FCDL Comment:
DR1:During the Special Compliance review you were asked to explain why you filed 61 unique FRNs filed by 61 entities all of which requested the exact same equipment for a total of $132,008.00 for each FRN. We understand that Academica (Management Company for each individual school) standardizes their equipment; however, the quantities requested on the FCC Form 470 did not match the quantity that each entity truly needed. During the review you were asked to demonstrate how each location has similar needs and how the quantities on the FCC Form 470 were determined. In response to your questions, you stated there is no specific documentation other than the spreadsheet which was provided in a follow-up response. The follow-up response requested to reduce the quantities for six FRNs based on the needs of each school. Furthermore, it was stated in a follow-up response regarding the quantities that “These decisions would be made during the E-Rate year and depend on IT needs and overall budgets at that time” and “This may mean that they would buy everything listed on the 471, they may buy nothing, or they may buy a subset of what is listed”. At the time the FCC Form 470 is filed, the equipment and quantities should be reflective of the true needs of the school and what each school would purchase for the funding year. Your responses to the Special Compliance inquiry demonstrate that the school did not accurately know the exact quantities and needs of each school when the FCC Form 470 was filed.||DR2:The quantities of products and services that you requested on your FCC Form 471 are substantially different than those requested on your FCC Form 470. Program rules require applicants to make a bona fide request for services by filing an FCC Form 470. The FCC Form 470, RFP, or other solicitation method should be clear about the type and quantity of products and services the applicant is seeking and must be based directly on the applicant’s technology needs. The services requested on your FCC Form 470 must describe the planned service requirements requested on your FCC Form 471. Since you did not meet this Program requirement, the FRN must be denied.||MR1:The Service/Product Type for FRN Line Item 2199043705.002 was modified from Connector to Module to agree with the applicant documentation.||MR2:The Service/Product Type for FRN Line Item 2199043705.010 was modified from Connector to Module ?to agree with the applicant documentation||MR3:The One Time Quantity for FRN Line Item 2199043705.001 was modified from 10 to 3 to agree with the applicant documentation.||MR4:The One Time Quantity for FRN Line Item 2199043705.002 was modified from 10 to 0 to agree with the applicant documentation.||MR5:The One Time Quantity for FRN Line Item 2199043705.003 was modified from 10 to 0 to agree with the applicant documentation.||MR6:The One Time Quantity for FRN Line Item 2199043705.004 was modified from 10 to 0 to agree with the applicant documentation.||MR7:The One Time Quantity for FRN Line Item 2199043705.005 was modified from 10 to 3 to agree with the applicant documentation.||MR8:The One Time Quantity for FRN Line Item 2199043705.006 was modified from 10 to 4 to agree with the applicant documentation.||MR9:The One Time Quantity for FRN Line Item 2199043705.007 was modified from 10 to 3 to agree with the applicant documentation.||MR10:The One Time Quantity for FRN Line Item 2199043705.008 was modified from 15 to 9 to agree with the applicant documentation.||MR11:The One Time Quantity for FRN Line Item 2199043705.009 was modified from 2 to 0 to agree with the applicant documentation.||MR12:The One Time Quantity for FRN Line Item 2199043705.010 was modified from 2 to 0 to agree with the applicant documentation.||MR13:The One Time Quantity for FRN Line Item 2199043705.011 was modified from 2 to 0 to agree with the applicant documentation.||MR14:The One Time Quantity for FRN Line Item 2199043705.012 was modified from 2 to 0 to agree with the applicant documentation.||MR15:The One Time Quantity for FRN Line Item 2199043705.013 was modified from 2 to 0 to agree with the applicant documentation.||MR16:The One Time Quantity for FRN Line Item 2199043705.015 was modified from 50 to 25 to agree with the applicant documentation.||MR17:The One Time Quantity for FRN Line Item 2199043705.016 was modified from 1 to 0 to agree with the applicant documentation.||MR18:The One Time Quantity for FRN Line Item 2199043705.017 was modified from 45 to 5 to agree with the applicant documentation.||MR19:The One Time Quantity for FRN Line Item 2199043705.018 was modified from 15 to 6 to agree with the applicant documentation.||MR20:The One Time Quantity for FRN Line Item 2199043705.019 was modified from 2000 to 800 to agree with the applicant documentation.||MR21:The funding request amount was reduced from $132,008.00 to $43,910.00 to remove the amount that exceeded the Category Two budget set for the following entity(ies): Mater St Cloud-17017731