Post on 25-Feb-2016
description
Presented by Julie Tritt
SchellPA E-rate
CoordinatorFall 2011
1
E-RATE TRAINING WORKSHOP FOR
BEGINNERS FUNDING YEAR 2012
Happy 15th Birthday,E-rate!
History and Program AdministrationApplicant and Services EligibilityStep-by-Step Program Requirements and
FormsAdditional Rules
Morning break, if neededQuestions at end of each sectionLunch from 12 -12:30* What does this mean?
2
AGENDA
School DistrictsIUsCharter SchoolsAVTSsNon-public
SchoolsLibraries
Superintendents/Asst Supt
Business ManagersTechnology DirectorsVendorsConsultants
3
WHO IS HERE?
Who is brand new to E-rate?Who NOT on PA E-rate listserve?
Telecommunications Act of 1996 established “Universal Service Discount Program for Schools and Libraries”
Annual $2.25 billion program, adjusted for inflationFunding years named for the year in which they
beginFY 2012 = July 1, 2012 – June 30, 2013
Provides 20-90% discounts on eligible services
Fund made up from charges on your phone bills
Not a typical grant program 4
WHAT IS E-RATE?
FCC Federal Communications CommissionCreated program and sets rules and policy
USAC Universal Services Administrative CompanyCreated by FCC to run E-rate and other
universal service programsPays invoices
SLD Schools and Libraries DivisionEntity within USAC that runs E-rateMakes no policy decisions
5
WHO ADMINISTERS E-RATE?
Under contract with PDE to serve as PA E-rate CoordinatorProvide outreach and training to schools and
libraries in PARepresent PA before federal policymakersMaintain PA E-rate website and listserveAct as resource when E-rate administrator
can’t help
6
WHAT IS JULIE’S ROLE?
Public libraries eligible for LSTA fundingPublic and private K-12 schools
For-profit schools not eligiblePre-k eligible in PA (age 3+)Head Start entities eligible in PA but only if
operated by a public school entity Cannot have endowment exceeding
$50 million
7
WHO IS ELIGIBLE?
Residential locations within schools serving (beginning with FY 2011):tribal studentschildren with physical, cognitive, or
behavioral disabilitiesjuvenile justice students, orresidential schools where 35% or more of
their students are eligible for NSLP Schools can be public or private and both
Priority 1 and Priority 2 services are eligibleResidential locations of cyber school students
or employees are not eligible
8
ELIGIBLE RESIDENTIAL LOCATIONS
WWW.E-RATEPA.ORG
9
E-rate is not a short, easy processRead listserve messages Read form certificationsBe prepared for an auditStay organized! –
USE THE BOX or BINDER!
10
FAIR WARNING!
Eligible Services List in Binder*
11
WHAT SERVICES ARE ELIGIBLE AND
INELIGIBLE?
FCC established funding priorities because demand always exceeds cap of $2.29 billion
Priority 1: Telecommunications and Internet AccessAll ‘services’ that are leased, and nothing that is
purchasedAll approved-inside the window-likely to be funded,
regardless of discount levelPriority 2:
Internal Connections and Basic Maintenance of ICFunds go first to neediest applicants (90% discount
level), then to others in order of discount until funds are exhausted
12
FUNDING PRIORITIES
MUST be provided by an Eligible Telecommunications Provider (ETP)
Local, long distance, voice mail, cell, paging, Centrex, T-1, PRI, frame relay, ISDN, etc.
Installation of eligible telecom services (if included on your application)
Including most taxes and surcharges and custom calling features
Hosted VOIP* (also eligible under Internet)Lit fiber service (also eligible under Internet
Access)*
13
P1: ELIGIBLE TELECOM SERVICES
Sharing of bandwidth to ineligible entities900 callsPayphone serviceCost of not-publishing phone numbersCost of additional directory listingsEnd user equipment (phones, beepers, cell
phones, fax machines, etc.)Late fees or finance chargesPaper statement feesCost recovery feesProperty tax fees
14
P1: INELIGIBLE TELECOM SERVICES
Eligible:Basic conduit access Hosted E-mail serviceLaptop aircard accessBasic webhosting, including:
discussion boards, blogging, instant messaging and chat
Firewall fees – if part of standard vendor service
Blackberry/data services(be sure to post separately
from telecom on 470)Lit fiber serviceDark fiber service
Ineligible:Filtering Any remote access
outside school property to Internet
Broadcast messaging services
AntiVirus/AntiSpamIneligible webhosting
features: content, website
development costs, searchable databases or content, student attendance reporting, and grade books
15
P1: INTERNET ACCESS
Called On-Premise, Priority 1 EquipmentPermitted if bundled with service from Telco
or ISPMust tell SLD make/model of equipmentMust certify to TN Test:
No applicant ownership – everNo exclusive useLAN functions without use of equipmentService provider maintains equipment
Not applicant(Answers on PA E-rate website)
16
EQUIPMENT ELIGIBLE TO BE BUNDLED*
Can be leased from telecommunications provider (such as Verizon, Comcast, Sunesys, Sting, etc)
OR
Beginning in FY 2011, can be leased from any other provider (such as electric company, cable company, regional network, etc)Post in both telecom and internet category
on Form 470 17
LIT FIBER ELIGIBILITY
Beginning in FY 2011, applicants may lease dark fiber from any provider, with conditions:E-rate will not pay for new fiber networks off school
propertyInstallation (non-recurring) charges eligible from
school building to edge of school propertyModulating electronics must be provided by the
applicant and cannot be bundled with the cost of the serviceThis equipment is eligible for Priority 2 funding
18
DARK FIBER ELIGIBILITY
Fiber must be lit immediatelyExcess fiber that is not lit is not eligible
Network maintenance costs are eligibleService should be posted in both telecom and
internet access categoriesApples-to-apples comparison should be done
to ensure that leasing dark fiber is most cost effective method of delivering service
19
DARK FIBER ELIGIBILITY, CONT.
