Document Retention

All E-Rate program participants—applicants, service providers, and consortia—are required to maintain documentation that demonstrates compliance with the statutory or regulatory requirements for all E-Rate program purchases of equipment and services. Participants must keep these records for a period of 10 years after the last day of the applicable funding year or the service delivery deadline for the funding request, whichever date comes later. Examples of such documentation include competitive bidding materials, program forms, contracts, and asset and inventory records of equipment purchased as components of supported Category Two services.

The FCC first established document retention requirements for school and library applicants and service providers in the Fifth Report and Order (FCC 04-190) and provided an illustrative list of examples of the types of documents that should be retained. The FCC extended the document retention period to 10 years in the E-Rate Modernization Order (FCC 14-99) and clarified that the record retention and audit requirements apply to all program participants including any consortium that includes schools and libraries. Examples include:

  • Pre-bidding Process. Beneficiaries must retain all pre-bidding documents, for example, if consultants are involved, beneficiaries must retain signed copies of all written agreements with such consultants.
  • Bidding Process. All documents used during the competitive bidding process such as Request(s) for Proposal or equivalent, documents describing the bid evaluation criteria, weighting, and evaluation worksheets; all written correspondence between the beneficiary and prospective bidders, all bids submitted (both winning and losing), and documents related to the selection of service provider(s). Service providers participating in the bidding process that do not win the bid need not retain any documents.
  • Contracts. Both beneficiaries and service providers must retain executed contracts, signed and dated by both parties. All amendments and addendums to the contracts must be retained.
  • Application Process. Beneficiaries must retain all documents used to submit the FCC Form 471, including National School Lunch Program eligibility; documents to support the necessary resources certification including budgets.
  • Purchase and Delivery of Services. Beneficiaries and service providers should retain all documents related to the purchase and delivery of E-Rate eligible services and equipment.
  • Asset Inventory. Schools, libraries, and consortia must maintain asset and inventory records of equipment purchased as components of supported Category Two services (internal connections, managed internal broadband services, and basic maintenance of internal connections), sufficient to verify the actual location of such equipment for a period of 10 years after purchase.
  • Invoicing. Both service providers and beneficiaries must retain all invoices including records proving payment of the invoice, such as accounts payable records, service provider statement, beneficiary check, bank statement or ACH transaction record, as applicable.
    • Service providers and applicants should also maintain a reconciliation worksheet that includes: Service provider bill number, billed product or service, quantity and cost per unit, extended billed amount, and sum of all the extended bill amounts that agrees to the total undiscounted amount, so that amount for equipment or service requested on the BEAR form can be traced to the actual copies of the service provider bills.

Sample Reconciliation Worksheet

  • Inventory. Beneficiaries must retain asset and inventory records of equipment purchased and components of supported internal connections services sufficient to verify the location of such equipment. Beneficiaries must also retain detailed records documenting any transfer of equipment.
  • Forms and Rule Compliance. All program forms, attachments and documents submitted to USAC must be retained by applicants and service providers.

Note that FCC rules may have changed over the years so the descriptive list above is provided as a guideline but cannot be considered exhaustive. Use the E-Rate Program List of Documents to Retain for Audits and to Show Compliance with Program Rules as a guide to understand the types of documents that should be retained.