashion so that USAC can review the information, make a determination of product and service eligibility, and provide a prompt funding decision.

If at the time of application review, the reviewer fails to see that an Item 21 Attachment has been filed, they may contact the applicant and request that this information be provided via the online system, or directly to the reviewer by email or fax. In other cases, manually filed Item 21 Attachments should be submitted in either of the following ways.

Send submissions via email. Do not send submissions other than Form 471 Item 21 Attachments to this email address. Documents may be sent in most commercially available word processing or spreadsheet formats. Scanned documents may also be sent. (TIF file format is preferred.) Total file size of the email message must be less than 10 Megabytes. If you have more than one Form 471 application, do not combine Item 21 Attachments from other Form 471 applications in the same email message.

Send submissions via fax to (973) 599-6511. Do not send submissions other than Form 471 Item 21 Attachments to this fax number.

Send submissions via USPS to SLD Forms, Form 471-Item 21 Attachment, P.O. Box 7026, Lawrence, KS 66044-7026. For courier delivery services or U.S. Postal Service Return Receipt Requested, send to SLD Forms, ATTN: Form 471-Item 21 Attachment, 3833 Greenway Drive, Lawrence, KS 66046, Phone 1-888-203-8100.

All certifications provided as a part of the Form 471 also apply to the Item 21 Attachment including certifications of compliance with state and local procurement laws and compliance with Schools and Libraries Program rules. Misrepresentations on the Item 21 Attachment can result in administrative and criminal penalties described in Form 471 Block 6 Certifications.

USAC reiterates that the applicant certifies as a part of the Form 471 that: (1) resources to use the services effectively have been secured (Form 471, Block 6, Item 25), and (2) all required documents will be retained for a period of at least five years after the last day of service delivery (Form 471, Block 6, Item 32).

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5. Appendix: Further Examples of Additional Information

The following examples describe particular cases where further information should be supplied with Item 21 Attachments.

Network file servers.  The eligibility of network file servers depends on the use of the servers.

Therefore, USAC will not approve funding requests for file servers unless the specific use(s) of the file servers are detailed (e.g., network, email, web, etc.) and the make and model are provided.  In addition, file server costs should be allocated appropriately between eligible and any ineligible uses.  The Eligible Services List provides additional information about the eligible and ineligible uses of file servers.

Amortization of up-front capital costs. For projects that have service provider infrastructure with up-front capital costs greater than $500,000, the initial capital costs must be amortized over at least a three-year period. View an Item 21 Attachment that shows the amortization of capital costs.

The use of Schools and Libraries support for the build out of a service provider's infrastructure is limited. The FCC has recognized that some business arrangements between an applicant and service provider, even if labeled a lease of services, can reach essentially the same result as a prohibited WAN purchase by applicants. USAC will not commit to support on such arrangements. Further information about relevant program rules may be found in the Wide Area Network (WAN) Fact Sheet.

On-premise Priority 1 equipment. In limited circumstances, some types of equipment located at the applicant site can be funded as a part of an "end-to-end" telecommunications or Internet access service. Depending on the complexity of the request, the Item 21 Attachment for such funding requests may consist of two to four components:

  • The listing of products and services that make up the request. This should include a specification of the components that will be located at the applicant site and a narrative overview of the funding request.
  • A statement indicating whether or not there is compliance with each of the several conditions for on-premise Priority 1 equipment.
  • When not otherwise clear from other information provided, a calculation that shows whether or not up-front capital charges of on-site components are less than 67% of total charges requested.
  • For situations in which the equipment configuration is not clear from other information submitted, a network diagram may be required that shows how the components are interconnected with an applicant's internal connections components.

In cases where the above information is not provided, USAC may request further information during review of the application. View an Item 21 Attachment that specifies on-premise Priority 1 components. For further information, including examples of configuration diagrams, see On-Premise Priority 1 Equipment.
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Last modified on 2/22/2008