• Network and phone wiring
• Routers• Switches, hubs• Certain network
servers • e-mail, DHCP, firewall,
DNS• Video codecs• VOIP equipment• GBICs and modulating
electronics to light fiber
Wireless access pointsPrivate branch
exchange (PBXs)FirewallsInstallation of eligible
internal connectionsSystem operating
software For eligible equipment
only
20
P2: ELIGIBLE INTERNAL CONNECTIONS
Personal computers FAX machines Asbestos removal Cameras Electrical wiring Teacher training Security wiring Servers for storage
Network management s/w
Curriculum softwarePhones, beepers,
aircardsSalaries of school or
library staffFiltering software
21
P2: INELIGIBLE INTERNAL CONNECTIONS
Beginning in FY 2011, maintenance severely curtailed
Eligible: Bundled manufacturer warranties up to 3
yearsCannot have a separate price
Software, patches, online tech supportActual labor and break-fix cost
Ineligible:Unbundled warranties, insurance-type
warranties, including Smartnet (portion of Smartnet eligible) 22
P2: BASIC MAINTENANCE
Contract:Must separately identify cost of maintaining E-rate eligible
equipment from E-rate ineligible equipmentMay not mix E-rate eligible maintenance services with other
ineligible services (such as help desk or monitoring services)Calculation of funding request:
Must be based on an estimated number of maintenance hours per year for eligible equipment, based on current life of equipment and history of needed repairs
Reimbursement amountBreak/fix - USAC will only pay for cost of actual work
performed (which includes labor, equipment fix, or if it is beyond repair, equipment replacement)
Software patches/Online tech support – 100%, no documentation needed
23
P2: BASIC MAINTENANCE
An entity may only receive discounts 2 out of every 5 years for internal connectionsDoesn’t include basic maintenance
Applies at the building level, not district levelIf central equipment is purchased for NOC, each
building receiving benefit of that equipment receives a strike
Plan accordingly to maximize discounts“Strikes” related to FCDL, not 471 or invoicesCan cancel FRN to get strike (year) back, but not
after funding has been disbursedHint: Don’t use a strike (year) for a $500 piece
of equipment
24
2/5 RULE*
E-rate-funded equipment must remain at approved site for 3 full years after installationAfter which it may be moved to another eligible location
Documentation must be retained describing transferIf school or library closes, equipment may be
moved to another entity, regardless of discountMust send letter to SLD outlining closing of school and
transfer of equipmentMust keep documentation regarding transfer for 5 years
After 5 years, equipment may be disposed of or soldDisposal does not need to be reported to USACProceeds from sale do not need to be returned to USAC
25
TRANSFER OF EQUIPMENT*
SHOULD I APPLY FOR P2 FUNDING?
Year 1 -- funded to 70%Year 2 – all fundedYear 3 – down to 82% Year 4 – down to 87%Year 5 – down to 81% Year 6 – down to 70% - significant rollover
fundsYear 7 – down to 81%Year 8 – down to 80%Year 9 – down to 86% Year 10 – down to 81% - $650M rolloverYear 11 – down to 87% - $600M rolloverFY 2009 – down to 77% - $900M rolloverFY 2010 -- all funded - $1.15B rollover +
inflation26
27
QUESTIONS ABOUT APPLICANT OR
SERVICE ELIGIBILITY ISSUES?
28
APPLICATION FLOWCHART
29
GENERAL FRAMEWORK
PlanBid Apply Approval!
Receive Services
Pay Full InvoicesUSAC Pays Applicant
Pay Discounted InvoicesUSAC Pays Vendor
Required if applying for P2 fundingMust include four SLD technology plan
criteriaGoals and Strategies for using technologyNeeds AssessmentProfessional DevelopmentEvaluation
Must align with funding requests and bidding documents
Must be “written” before 470 is filedMust cover full 12 months of NEXT funding
year (include dates!)3 year max
30
STEP 1: TECHNOLOGY PLAN (MAYBE?)*
Must be approved by SLD “Certified” approverPublic schools – PDE approves
PDE requires submission by Sept. 30 for plans expiring June 30, 2012
Status of LEAs’ tech plans in binderNonpublic schools – Various entities approve
List in binder and on SLD websiteCAIU will approve if no organization on the
SLD list represents your entityLibraries: Approved by Commonwealth
Libraries
31
TECHNOLOGY PLAN APPROVALS*
32
QUESTIONS ABOUT TECHNOLOGY
PLANS?
