E-RATE AND YOU A RELATIONSHIP MADE IN H…

Universal Service Administrative Company

E-RATE AND YOUA RELATIONSHIP MADE IN H…


WELCOME

• TO DEATH… by PowerPoint….


E-Rate and YouA Relationship Made in H…Mary Mehsikomer, State E-Rate Liaison

November 2007

Universal Service Administrative CompanyOverview

• Schools and Libraries Program• Provides discounts to eligible schools and

libraries for Telecommunications Services, Internet Access, Internal Connections, and Basic Maintenance

• Applicants can be schools, libraries, or consortia, but only eligible recipients of service can receive discounts

• Applicants must apply for discounts each year (Form 471 application filing window)

• Funding cap each year is $2.25 billion4


• Funding year – July 1 through following June 30• Competitive Bidding Process – Form 470

July – 28 days before end of 471 window (usually February)• Services Selected – Form 471

November – February (check website for exact dates)(60 days after release of Eligible Services List from FCC)

• Receipt of Services Confirmation – Form 486120 days after USAC response from 471 letter or120 days after the service start date

• Billing Entity Reimbursement Form – Form 472 or Form 474120 days after date of the Form 486 Notification Letter or120 days after the last date to receive service

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• Forms for Applicants• Technology plan – Letter from MDE• Form 470• Form 471• Form 486• Form 472 – BEAR

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BEAR Billed Entity Application Reimbursement (Form 472)BEN Billed Entity Number CIPA Childrens Internet Protection ActFCC Federal Communications CommissionFRN Funding Request NumberFRN FCC Registration Number FCDL Funding Commitment Decision Letter (Form 471)FY Fiscal Year (for normal people, not E-rate)FY Funding Year (E-Rate)ISTE International Society for Technology and EducationNIF Non-Instructional FacilitiesNL Notification Letter (Form 486)NSLP National School Lunch ProgramPCS Personal Cellular ServicePIA Program Integrity AssuranceRAL Receipt Acknowledgement Letter (Form 471)


• Application process• Eligibility• Technology planning• Competitive bidding / Form 470• Calculating discounts• Funding requests / Form 471• Application review / Funding commitments• Starting services / Form 486• Invoicing USAC / Form 472 (BEAR) or Form

4748


Calculating Discounts

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% Eligible Students Urban Rural Less than 1% 20% 25% 1% - 19% 40% 50% 20% - 34% 50% 60% 35% - 49% 60% 70% 50% - 74% 80% 80% 75% - 100% 90% 90%

Discount Matrix


EligibilityApplicants

• Eligible Entities - Schools• Must meet the statutory definition of elementary or

secondary school found in the No Child Left Behind Act of 2001.

• Must be a non-profit institutional day or residential school, including a public charter school, that provides elementary or secondary education, as determined under state law.

• Must not be operating as a for-profit business.• Must not have an endowment exceeding $50

million.

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• Eligible Entities - Schools• Pre-kindergarten, Adult Education, Juvenile

Justice students/facilities may be eligible. In MN, Pre-K and Juvenile Justice are eligible.• Must provide elementary or secondary

education as determined under state law.• USAC requests updated eligibility

information from state departments of education every two years.

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• Consortia• Eligible schools and/or libraries may form

consortia with• Other eligible schools and/or libraries• Certain health care providers• Public sector (governmental) entities

• Only eligible entities can receive discounts

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Eligible ServicesBoth

• Priority 1 – funded first• Telecommunications Services

• Basic telephone service — wireline or wireless phone service (local, cellular/PCS, and/or long distance)

• Voice mail• Transmission services (T-1, DSL)

• Internet Access• Basic conduit access to the Internet

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Eligible ServicesBoth

• Priority 2• Internal Connections (switches, hubs,

routers, wiring)• Basic Maintenance on Internal Connections

• Priority 1 funded first, then Priority 2 begins with neediest applicants (90% first, then 89%, 88%, etc.).

• Internal Connections funded in only two out of five funding years. (may or may not make a

difference).14



• Educational Purposes• Activities that occur on school property are

presumed to be integral, immediate, and proximate to the education of students or the provision of library services to library patrons and therefore qualify as educational purposes.

• Customary work activities of employees of a school or library are presumed to fall under the definition of education purposes.

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SCHOOLS:• Administrative buildings• School bus barns and

garages• Cafeteria offices• Facilities associated with

athletic activities16

• Examples of Non-instructional Facilities (NIFs) that can receive Priority 1 services



• Educational Purposes – Priority 1• Wireless Telecommunications Services

used offsite may be eligible. For example,• School bus drivers delivering children to

and from school when cell phones are need to make sure no child is left behind.

• Cell phones for teachers or other school staff accompanying students on a field trip or sporting event.

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• Educational Purposes – Priority 2• Priority 2 services to NIFs are NOT

eligible unless those internal connections are essential for the effective transport of information to an instructional building of a school.

