Ministerial & Clerical Errors
Applicants occasionally make data entry and other similar ministerial and clerical (M&C) errors on an FCC Form 470 or FCC Form 471. Applicants are generally allowed to contact USAC to correct those errors when they discover them unless the correction on the FCC Form 470 would materially affect the competitive bidding process. If the applicant wishes to make a correction to their FCC Form 470 that materially affects the competitive bidding process, they must file a corrected FCC Form 470 and restart the 28-day waiting period.
FCC Form 470 Corrections
Applicants that want to correct M&C errors that WILL NOT materially affect the competitive bidding process, need NOT file a new form and start a new 28-day waiting period. These allowable changes include:
- Editing an application name
- Changing the main contact person and/or technical contact person
- Making minor, non-substantive updates to a request for proposal (RFP) *
Requests to correct these types of FCC Form 470 M&C errors should be submitted to USAC using the E-Rate Productivity Center (EPC) as soon as the applicant detects the error. To request an FCC Form 470 correction, follow the submission instructions in the FCC Form 470 User Guide.
* Note: Changes to the FCC Form 470 beyond the allowable changes require applicants to wait 28 days from the date of the change to close the competitive bidding process.
Requirement to File New FCC Form 470
Applicants that want to correct M&C errors that materially affect the competitive bidding process MUST file a new FCC Form 470 and start a new 28-day waiting period. Corrections that require filing a new FCC Form 470 include:
- Adding a category of service to an FCC Form 470 after it has been posted
- Adding new services or changing service descriptions on FCC Form 470s or RFPs after the FCC Form 470 has been posted*
- Adding or subtracting a significant number of recipients of service listed on the FCC Form 470 after it was posted
* Note: The FCC Form 470 is the formative document of the competitive bidding process so applicants should align the service request information in their RFP with the indicated service selections indicated on the FCC Form 470.
FCC Form 471 Corrections
The type of errors that applicants may correct on their FCC Form 471 include:
- Spelling errors and transposed letters and numbers
- Simple addition, subtraction, multiplication or division errors, misplaced decimal points
- Punctuation marks (e.g., periods, commas) that were included, omitted or misplaced
- Incorrect citations such as:
- FCC Form 470 number
- Contract number
- Billing Account Number/Multiple Billing Account Numbers
- FCC Form 471 Recipient of Service entity numbers
- Contact person and/or consultant information
- Dollar figures copied incorrectly from contracts
- Incorrect identification of ineligible charges and services or products
- Incorrect amount budgeted for ineligible services in FCC Form 471 Certification: Total Funding Summary
- Incorrect service delivery time period (e.g., month-to-month to contractual, recurring to non-recurring)
- Incorrect service provider name or Service Provider Identification Number (SPIN), also known as the service provider’s 498 ID Errors that require Corrective SPIN changes
- Mischaracterizing non-recurring charges as recurring charges
Additional allowable corrections are discussed in the FCC’s Order DA 10-2354, released December 16, 2010.
Applicants can submit FCC Form 471 corrections in EPC using the Receipt Acknowledgment Letter (RAL) modification process or during Program Integrity Assurance (PIA) review. Please view the FCC Form 471 Receipt Acknowledgment Letter Modification Guide for more information. You will be informed in your Funding Commitment Decision Letter (FCDL) if your FCC Form 471 RAL modification request was approved.
FCC Form 471 errors that do NOT qualify as M&C errors:
- Underestimates of the quantities of services needed
- Services omitted due to a failure to recognize a need prior to filing one’s FCC Form 471
- Errors requiring Operational SPIN changes
- Changes to the services on the FCC Form 471 funding request (e.g., renegotiated contract terms or pricing)
- Omitting an entity from the discount calculation if it was not listed in the original source document
- Revising National School Lunch Program (NSLP) data dated after the close of the filing window
- Changes based on service provider documentation that is dated after the close of the filing window
Errors Detected During PIA Review
Your PIA reviewer may detect a discrepancy between your FCC Form 471 and the provided source documentation (e.g., contract) during the review of your application. If so, your PIA reviewer will ask if you would like to correct the application and will provide you 15 days to respond.
If you do not respond within the allotted 15 days, your reviewer will process your application with the information available, potentially resulting in a reduction or denial of funding.