All E-rate services must be competitively bidBefore any contract is signed
If multi-year contract is signed, then there is no requirement to bid the remaining years of the contract
Every year for all month-to-month servicesEven if no competition in your area or if
bidding under state lawBidding via E-rate does not exempt you from
bidding under state lawCan be done simultaneouslyOnly exception is if someone bid it for you
(consortium application, PEPPM contract) 33
STEP 2: COMPETITIVE BIDDING
File online to begin procurement processAll 470’s posted on SLD web site Cannot select vendor until 29 th day after 470
is postedBut must have Form posted on web at least
29 days before the Form 471 window close (example: March 15 close = Feb 16 deadline)Don’t wait this longFile 470 by Thanksgiving, if possible
eCertify! (or mail certification page to SLD if you don’t have PIN)
34
HOW? MUST USE FORM 470*
Read the
Instructions!
Must be fair and open processProvide as much detail as possible so
bidders can respond Be sure to post in proper category
If unsure, post in multiple categoriesFile single or multiple 470s (up to you)Review Checklist before submitting your
470*
35
COMPETITIVE BIDDING: FORM 470
New 470 removes many of the unused features and questionsMTM/contract/multi-year contract checkboxesBEAR/SPI preference questionIneligible entities sectionNecessary resources checkboxesArea codes and phone pre-fixes section
Added item for consultant registration number
36
NEW FORM 470
Have a relationship with service providers that would unfairly influence the outcome of the competition
Furnish service providers with inside competitive information
Provide information or grant meetings to only some bidders
Have ownership interest in a service provider’s company competing for services
Violate applicant’s own regulations or policiesViolate gifts rules
37
APPLICANTS CANNOT...
Have pre-bidding discussions with potential bidders as long as that doesn’t lead to one bidder having “inside” information
Attend product demonstrations Encourage and seek vendors to bid Do research to determine what cost-effective
solutions are available
38
APPLICANTS CAN...
Offer neutral technical assistance on development of technology planCannot exert undue influence on applicant's ability to
conduct a fair and open competitive biddingAnswer general questions about the products
and services they sell in response to applicant inquiries
Assist with Form 471 Item 21 attachmentProvide information to applicants to assist
with responding to PIA questions but applicant must respond to PIA
Provide assistance with service substitutions and other post-commitment activities but applicant must certify
39
SERVICE PROVIDERS CAN...
Help prepare Form 470Help write or provide RFP to applicantBe a contact person on Form 470Sign any applicant formsBe involved with bid evaluation in any wayProvide funding for the applicant's non-
discount portion or waive the applicant's non-discount portion
Coerce or pressure the applicant to use a specific Service Provider
Provide gifts to applicants that violate the gift restrictions 40
SERVICE PROVIDERS CANNOT...
All gifts from service providers to applicants are prohibited except for:(1) Modest refreshments that are not offered as
part of meal (e.g., coffee and donuts provided at a meeting) and items with little intrinsic value intended for presentation (e.g., certificates and plaques); and
(2) Items that are worth $20 or less (e.g., pencils, pens, hats, t-shirts, and other items worth less than $20, including meals), as long as those items do not exceed $50 per employee from any one source per funding year
41
GIFT RESTRICTIONS
Exception for charitable contributionsService providers can continue making charitable
donations to E-rate eligible entities in the support of schools – including, for example, literacy programs, scholarships, and capital improvements – as long as such contributions are not directly or indirectly related to E-rate procurement activities or decisions
Exception for personal gifts There is an exception for gifts to family and
personal friends when those gifts are made using personal funds of the donor (without reimbursement from an employer) and are not related to a business transaction or business relationship
42
EXCEPTIONS TO GIFT RESTRICTIONS
Service providers All service providers with current or possible
future E-rate relationship to applicantAll individuals who are on the governing
boards of such an entity (such as members of the board of directors); and
All employees, officers, representatives, agents, or independent contractors of such entities
43
WHO IS SUBJECT TO GIFT RESTRICTIONS?
ApplicantsAll individuals who are on the governing boards of such
entities (such as members of a school committee)All employees, officers, representatives, agents,
consultants or independent contractors of such entities involved on behalf of such school, library, or consortium with E-rateIndividuals whose work in any way relates to E-rate
forms and technology plans;Individuals who prepare bids, communicate or work
with E-rate service providers, E-rate consultants, or with USAC; and
Any staff of such entities responsible for monitoring compliance with the E-rate Program
44
WHO IS SUBJECT TO GIFT RESTRICTIONS?
Aggregate value of all gifts to an E-rate applicant, from any employees, officers, representatives, agents, independent contractors, or directors of the service providers, are considered when computing the $50 annual limit
Rules are always applicable, not just during the time period when the competitive bidding process is taking place
State and local restrictions regarding gifts also still applyIf more stringent than federal requirements,
violation of state or local provision constitutes a violation of the FCC rule
45
OTHER IMPORTANT DETAILS RE GIFTS
You are allowed to change your mind and not purchase a service that is listed on Form 470
You are not required to meet with any vendor before, during or after the 470 bidding period If you meet with a vendor during the bidding period,
fairness requires that you meet with any other vendor that contacts you.
