A Letter of Agency (LOA) is the document that establishes an applicant entity has authorized a specific person to act on its behalf for E-Rate filings. It's most commonly used for consortium applications, where a consortium leader files on behalf of member schools or libraries who each sign an LOA authorizing that filing.
How It Works
The person who certifies a Form 471 is affirming they're authorized to submit and certify on behalf of every entity featured in that application's funding requests. During review, USAC can require documentation proving that authorization actually exists.
A consortium LOA is typically signed by each member and kept on file by the consortium leader. A project agreement, contract, or letter agreement can substitute for a formal LOA. To be valid, the document must be signed and dated on or before the Form 471 certification date, and it must include:
- The name of the person filing the application (the consortium leader)
- The name of the person authorizing the filing (the member entity that will receive discounted services)
- The specific funding year the authorization covers
- The signature, date, and title of an authorizing official who is an employee of the member entity
- A description of the services covered, which can be as broad as "all E-Rate eligible services" or more restrictive
The authorization timeframe can't be open-ended, language like "until terminated by either party" isn't acceptable. Consortia with a statutory or regulatory basis and mandatory member participation can instead document that legal basis, such as the relevant state statute or regulation, in place of collecting individual LOAs.
See USAC's own guidance for the full requirements and a sample document (USAC: Letter of Agency (LOA)).
What This Means for You
Applicants
If you're a consortium member, keep a signed, dated, funding-year-specific LOA on file every year, not just once at the start of the relationship. If you're a consortium leader, be ready to produce every member's authorization document on request during a selective review.
Service Providers
An LOA never authorizes you to certify or file on an applicant's behalf. If a consortium or applicant representative signs your paperwork, confirm they actually hold that authority, since a missing or invalid LOA can unravel an otherwise clean application during review.
Consortium members often sign an LOA once, years ago, and forget it needs a specific funding-year scope rather than standing forever. When USAC asks for current-year authorization documentation during a review, that's exactly when an old, expired, or open-ended LOA turns into a real problem instead of a filing formality.
Common Questions About Letters of Agency
When do I need an LOA?
Most commonly for consortium applications, where the consortium leader files on behalf of member entities who each authorize it.
What has to be in a valid LOA?
The filer's name, the authorizing entity's name, the specific funding year covered, a signature, date, and title from an employee of the authorizing entity, and a description of the covered services.
Can an LOA cover multiple funding years indefinitely?
No. The timeframe must be specific and can't be open-ended.
Does a consortium always need individual LOAs from every member?
Not necessarily. A project agreement, contract, or similar document can substitute, or, for statutorily mandated consortia, documentation of that legal basis can substitute instead.
Who can respond to a selective review on my behalf using an LOA?
An authorized representative you've designated, but never your service provider, who is barred from completing a selective review response for an applicant.
Informational only, not legal advice. E-Rate procedures and forms can change by funding year. Confirm current requirements in the applicable USAC and FCC guidance.