The E-Rate program rules require that a consortium members have a signed letter of agency (LOA) with the consortium lead that authorizes the consortium lead to take specific actions on behalf of each consortium member. The letter of agency should be tailored to accurately describe what specific actions the consortium lead may take on behalf of the consortium members (e.g., file the FCC Form 470, conduct competitive bidding reviews, request funding, and/or invoice) and that the consortium member is eligible to participate in the E-Rate program and will comply with the E-Rate program rules. More details about the LOA and a sample LOA are available here.
Yes. A consortium could file an FCC Form 470 on behalf of its members and assist its members in selecting the most cost-effective services, but then the members themselves could sign contracts and file the FCC Form 471 requesting funding. The consortium lead and the consortium members should discuss how they wish to set up their consortium and what roles and responsibilities the different parties will have.
Yes, please use the Bulk Entity Creation Template to compile all of your entity information, call the Customer Service Center (CSC) at (888) 203-8100 to create a ticket, and follow the instructions provided by CSC to submit the spreadsheet. If Tribal Partners have any questions, please feel free to contact the USAC Tribal Liaison at TribalLiaison@usac.org.
A consortia application’s discount rate is calculated based on a simple average of the discount of the members on a particular application. The rate can vary from across applications when the members on each application vary.
The invoicing method is determined by the consortium lead and its members, in discussion with the selected service providers. Like other E-Rate applicants, consortia can choose between the two different invoicing methods; Billed Entity Applicant Reimbursement (BEAR) Form or the Service Provider Invoice (SPI) Form and should discuss this with their service providers as soon as possible in the selection process.
There are three key differences between the two invoicing methods, which are:
1. Who submits the form to USAC to request reimbursement of the discounted share?
2. Who receives payment from USAC?
3. How much is paid to the service provider.
When using the FCC Form 472, or BEAR method, to invoice, the applicant pays the service provider in full within 90 days of receipt of equipment and/or services. The applicant, i.e. the BEN filing the FCC Form 471, then requests reimbursement from USAC for the discounted portion of the approved equipment/services delivered to approved recipients of service at the rates and quantities approved on the FCC Form 471. If a consortium files the FCC Form 471, it would be the BEN filing the FCC Form 472 in this instance. If using the BEAR method, the consortium lead and/or the consortium members will also need to file the FCC Form 498 to be assigned an applicant 498 ID number, if they do not already have a FCC Form 498 ID number. An applicant 498 ID number is required to be able to submit the FCC Form 472.
When using the FCC Form 474, or SPI method, to invoice, the service provider bills the applicant for the non-discounted share and the consortium or the members of the consortium pays the non-discounted share to the service provider within 90 days of receipt of the equipment and/or services. The service provider then requests reimbursement from USAC through the FCC Form 474 for the discounted portion of the approved equipment/services delivered to approved recipients of service at the rates and quantities approved on the FCC Form 471.
For either invoicing method, the consortium is responsible for establishing its own process for how the consortium lead and/or the individual consortium members pay the non-discounted portion of the bill plus any ineligible equipment/services. Consortia may use a variety of different approaches to make these payments including, but, not limited to:
- The consortium lead collects the non-discounted portion of the bill from consortium members on a regular basis (i.e., monthly, quarterly, annually) and submits payment directly to the service provider.
- Each consortium member pays the non-discounted portion directly to the service provider.
- The consortium lead collects the payment from the consortium members for both the non-discounted and discounted portions of the bill to pay the service provider in full. The consortium lead then submits the BEAR Form to request reimbursement from USAC for the discounted portion of the bill. After payment is received from USAC, the consortium lead is responsible for reimbursing the consortium members. (BEAR Method Only).
- For some statewide consortia, the consortium lead pays the non-discounted portion of the bill to the service provider for the entire membership without collecting payment from individual members.
E-Rate program rules require payment of the non-discounted portion of the bill to the service provider within 90 days of receiving the equipment and/or services. A consortium lead and/or the individual consortium members must determine how they will pay the non-discounted portion of the bill plus any ineligible equipment/services.
The consortium lead, each consortium member, independent entities and service providers are each responsible for maintaining their respective documentation for at least 10 years after the last day of the applicable funding year or the service delivery deadline for the funding request, whichever is later. Information on specific documentation requirements is available on the Document Retention section of the E-Rate website.