Smartphone service should be posted under both the Telecom and Internet service categories
When contacted by a vendor, you must indicate your willingness to receive a proposal for services listed on Form 470
46
COMMON QUESTIONS ABOUT 470
47
LET’S LOOK AT THE FORM 470
http://www.sl.universalservice.org/menu.asp
GET 470 INFORMATION IMMEDIATELY!
Posted 470 available immediately on SLD web site to view
Online 470 shows:Posting date of applicationEarliest date that your contract can be signed and thus 471 submittedDate that certification page was received at the SLD
SLD also sends this info in Receipt Notification Letter*
48
After 470 is posted for at least 28 days, review all bids received for all services
Create bid evaluation matrixPrice of eligible services/components
MUST be the most heavily weighted factor*Keep documentation of criteria used to
select vendorKeep all winning and losing bidsKeep bid evaluation matrixRetain all correspondence between applicant
and all vendors (winning and losing)49
STEP 3: BID EVALUATION*
Can consider other criteria in bid evaluation. Examples:History with vendorCost of ineligible itemsNew vendors’ cell phones
Quality of proposed solutionMBE/WBE preferenceCost to switch vendorsStaff time
ReferencesCannot consider “free services”
50
WHAT CAN BE CONSIDERED?
What should you do if you receive no bids?Document via an email or file memo that no
bids were receivedExisting Services: can continue to receive
services from existing service providerNew Services/Procurement: Solicit bid from
willing vendor (who is not your brother-in-law)Make sure price is cost-effectiveCheck marketplace options from other vendors in
your area or nearby areasSave research and information to justify buying
service from this vendor
51
STEP 3: BID EVALUATION*
Vendor selection must be done before you submit 471
Be careful not to make any decisions, sign anything or file any forms during 28 day waiting period.
Contracts must be signed and dated by applicantMust sign contract unless receiving services on
month-to-month basisList extensions and expiration date in contract
(cannot be open-ended)Be careful to list prices in extension terms!
Include out-clauses if you can’t pay without E-rateTry to have contracts begin July 1 and end June 30,
20XX to coincide with E-rate funding year
52
STEP 4: SIGNING E-RATE CONTRACTS*
These are Priority 1 services that have NO contractLocal, long distance phone serviceCellular ServiceSome Internet Access
Must competitively bid every year, regardless of competition in your area for those services
E-rate does not recognize multi-year tariffs… these must be contracts
53
TARIFFED SERVICES/MTM*
54
QUESTIONS ABOUT BIDDING / FORM 470 /
BIDDING BEHAVIOR/GIFT RESTRICTIONS/BID
EVALUATION / SIGNING CONTRACTS?
Form that requests discounts (funding) Filed by entity that actually pays the billsShows discount calculations Lists which 470 was used to bid services,
provides contract signing dates, contract amounts
File single 471 (multiple OK) for all requestseCertify!! Or submit signed certification page
ASAP if you don’t have a PINMust be filed by close of 471 filing window
(likely will be mid March)Don’t miss this deadline!
55
STEP 5: FILING THE 471
Discount level for a school or library depends on: 1) Percentage of students who are eligible for National School Lunch Program (NSLP) in:
→ (for a school) the school→ (for a library) the school district in which the library is
located Doesn’t matter if school serves lunch or participates in NSLP AVTS and nonpublic schools use their own students’ data, not sending
schools’ data October NSLP data on PA E-rate website by mid January
USAC wants you to use this data for FY 2012
2) Urban or rural location of the school or libraryList in binder and on pa e-rate website under ‘discount
calculations’
56
WHAT IS MY E-RATE DISCOUNT?*
57
DISCOUNT MATRIX FOR SINGLE SCHOOL
INCOME Measured by % of
students eligible for NSLP
URBAN LOCATION Discount
RURAL LOCATION Discount
If the % of students in your school that qualifies
for the NSLP...
...and you are in an URBAN area, your discount will be...
...and you are in a RURAL area, your
discount will be...
