28-Day Waiting Period

The Federal Communications Commission’s (FCC) rules require applicants to wait at least 28 days after their FCC Form 470 is certified in the E-Rate Productivity Center (EPC) before selecting a service provider, executing any contracts for contracted services, or signing and submitting an FCC Form 471. The minimum 28-day waiting period is tracked automatically in EPC. 

Calculating the Waiting Period 

The waiting period starts the calendar day (including weekends and holidays) you certify your FCC Form 470. The day you certify the form is day one. For example, if you certify on 1/1/2024, your Allowable Contract Date is 1/29/2024. The Allowable Contract Date (ACD) is the earliest date on which an applicant can sign a contract for contracted services or enter into an arrangement for tariffed (T) or month-to-month (MTM) services with a service provider.  

Please refer to the infographic below for further clarification: 

This image provides a visual example of the 28-day waiting period, explaining that the day you certify your FCC Form 470 is day 1, and the 29^th day is the Allowable Contract Date (ACD).

Setting a Bid Deadline 

Applicants can select a service provider after the 28-day waiting period unless your FCC Form 470 lists a later bid deadline. ​Applicants may set a later bid deadline by including it in their FCC Form 470 narrative or their request for proposals (RFP). This deadline must be at least 28 days after certifying their FCC Form 470 or longer depending on your state or local procurement rules or regulations. If applicants do not add a deadline to their narrative or RFP, they should consider all bids received until applicants evaluate bids and make a vendor selection. Any deadlines should be memorialized in applicants’ records. 

Applicants may correct errors and modify their FCC Form 470, but only minor changes can be made without extending the original 28-day waiting period. Beginning in Funding Year 2025, if applicants wish to make any substantive corrections, they can attach a new RFP document to their certified FCC Form 470, and the new 28-day waiting period will be recalculated automatically in EPC. See the Modifications to the FCC Form 470 and FCC Form 471 page for more information. 

Automated, SPAM Bids, or Bids Received after the 28-Day Period

FCC rules require that applicants carefully consider all bids received before they start their bid evaluation process, even if the minimum 28-day waiting period has lapsed.  Applicants should consider all bids received up until they begin consideration, unless they provided a specific bid submission deadline and noted that bids received after the deadline would be disqualified on the FCC Form 470 or RFP document.

However, applicants do not need to consider automated or SPAM bids that do not include pricing information or require the applicant to contact the solicitor to request pricing. These types of bids can be disqualified as non-responsive even if the applicant does not state in the FCC Form 470 that pricing information is specifically required. The applicant should still retain the bid response and note why the response was disqualified and not evaluated.