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Technology PlanningApplicants

• Technology Plans• Not required for basic telephone service

(but they’re a good idea anyway)• Must be written before Form 470 filing• Must be approved by a certified approver

before the Form 486 is filed or discounted services start, whichever is earlier

• Must cover entire program year• Must cover five specific elements

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Technology PlanningApplicants

• Technology Plans• Must cover five specific elements:

• Goals / Strategies for using technology• Professional development• Needs assessment• Sufficient budget• Evaluation process

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Competitive Bidding / 470Applicants

• Filing Form 470 opens a competitive bidding process.

• Can also issue a Request for Proposals (RFP).

• Applicants are responsible for ensuring an open and fair process and selecting the most cost-effective provider of the desired services.

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• Request for Proposal (RFP)• Not required under FCC rules, but a good

idea• Must comply with local and state

procurement laws• Describes your project scope, location,

other requirements in detail• Even if you have an RFP, you must

describe the services you desire on your Form 470.

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• Competition• Goal is to have as many bidders as

possible• Promotes better service and lower prices

• Fair and open process• All bidders treated the same• No advance knowledge of RFP information• No secrets in the process• All bidders know what is required of them.

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• Selecting service providers• Applicants must choose the most cost-

effective solution to their Form 470 or RFP, with price as the primary factor• Other factors can be considered, but

price must be the most heavily weighted.• Evaluation process should be carefully

documented and that documentation must be maintained.

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• Form 470 Deadline• Absolute deadline is 28 days before the

close of the Form 471 filing window.• However, if the applicant waits until that

date to file a Form 470, the following must all occur on the last day of the window:• Selecting a service provider• Signing a contract• Signing, dating and submitting Form 471.

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Competitive Bidding / 470Applicant Tips

• Retain worksheets, bid evaluation criteria, winning AND LOSING bids

• Prepare a memo to file if you received only one bid or no bids

• File (and certify) online• Reduces errors and speeds processing• USAC will issue you a PIN

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What should I keep?

• Keep all documents FIVE years after the last day of service for the E-rate funding year.

• Applicants, service providers, and consultants should ALL retain E-rate documentation.


TOP 5 MISSING DOCUMENTS

• Discount verification (NSLP, etc.)

• Asset listings

• Signed and dated contracts

• Consultant agreement or LOA

• Bid evaluation/award schedule



• Form 470 Receipt Notification Letter (RNL)

• Cover page of important reminders• Notifies applicant that Form 470 has been

posted to the USAC web site• RNL generated before certification• Contains Allowable Vendor Selection /

Contract Date

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Calculating DiscountsApplicants

• Discounts are calculated using• Percentage of students eligible for

National School Lunch Program (NSLP)

• Urban or rural status of county in which school or library is located (from web site)

• These two pieces of information are carried into the Discount Matrix

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Funding Requests / 471Applicants

• Form 471• Provides specific information on services,

service providers selected, and contracts• Provides discount calculation information• Must be filed for each funding year• Contains certifications of compliance• Can include one or more funding requests,

but break out Form 471s based on service category.

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• Form 471 Deadline• Must be filed online or postmarked on or

before the close of the Form 471 application filing window.

• Forms 471 filed after the close of the window will be considered after all Forms 471 filed in-window.

• Certifications for associated Forms 470 also must be filed online or postmarked before the close of the window.

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• Contracts• Applicants and service providers must sign

contracts for services that are not provided under tariff or under month-to-month arrangements

• Contracts can cover more than one year or contain extensions, but applicant must indicate these options in the Form 470

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Funding Requests / 471 Applicant Do’s and Don’ts

• WAIT AT LEAST 28 DAYS BEFORE• Selecting a service provider• Signing a contract• Signing and dating the Form 471• Submitting the Form 471

• These actions must occur in this order.• Refer to 470 RNL for allowable date.• Both applicants and service providers must

sign and date all contracts.34


Funding Requests / 471 Applicant Tips

• Remove ineligible costs from funding requests

• Document ineligible costs carefully• 30% rule – if 30% or more of the dollar

value of the request is for ineligible products and services, the entire request will be denied

• Work with your service provider(s) to create your Item 21 attachment(s)

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Funding Requests / 471 Applicant Tips

• Don’t combine Priority 1 and Priority 2 requests on the same Form 471.

• Review of Priority 2 requests may hold up Priority 1 commitments.

• “When in doubt, split it out.”

• File (and certify) online• Reduces errors and speeds processing• USAC will issue you a PIN

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Funding Requests / 471Both

• Form 471 Receipt Acknowledgment Letter (RAL)

• Cover page of important reminders• Provides confirmation of certain information

entered from Form 471• Data entry errors may be corrected• Applicants can request funding

reductions but not funding increases

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Application Review Applicants

• Forms 471 are reviewed by Program Integrity Assurance (PIA) for compliance with program rules concerning areas such as:

• Competitive bidding process• Contracts• Discount calculation• Sufficient budget• Establishing Form 470• Technology plan• Children’s Internet Protection Act

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Application Review Applicant Tips

• Provide information to Program Integrity Assurance (PIA) promptly – 15 days

• Work with your service provider to comply with information requests.