Less than 1% 20% 25% 1% to 19% 40% 50%
20% to 34% 50% 60% 35% to 49% 60% 70% 50% to 74% 80% 80% 75% to 100% 90% 90%
SchoolsUse straight matrix discount
DistrictsUse weighted average of schools’ individual
discountsLibrary
Use the total number of students eligible for NSLP in the school district in which the library is located divided by the total number of students in that school district, then use straight matrix discount
Library SystemUse simple average of member libraries’ discounts
ConsortiumUse simple average of members’ discounts
58
DISCOUNT CALCULATIONS BY ENTITY*
1 3 4 5Name of School Urban or
RuralU or R
Total# of
Students
# of StudentsEligible for NSLP
Oak Elementary R 100 50
7Discount% from
DiscountMatrix
80%
6% StudentsEligible for
NSLP Col. 5/Col. 4
50%
59
SCHOOL BUILDING DISCOUNTS
Individual School uses Discount from Matrix
1 3 4 5 8Name of School Urban or
RuralU or R
Total# of
Students
# of StudentsEligible for NSLP
Weighted Product for Calculating Shared Discount
(Col. 4 x Col. 7)
Oak Elementary R 100 50 80.00Spruce Jr. High R 212 98 148.40Elm High School R 566 273 396.20
District Totals for calculating Weighted Average Discount 878 624.60
71%10c Weighted Average Discount % for Shared Services (Col. 8 total divided by Col. 4 total. Round to nearest %)
50%46%
6% StudentsEligible for
NSLP
48% 70%
7Discount% from
Discount
80%70%
60
SCHOOL DISTRICT DISCOUNTS
Weighted Average of Individual School Discounts
1 2 3 4 5 6 7 8Name of Eligible Entity Entity Number and
FSCS of LibraryUrban or
Rural# of Students in
District# of
Students Eligible for
NSLP in District
% of Students
Eligible for NSLP
Discount from Matrix
Entity Number of
School District in
which Library is Located
Treetop Branch Library 123123 987654321U 525 200 38% 60% 125246Greenleaf Branch Library 123234 U 800 130 16% 40% 125400Acorn Branch Library 123122 U 1220 350 29% 50% 125659System Totals for calculating Shared Discount
10c Library Systems % (Col. 7 total divided by # of sites in Col. 1. 50%
61
LIBRARY BRANCHES
Use discount information for school district in which library is located
1
ELIGIBLE MEMBER ENTITIES Name of each individual school, school district and/or
library/library system in consortium
Treetop School DistrictWoodsville Library SystemForest Academy Totals for calculating Shared Discount
10c Shared Discount % (Col. 4 total divided by # of sites in Col. 1. Round to nearest %)
66%
198%
67%60%
71%
ENTITY DISCOUNT Individual School: Discount from Worksheet A
School District: Weighted average discount calculated in Worksheet ALibrary System: Shared discount from Worksheet B
4
62
CONSORTIUM DISCOUNTS
Simple Average of All Entity Members
Participation in these programs also qualifies:TANFMedicaidFood StampsSupplementary Security Income (based on
income)Federal public housing assistance (section 8)Low Income Home Energy Assistance
(LIHEAP)Not acceptable - Title 1, feeder schools
method, principal’s estimate63
ALTERNATIVE MEASURES TO NSLP*
Can conduct family survey even if you participate in NSLP
Must survey all families in the schoolCan do single buildings
If 50% of surveys are returned, survey is considered valid and results may be extrapolated for entire school
Keep careful documentationBeneficial for both public and nonpublic
schools seeking P2 fundingDon’t let consultants talk you into conducting
surveys64
ALTERNATIVE MEASURES TO NSLP*
Non-instructional school and library buildings are eligible for Priority 1 funding
NIFs that house the network hub are eligible for Priority 2 services and equipment
NIFs that contain classrooms
65
NON-INSTRUCTIONAL FACILITIES (NIFS)
Method of calculating discounts depends on what purpose the services are being used
School: Use NSLP data of students attending classroom
IU Admin Services: Weighted average of discounts in all buildings within IU territory (act as large admin building)
Consortium Lead: Simple average of consortium members’ discounts
66
IU DISCOUNT CALCULATIONS
67
QUESTIONS ABOUT DISCOUNT
CALCULATIONS?
Provide information related to your funding requests in Block 5 of Form 471Vendor/SPINCategory of ServiceForm 470 NumberT/MTM or Contracted Service
Signing dates/expiration dates for contracted servicePre-discount amount must be based on bill,
contract, quote, etc.Which entities receiving service
68
FUNDING REQUESTS – FRNS
New FRN (block 5) for each contract or SPINFRNs will be reviewed and funded individuallyDon’t include Priority 1 and Priority 2 on the
same Form 471This is called a ‘polluted 471’ and can’t be
funded until all FRNs can be funded
69
FUNDING REQUESTS – FRNS
File and certify online!Multiple forms OKNo one-to-one correlation with 470 required
Meaning, you can have (1) 471, but (3) 470’s.
All services listed on 471 must have been listed on a 470
Checklist*
70
FORM 471 FILING TIPS
AFTER YOU HIT ‘SUBMIT’ ON THE
471, THEN WHAT?
71
Item 21 attachments provide descriptions of actual servicesBecause no space to do so on the 471
Must have separate description for each FRN (funding request/Block 5)
Detailed list of products with associated prices that add up to funding request
List # of lines, speed, and description of service
File online or on paper (online preferred)
72
STEP 6: ITEM 21 ATTACHMENTS*
Don’t need to submit bills or contractsBut must have available and may be asked
to submit during application reviewKeep 471 Security Code to access Online Item
21 Attachment systemItem 21 attachments are required to be
submitted within 471 windowCan increase request on Item 21 attachment
if you made clerical error on 471
73
ITEM 21 ATTACHMENTS - ONLINE
74
LET’S LOOK AT THE FORM 471
http://www.sl.universalservice.org/menu.asp
75
76
SLD mails to applicantsConfirms receipt of Form 471Verifies Block 5 informationService provider receives similar letter
when they are listed as SPIN on 471Can use to make corrections for ministerial
and clerical errors
77
471 RECEIPT ACKNOWLEDGMENT LETTER (RAL)*
“The applicant can amend its forms to correct clerical and ministerial errors on their FCC Forms 470, FCC Form 471 applications, or associated documentation until an FCDL is issued. Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error.”(FCC 11-60)
78
MINISTERIAL AND CLERICAL ERRORS
Examples include but are not limited to:
Not timely notifying USAC to correct a USAC clerical errorUsing wrong FCC Form 470 number, wrong billed entity
number, or wrong billed entity number/worksheet number on Form 471
Using wrong name or service provider identification number (SPIN)
Using wrong expiration date for a contractRequesting recurring service when the service is one timeRequesting one time service when the service is recurring Inaccurately reporting the prediscount amount on Block 5Leaving off a building from Block 4Referring to wrong Block 4 worksheet for a funding requestListing wrong service category in Block 5
79
MINISTERIAL AND CLERICAL ERRORS
Spelling errorsSimple addition, subtraction, multiplication or
division errorsTransposed letters and/or numbersMisplaced decimal pointsOther punctuation marks (hyphens, periods,
commas, etc.) included, or not included or misplaced
Failing to enter an item from the source list (e.g., NSLP data, uploading Block 4 data, FRN, etc.)
