The E-Rate cycle has seven main steps. CIPA is certified near the end, on Form 486. But the facts you certify must be true on the day services start, so the CIPA work runs alongside the whole cycle. The green box under each step says what CIPA needs ready at that point.
1Form 470 and the 28-day wait
Form 470 opens competitive bidding. Once you certify it in EPC, it is posted publicly and service providers can bid. If you issue a request for proposals, you must upload it with the Form 470. USAC says it usually posts each year's Form 470 about 12 months before the funding year starts, and the FY2027 form has been open since July 1, 2026.
You must then wait at least 28 days before you select a provider, sign a contract or certify Form 471. The day you certify Form 470 is day one, and the 29th day is your Allowable Contract Date. You can set a later bid deadline in the Form 470 narrative or the RFP. If you do not set one, USAC says to consider all bids received until you start evaluating them. Form 470 must be certified at least 28 days before the Form 471 window closes.
CIPA at this step: read your internet safety policy against the CIPA list and decide if it needs changes. If you plan to change the filter or the policy, plan the public notice and the hearing or meeting now. Remember that the filter is not an E-Rate eligible service, so buy it through your own procurement and budget.
2The Form 471 filing window
Form 471 is the funding request. It lists the schools or libraries receiving service, the providers, the services, the costs and the dates. You certify that you comply with program rules. USAC announces the exact window dates each year before it opens. You cannot certify Form 471 before your Allowable Contract Date, and it must be certified by 11:59 p.m. ET on the last day of the window. Late forms are out of window.
Since FY2026, you also pick your invoicing method on Form 471: the Billed Entity Applicant Reimbursement (BEAR) method on Form 472, or Service Provider Invoicing (SPI) on Form 474. Consortium leaders need letters of agency signed and dated on or before the date they certify Form 471. After you certify, USAC sends a Receipt Acknowledgment Letter (RAL). Use it to catch and fix mistakes.
CIPA at this step: for FY2027 the CIPA certification is not on Form 471. It is still on Form 486. Use the window period to make sure the internet safety policy is adopted, the notice and hearing records are filed, and the filter subscription will cover the whole funding year.
3PIA review
After the window, USAC's Program Integrity Assurance (PIA) team reviews each Form 471. Questions can cover the eligibility of the entities and services, discount calculations, contracts and the bidding process. You have 15 days to respond to PIA questions. You can ask for more time, but that slows your review. Some applications go to a deeper Selective Review that can ask for bid records, proof you can pay your share, and proof you have the other resources needed to use the services.
CIPA at this step: keep your bid records and contracts in the same folder as your CIPA records. Reviewers and auditors often ask for both. Ask IT for a short dated note that says which filter is in use, where it runs and which devices it covers.
4The Funding Commitment Decision Letter (FCDL)
When review is done, USAC issues an FCDL with its decision on each funding request. It appears in your EPC News feed. Read it closely, because it drives the next deadlines. If you disagree with a decision, USAC must receive your appeal within 60 days of the date of the letter.
CIPA at this step: the FCDL date starts one of the two clocks for Form 486. Write it on the shared calendar the day it arrives, next to the expected service start date for each request.
5Form 486 and the CIPA certification
Form 486 tells USAC that services have started and states your CIPA status. You cannot file it until you have an FCDL with a positive commitment. The deadline is 120 days after the service start date or 120 days after the FCDL date, whichever is later. You may file early, before services start, only if you have your FCDL, services start in July, you can truthfully make every certification, and you file on or before July 31.
If USAC thinks you missed the deadline, it sends an Urgent Reminder Letter. You then have 15 days to file with no penalty. If you miss that, USAC moves your service start date to 120 days before the date you certified, and your commitment can shrink.
CIPA at this step: you pick one status: compliant, undertaking actions to comply (first funding year only), or CIPA does not apply (telecommunications services only). USAC says you must be in compliance before services start and that it cannot pay discounts for any period when you were not. Read more in our
Form 486 and CIPA certification guide.
6Form 479 for consortium members
When the body that runs a school or library (its Administrative Authority) is not the Billed Entity, it certifies its CIPA status on FCC Form 479 and gives it to the consortium leader. The form goes to the leader, not to USAC, so USAC sends no receipt. The leader cannot complete the CIPA certification on Form 486 without completed Forms 479 on file. A leader that applies only for telecommunications services does not need to collect them.
CIPA at this step: members should send Form 479 well before the leader's Form 486 deadline. A late Form 479 can make the whole consortium's Form 486 late. See our guide to
Form 479 for consortium members.
7Invoicing on Forms 472 and 474
Once services have started and Form 486 is processed, USAC can be invoiced for the discounted share. Under BEAR (Form 472), you pay the provider in full and USAC reimburses you. Under SPI (Form 474), the provider bills you only for your share and invoices USAC for the rest. Before any invoice is paid, the provider must have a Form 473 (SPAC) on file for the funding year. BEAR filers need an approved Form 498 with a SAM.gov Unique Entity Identifier (UEI). Since September 8, 2026, USAC pays invoices to the bank account linked to your SAM.gov registration, and it holds BEAR payments for filers that have no UEI on Form 498.
The invoice deadline is the latest of 120 days after the last date to receive service or 120 days after the FCDL date, with later dates for revised commitment letters. You can get one 120-day extension per funding request if you ask before, or within 15 days after, the original deadline.
CIPA at this step: save filter reports or logs from across the funding year. USAC's CIPA page says audit records should show the filter was installed and working during the year.