Document Retention Requirements
At HWC Consultants, we have blogs outlining the steps necessary for E-Rate program applications from start to finish. Here we discuss E-Rate program requirements for document retention.
E-Rate has strict document retention requirements, and it is vital to keep documentation for the purpose of a potential audit. Although audits are rare, E-Rate program rules require that participants retain all documentation demonstrating compliance with the rules for a minimum of ten years after either the last day of the applicable funding year, or the service delivery deadline for the funding request - whichever is later.
The following list provides examples regarding the types of E-Rate program documents that should be retained by all program participants to be in compliance with FCC audit and document retention requirements. These include school and library applicants, service providers, and consortia. For those of you who have done Category Two, please pay particular attention to the requirements regarding the Asset Register for each funding year. Note that there are many other types of documentation that are required to be retained - these are just examples.
Applicant Eligibility
Accreditation, Charter, or other documentation that supports that your school meets the state’s definition of elementary or secondary school.
Competitive Bidding
Overview of the service provider selection process, including criteria and weighting of the criteria.
Requests For Proposals (RFPs) issued (if applicable), and public notice of RFP(s) issued if public notice is required by your state or local procurement laws.
Copies of all bids received.
Discount Calculations
Copies of any policies and/or procedures related to the entity’s discount calculation process or methodology (e.g., National School Lunch Program (NSLP), DEP certification documents, income surveys, financial applications, etc.).
Disbursements
Documentation of payment (cancelled checks or ACH transfers) for services to service providers.
Documentation showing receipt and deposit of any reimbursement amounts received (e.g., wire transfers from USAC).
Children’s Internet Protection Act (CIPA)
Copy of the internet safety policy or acceptable use policy. To learn more about what your policy must address, please click here.
Documentation of the adoption of the internet safety policy.
A copy of the minutes and the date of the public hearing regarding the internet safety policy.
Documentation showing that the filter was installed and working during the funding year. This would be purchase or subscription invoices, filtering logs, etc.
Services
For Basic Maintenance of Internal Connections, you need documentation to support that the funded service was received. This would be invoices and logs detailing the eligible maintenance performed on E-Rate eligible equipment (e.g., itemized invoices).
For Category Two: A completed Asset Register for each funding year with Category Two services and/or equipment purchased, including references to vendor bill, USAC invoice, serial number, current physical location, documentation of any transfers, etc.
Other
Copies of financial statements and annual budgets.
You can review the complete USAC list of document retention requirements here.
HWC Consultants provides assistance with E-Rate and Emergency Connectivity Fund consulting, telecom optimization audits, contract negotiation with service providers, and telecom project management. We help clients reduce their telecom expenses through better technology and more cost-effective solutions. Reach out to us if you have any questions regarding document retention requirements.