80
MORE M&C ERRORS
PIA will ask if this is a ministerial or clerical errorExplain how the error occurred Provide a reasonable explanationProvide documentation that was in existence as of the date of submission of Form 470 or Form 471
Explain that the error occurred when consulting “source list”
PIA must approve the explanation before the change will be made
81
REQUESTING A M&C CORRECTION
Contract, Service AgreementVendor quote, bill, invoice, etc.RFP, Newspaper listingNSLP documentation or student enrollment
dataBoard Minutes, ResolutionsBudgetAny other documentation in existence as of
date of submission of Form 470 or Form 471 to prove error was ministerial/clerical
82
EXAMPLES OF SOURCE DOCUMENTATION
83
QUESTIONS ON FORM 471, ITEM 21 ATTACHMENTS, M/C
ERRORS?
Program Integrity Assurance (PIA) ReviewChecks for rule compliance
eligible serviceseligible entitiesappropriate discount
Almost everyone receives a PIA call (document contacts with PIA)
If they are going to deny an FRN, they will tell you so and give you 1 more chance to submit new information
84
STEP 7: PIA REVIEW
THEN WHAT?
WaitReturn PIA calls/e-mails
Ask for extension if absolutely necessaryE-mail Julie if you’re unsure of answersCheck status of 471 on SLD website
85
FCDL = Funding Commitment Decision Letter
Tells you which funding requests (block 5’s) of Form 471 are approved or denied
Provides information for Form 486Can appeal if you don’t agree with your
decision*Must do so within 60 daysAppeal first to the SLD. If SLD denies,
appeal to the FCC within 60 daysAlways appeal!
86
NEXT: SLD MAILS FCDL*
Signifies that it’s OK for SLD to pay any invoices for that FRN
Lists who approved tech plan Certifies CIPA complianceMust be postmarked no later than:
120 calendar days after the Service Start Date featured on the Form 486 or
120 calendar days after the date of the Funding Commitment Decision Letter
whichever is later.Submit online using info from FCDL
Use 07/01/2012 as service start date for FY 2012 (Yr 15)
Form 486 Approval Letter Mailed*87
STEP 8: APPLICANT FILES FORM 486*
Filtering and Internet Safety PoliciesISP must have been adopted after public
hearingRequired for any school or library receiving:
either Internal connections or Internet accessRecipients of only Telecommunications
services are exempt from E-rate CIPA compliance
Consortium members submit Form 479 to consortium leader certifying compliance in order for leader to submit Form 486
88
CIPA: ORIGINAL REQUIREMENTS*
New CIPA requirements becomes effective 7/1/2012Requires schools’ (not libraries) Internet Safety
Policies include ".. . educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response." This means that schools are required to teach
online safety to students as a prerequisite to receiving E-rate funding
Local boards decide frequency and delivery of online safety/cyberbullying educationCan’t be once every 4 years
Establish policy, follow policy and document implementation
89
NEW CIPA REQUIREMENTS
Notice of public hearing or public meeting (such as school board meeting) where CIPA policy was considered and voted uponAgenda for meeting – show opportunity for public input/comment before adoption of CIPA policy
Other documentation for opportunity for public comment
Filtering records, purchase orderDocumentation of cyberbullying/appropriate
online behavior education for all minors90
CIPA DOCUMENTATION
91
LET’S LOOK AT THE FORM 486
http://www.sl.universalservice.org/menu.asp
92
QUESTIONS ON PIA REVIEW, FCDLS,
FORM 486, CIPA?
Two choicesDiscounts on bills (vendor invoices USAC)ORReimbursement process (applicant pays bills in full,
then invoices USAC)Must select one or the other for entire yearIf you want discounted bills, call provider as soon
as you are fundedMany have additional forms to complete
93
HOW DO YOU GET E-RATE $?
Discounts appear on applicant’s billService provider submits Form 474 to USAC
the Service Provider Invoice Form (SPIF)Provider should get reimbursed by SLD within
30 – 60 days from date of submissionApplicants do nothing except make sure they
are getting discounts they deserve on billsDo the math!
