| Schools and Libraries News
Brief
October 23, 2009
TIP OF THE WEEK: If you are having
trouble completing all of your invoices (BEAR Forms 472 or SPI Forms 474)
for FY2008 recurring services, consider filing an invoice deadline
extension request now. The volume of requests will increase
significantly after the October 28 invoicing deadline.
Commitments for
Funding Years 2009 and 2008
Funding Year
2009. USAC will release FY2009 Wave 25 Funding Commitment
Decision Letters (FCDLs) October 27. This wave includes commitments
for approved Priority 2 requests (Internal Connections and Basic
Maintenance of Internal Connections) at 85% and above. As of October 23,
FY2009 commitments total just under $1.15 billion.
Funding Year
2008. USAC will release FY2008 Wave 71 FCDLs October 28.
This wave includes commitments for approved Priority 2 requests at 88% and
above and denials at 86% and below. As of October 23, FY2008 commitments
total just under $2.35 billion.
On the day the FCDLs
are mailed, you can check to see if you have a commitment by using USAC’s
Automated
Search of Commitments tool.
Equipment
Transfers
Equipment purchased with E-rate discounts cannot be sold, resold, or
transferred for money or any other thing of value. There are two
exceptions to the transfer of equipment:
- If a school or library is temporarily or permanently closed,
equipment purchased with E-rate funds can be transferred to another
eligible entity as long as no money or any other thing of value is
exchanged. You must notify USAC of the transfer if the date of purchase
of the equipment is less than three years ago.
- After three years from the date of purchase, equipment purchased
with E-rate funds can be transferred to another eligible entity as long
as no money or any other thing of value is exchanged. You are not
required to notify USAC of the transfer.
Below we discuss each of these situations in more detail.
Transfers due to school or library closings
Equipment can be transferred from the original entity to another
eligible entity less than three years after the date the equipment was
purchased — even if the receiving entity is at a lower discount level
— if the original entity is temporarily or permanently closed. This
includes equipment serving part of a facility, such as equipment serving
individual classrooms, if that part of the facility is temporarily or
permanently closing. You may not transfer the equipment for money or any
other thing of value.
If such a transfer occurs, USAC must be notified of the transfer.
To do this, mail, fax, or email a letter to USAC that contains
entity and contact information for both the original and the receiving
entity and the date and reason for the transfer. You can find a
complete list of the information you must include in the letter in the Transfers
of Equipment guidance document on the USAC website.
-
Note that moving equipment is not necessarily the same as a
transfer. For example, a school district with an elementary school, a
junior high school, and a high school purchases a router with E-rate
funding to serve all three schools and installs it in the elementary
school. After a year, the district decides that the router should
be moved to the high school to better serve those three schools. As long
as the router continues to serve the same recipients of service, no
transfer has taken place.
Transfers after three years
Starting three years after the date of purchase of E-rate funded
equipment, an entity may transfer that equipment to another eligible
entity as long as no money or any other thing of value is
exchanged. The receiving entity can be at a lower discount level, and
it does not have to appear on the Block 4 worksheet associated with the
funding request. For example, a school at a 90% discount level can, after
three years, transfer a piece of E-rate funded equipment to a library at a
20% discount level that has never before applied for Internal
Connections.
If the transferred equipment was purchased at least three years ago,
you do not have to notify USAC of the transfer.
Transfers of equipment and the Two-in-Five Rule
When you submit a Form 471 Block 5 funding request for a shared
service, you identify the entity or entities that will be receiving the
service in Item 22 of the funding request. If USAC makes a commitment
on an Internal Connections funding request, the entity or entities
identified in Item 22 of that funding request are considered to have used
a year under the Two-in-Five
Rule. (This rule limits the receipt of Internal Connections to two
years in any five-year period, starting with FY2005.)
If an entity transfers equipment to another entity, the receiving
entity is not considered to have used a year under the Two-in-Five Rule.
The original entity, however, retains its status under the Two-in-Five
Rule – that is, USAC still considers it to have used a year of Internal
Connections even though it no longer has the equipment.
Record retention requirements
When equipment is transferred from one entity to another, both the
transferor and the recipient must maintain complete records of the
transfer - including the notification to USAC of an equipment transfer due
to the closing of a facility - and retain these records for at least five
years after the last date to receive service on the associated Funding
Request Number (FRN). In particular, the asset registers or other
inventory tracking mechanisms of both entities should feature information
on the transfer of the equipment and reflect the new location of the
equipment.
Disposal or trade-in of equipment
As indicated
above, equipment purchased with E-rate funds cannot be sold, resold,
or transferred for money or any other thing of value. Outdated
equipment and equipment that is no longer being used are still
subject to this requirement.
As with other changes
in status, disposal or trade-in of equipment should be carefully recorded
on your asset register and inventory tracking documents. Any documentation
related to the disposal or trade-in should also be retained.
See Transfers
of Equipment for more detailed guidance on equipment transfers.
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