PIA (Program Integrity Assurance) Review
HWC Consultants assists schools and school districts with E-Rate program applications, telecom consulting and auditing, and project management. Our previous blogs have discussed the steps needed to prepare for the funding year 2023 E-Rate application, including forms, timing, bidding, and other process requirements. Today we would like to discuss PIA (Program Integrity Assurance) reviews.
After an applicant files a certified Form 471, PIA reviewers check all forms for completeness and accuracy, and may have additional inquiries for the applicant. This review begins the minute the application is submitted and can last through the funding commitment. Inquiries by PIA reviewers may involve the competitive bidding process, eligibility of entities receiving service or the services/equipment requested, contracts, discount calculations, contract signing, or other questions. While applications are reviewed on a first come first serve basis, all applicants go into review. While most applicants will receive at least one PIA inquiry, not all will. Your consultant can assist with preparing answers to PIA inquiries.
All PIA inquiries and their answers will be posted in the applicants’ EPC portals, and the Form 471 email contact in the certified application will receive email notification that a PIA reviewer has inquiries regarding their application. The email will list the Form 471 number and the general subject of the inquiry, but will not contain the actual inquiry itself.
Applicants can click on the PIA email to see and respond to specific inquiries, with all submitted inquiries remaining in EPC. If there is more than one inquiry on the PIA list, they should all be answered. The pending inquiries show the due date by which answers must be submitted. Applicants are typically given 15 days to respond to PIA inquiries, with reviewers having authority to grant one-week extensions. If you do not respond within the allowable time frame, your application can be denied.
First time clients in particular may need to prepare specific items for PIA review, including proof of student eligibility and enrollment numbers, and redacted copies of sample financial aid forms or state school lunch program submissions. It’s safe to say that if you are new to the E-Rate program that you will be asked for this information, so plan ahead and have this information ready to go after certifying your Form 471.
Some applications undergo additional review, such as Selective Reviews, where PIA reviewers may request more detailed responses. These can include providing documentation of the competitive bidding and service provider selection processes, copies of contracts, communications with providers, and any bid evaluation tools.
As part of the review process, PIA reviewers may be required to change certain parts of the Form 471 - for example, the service start/end date, the service type or category of service on an FRN, or a portion of the costs. If ineligible or overbudget services are discovered in a funding request, the applicant has the option to remove them.
After the PIA review process is complete, USAC issues a Funding Commitment Decision Letter (FCDL) containing its decision regarding the applicant's funding requests. These can be found in the newsfeed in the organization’s EPC account, and is emailed to the Form 471 contact person and EPC account administrator. This decision contains important information about the start of services and how to complete the final steps in the application process.
Should you need assistance with E-Rate consulting, reach out to us at HWC Consultants!