94
DISCOUNTED BILLING METHOD
Applicant pays bill in fullApplicant submits Form 472 – BEAR Form for
reimbursement* Quarterly, semi-annually, or at end of yearComplete one BEAR for each SPINMust contain SPIN signature on last pageSend or fax to SPIN SPIN will mail or fax back
Calculated based on eligible charges on actual billsNot AP register or amount committedSubtract ineligible charges
95
REIMBURSEMENT METHOD
Deadlines:October 28 (following close of funding year)
for recurring services; January 28 for non-recurring servicesCan request extension if good cause exists
SLD approves BEAR and sends approval letter to vendor and copy of letter to applicant
SLD then sends check to vendorVendor must send check to applicant within
20 business daysCall SLD if you don’t get a check in a timely
manner after receiving approval letter 96
REIMBURSEMENT METHOD
Applicant and Vendor must have PINs to file online BEARs
Applicants completes BEAR OnlineElectronically sent to vendorVendor certifies or deniesIf approved, applicant receives e-mail and
BEAR is automatically sent to USAC for payment
If denied, applicant receives e-mail and must refile the BEAR from scratch
97
ONLINE BEAR PROCESS*
When determining the amount to list on a BEAR, create a quick spreadsheet showing each month’s total charges, and total ineligible charges
What are the ineligible charges? Varies by vendor, but these are known to be ineligible: Property Tax Fees Universal Service Administrative Fee
USF fees themselves ARE eligible Late payment or finance charges USF Cost Recovery Fees Paper statement fees Equipment charges (on P1 bills) Equipment insurance fees Directory listing fees Non-published phone number fees Payphone service
Here’s an example of what your spreadsheet may look like: 98
INELIGIBLE CHARGES ON BILLS
Verizon Account: 215-235-1232 Ineligible Charges Total Eligible Charges
non-published #
July $ 200.10 $ 2.75 $ 197.35
Aug $ 200.20 $ 2.75 $ 197.45
Sept $ 200.30 $ 2.75 $ 197.55
Oct $ 200.20 $ 2.75 $ 197.45
Nov $ 201.30 $ 2.75 $ 198.55
Dec $ 203.30 $ 2.75 $ 200.55
Jan $ 202.20 $ 2.75 $ 199.45
Feb $ 201.30 $ 2.75 $ 198.55
Mar $ 200.30 $ 2.75 $ 197.55
Apr $ 203.20 $ 2.75 $ 200.45
May $ 200.10 $ 2.75 $ 197.35
June $ 203.50 $ 2.75 $ 200.75
$ 2,416.00 $ 33.00 $ 2,383.00
Total Charges $ 2,416.00
Ineligible Charges $ 33.00
Eligible Charges $ 2,383.00
E-rate Discount 65%
E-rate Reimb. $ 1,548.95 99
100
LET’S LOOK AT THE FORM 472 BEAR
http://www.sl.universalservice.org/menu.asp
Sent only to applicantsAuthorized personBilled Entity (BEN) address
Contains all invoice (Form 472 and Form 474) payment authorization amounts for the Billed Entity approved during that quarter for all funding years
Review to ensure you agree with disbursements
101
QUARTERLY DISBURSEMENT REPORTS
File Form 500 to either:Change a service start date or a contract
expiration dateCancel or reduce a funding commitment
Warning: reductions or cancellations of funding commitments are irreversible
Not required, but strongly suggested to file Form 500 if FRN not needed, or large amount of commitment is not used
102
OPTIONAL FORM 500*
103
QUESTIONS ON FORM 472
REIMBURSEMENTS, DISCOUNTED
BILLING, FORM 500?
FY 2012 is YELLOW!For services rendered 7/1/2012 - 6/30/2013471 application window slated to open early
January 2012Window is expected to close mid March 2012Form 470’s being accepted now!
104
FY 2012 (YEAR 15) COMING SOON!
Happy 15th Birthday,E-rate!
For services rendered 7/1/2011 - 6/30/2012FY 2011 is BLUE
72% of PA Priority 1 FRNs funded as of 10/12/2011
File the 486 after FCDL arrivesRequest discounted bills from vendors, if
desiredWatch PA E-rate Listserve closely
105
FY 2011 (YEAR 14) DETAILS
Funding Year ended June 30, 2011 for recurring servicesFY 2010 was PINK
Deadline for submitting BEARs (Form 472s) is October 28, 2011
Deadline for submitting invoices for non-recurring services is January 28, 2012 (unless an extension has been granted)
List available at training and watch PA E-rate listserve for “list” of affected entities List available at training
File for extension if you haven’t submitted your BEAR!
106
FY 2010 (YEAR 13) NOT OVER YET!
107
QUESTIONS ABOUT FUNDING YEARS AND WHAT’S DUE WHEN?
BUT WAIT!THERE’S MORE!
108
Two types of SPIN changes: Corrective: Mostly for data-entry errors
Can be done pre-and post-commitmentOperational: When actually switching
vendorsCan only be done post commitment and for
legitimate reasonMust submit request to the SLD requesting
changeCan do so using Submit a Question feature*
Can request to split an FRN*Allocate $ to 2 providers in same funding
yearDon’t forget to file 486 for new FRN
109
CHANGING SERVICE PROVIDERS*
Can no longer switch vendors because of lower priceSome vendors were abusing lax SPIN change rules
and not bothering to participate in 470 bidding process
Legitimate reasons include:breach of contractservice provider is unable to performbankruptcy
Must select vendor that received the next highest point value in the original bid evaluation, assuming there was more than one bidder
110
CHANGING SERVICE PROVIDERS
E-rate PINs can be used to file E-rate forms onlinePIN assigned to a person and is specific to that
entity while employed at that entity Not given to an entity
No way to request a PINMust sign a paper certification of a 470, 471 or
486SLD will mail them a PIN in a small white mailerCan still submit these forms online, but cert page must
be signed and mailed to USACPIN then may be used to 470, 471, 486, and BEAR
Forms
111
E-CERTIFICATION/PINS*
Applicants required to pay non-discounted portion of cost
Cannot be waived by the vendorVendor cannot provide a “grant” Funding must be in budget or draft
budgetMust keep all invoices and copies
of cancelled checks for 5 years after last day to receive service
112
PAYING YOUR SHARE
SS required when a change is made to any service on your approved 471, Item 21 attachments
After FCDL issuedApplicant must seek SLD
approval which meets certain conditionsGood idea to seek approval
PRIOR to doing substitution in case it’s not approved by SLD.
113
SERVICE SUBSTITUTIONS*
Depends on the form and requirementForm 470 – noForm 471 – noForm 486 – no
but they will send a reminder letter and you can then file if you missed the original deadline
Form 472 BEAR – yes. Must be submitted by original deadlineService delivery – recurring services – no
Services must be delivered between July 1 – June 30Service delivery – non-recurring services – yes
Installations and equipment purchases have until Sept 30 If applicant needs more time, they must request extension prior to
Sept 30PIA inquiries – yes.
If you cannot provide the info by the deadline, you may request extension, but it may not be granted
114
CAN YOU REQUEST EXTENSIONS?
Consortium Name of consortium
leader, consortium member name, type of service, signature, date and title of people signing document
Sample LOA available on SLD website
Must be signed/dated before filing of Form 471
Consultant Must be signed by
applicant before the consultant does ANY work on behalf of the applicant
115
LETTERS OF AGENCY*
Most data on SLD website, using DRTDownload by state, by SPIN, by entity, etcUpdated nightlyShows:
Entity info / 471# / FRN # / 470 # / SPINif FRN fundedwhether 486 was submittedlast date to invoiceoriginal requested amount & committed amountdiscountinvoice paid and by what modeetc.
E-rate Central Database Tool*
116
DATA RETRIEVAL TOOL*
PEPPM is contract administered by IU 16 for PDEState posts Form 470 when contract is bidSchools and libraries may skip 470 process and
purchase directly from PEPPM for P2 equipment and services
Obtain quote from PEPPM vendor(s) for products neededBe sure quote is dated before Form 471 is submitted
Use quote for funding request on Form 471E-mail with details of which 470 number to use is
sent to PA E-rate listserve in JanuaryCo-Stars is not an E-rate eligible contract
117
USING PEPPM FOR P2 PURCHASES
COMMUNITY USE OF SERVICES
Schools may now permit general public to use the schools’ Internet access during non-operating hours – at the schoolUntil February 2010, such Internet access was
only permitted to be used by K-12 students and staff for educational purposes only, putting many schools and most vocational technical schools in a difficult position
In February 2010, the FCC permitted such usage on a temporary basis
118
3 conditions for community use of school facilities: Usage is permitted only during a school’s “non-
operating” hours or summer School may not request E-rate funding for a higher
level of service than would be required for educational purposes
Schools may not charge for the use of the Internet access, but may charge reasonable fees to cover overhead costs from individuals that use the schools' services and facilitiesOrganizations using a schools' services are permitted
to recover related costs (e.g., “curriculum development and presentation costs”) from attendees
119
COMMUNITY USE OF SERVICES
COMMUNITY USE OF SERVICES
School not required to open facilitiesInternet filtering rules must remain intact
during useNew rule in no way permits schools to share
their bandwidth with other ineligible entities, such as an off-site after-school program at the YMCA or community center
Also does not permit partially eligible entities, such as a Diocesan office that provides services to both schools and the church, to stop cost allocating the ineligible portion of Internet use
120
121
WHAT SHOULD ALWAYS BE ON YOUR
MIND?
Rules require all applicants to retain ALL E-rate and related documents for 5 years from last day of service in a particular funding year
If auditor visits in 4 years, and documents are missing, it could be the basis to recover all funding from that funding year
Document and keep everything remotely related to E-rateLike what?
122
AUDITS AND DOCUMENT RETENTION*
Tech plan and approval letter Consultant agreements RFP and proof of publication
date All vendor correspondence Winning and losing bids Professional development
records Bid evaluation documentation Proof of authorization to sign
E-rate forms Filtering records and
payments NSLP forms AUP and proof of public
meeting
Signed contracts NSLP documentationBudgetsPurchase ordersPacking slipsAsset or inventory
records Installation recordsAll InvoicesFront and back of checks
as proof of payment to vendor (non-discounted share)
Proof of receipt of payment from vendor (BEAR checks)
123
DOCUMENTS TO RETAIN*
124
QUESTIONS ABOUT DOCUMENT
RETENTION AND AUDITS?
SLDClient Service Bureau (CSB)
E-rate “Help Desk” where applicant & service providers can get answers to questions
Accessed via 888-203-8100Submit a Question
Available on SLD websitePA E-rate Coordinator
E-mail jtschell@comcast.netwww.e-ratepa.org
125
E-RATE HELP
126
APPLICATION FLOWCHART
The end!
127
QUESTIONS?