• Make sure your answers respond completely to the questions asked.

• Ask for more time to respond if you need it.• However, if you ask for more time, your PIA representative

will work on other applications and you may wait longer for a decision.

• Check the 471 Application Status Tool.39


Funding Commitments Both

• Funding Commitment Decision Letter (FCDL)

• Cover page of important reminders• Reports status of individual funding

requests:• Funded• Not funded• As yet unfunded (Priority 2 requests)• Cancelled

• May receive more than one FCDL40


Funding CommitmentsApplicant Tips

• Check all entries on the Funding Commitment Decision Letter (FCDL) carefully to make sure there are no data entry errors.

• Use the information on the FCDL to prepare your Form 486.

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Starting Services / 486Applicants

• Form 486• Notifies USAC that services have started

and invoices can be paid• Certifies that Tech Plan (if required) meets

program requirements.• Certifies the status under Children’s Internet

Protection Act (CIPA).• Lead members of consortia may be required to

collect CIPA certifications from consortium members on a separate form (Form 479).

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• Children’s Internet Protection Act (CIPA)• Applicants must certify compliance with

requirements:• Internet safety policy• Public notice or meeting• Technology protection measure (filter)

• CIPA does not apply to requests for plain old telephone service, but does apply to any request for Internet access.

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• Form 486 Deadline• Form 486 must be filed online or

postmarked no later than• 120 days after the Service Start Date OR• 120 days after the date of the Funding

Commitment Letter whichever is later.

• If the Form 486 is late, discounts will be reduced to reflect the submission date.

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Starting Services / 486 Both

• Form 486 Notification Letter (486NL)• Cover page of important reminders• Provides confirmation that a Form 486 has

been successfully data entered.• Reports Service Start Date or Adjusted

Service Start Date• USAC will accept invoices from applicants

(Form 472 - BEAR) or service providers (Form 474) once the Form 486 is certified.

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Starting ServicesBoth

• Obligation to Pay Non-discount Share• Applicants are required to pay their share

of the cost (the “non-discount” portion or share) — this share cannot be donated, forgiven or ignored.

• Service providers cannot waive or credit the applicant’s share.• Offers to reduce price must be incorporated into

the “total pre-discount amount.”

• Service provider must bill the applicant for non-discount share of services.

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Invoicing / 472 or 474Both

• Billed Entity Applicant Reimbursement (BEAR) Form 472 is filed by the applicant and certified by the service provider after the applicant receives services and pays for the services in full.

• Service Provider Invoice (SPI) Form 474 is filed by the service provider when the bills to the applicant are directly discounted by the provider.

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Invoicing / 472 Applicant Do’s and Don’ts

• Form 472 (BEAR Form)• DO verify that your service provider has

signed the last page of the form before you submit it.

• DO check your calculations.• Make sure you have service provider bills that

agree with your reimbursement request.

• DO make sure you have paid your non-discount share.

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Invoicing / 472 Both

• Invoicing deadlines• Form 472 (BEAR) must be filed online or

postmarked no later than• 120 days after the last date to receive service

OR• 120 days after the date of the 486 NL

whichever is later. If using BEAR – do them quarterly.

• If the invoice is late, payment will be denied.• Extensions of invoicing deadlines may be

requested under certain conditions.49


Invoicing / 472

• BEAR Notification Letter• Cover page of important reminders• Provides confirmation that a Form 472 has

been successfully data entered.• Indicates what amounts are being paid and

reasons for reductions or denials.

• Invoice Status Report / E-notification• Indicates what amounts are being paid and

reasons for reductions or denials.• Sent only to service providers.

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Invoicing / 472

• Quarterly Disbursement Report

• Sent only to applicants

• Authorized person

• Billed Entity (BEN) address.

• Contains all invoice (Form 472 and Form 474) payment authorization amounts for the Billed Entity for all funding years approved during that quarter.

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Appeals

• USAC decisions can be appealed to USAC and to the FCC.

• Applicants MUST appeal first to USAC.• Can appeal to the FCC if USAC does not

grant the appeal.

• Can be filed electronically or on paper.• Must be filed electronically or postmarked

within 60 days of the USAC decision.• Requests for waivers of rules must be

filed with the FCC.52


General Tips

• If you submit something to USAC:• Check your work• Sign and date it (online or on paper)• Submit it by the deadline• Keep a copy and proof of submission

• If USAC sends something to you:• Read it• Take all appropriate actions• Save it for AT LEAST FIVE YEARS.

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Assistance

• Schools and Libraries / USAC web site

http://www.universalservice.org/sl/

• Client Service Bureau

• Use the “Submit a Question” link on the web site

• Fax toll-free at 1-888-276-8736

• Telephone toll-free at 1-888-203-8100

• Form instructions54


Assistance (continued)

• Mary Mehsikomer, Minnesota State E-Rate Liaison

(651) 582-8827

[email protected]

E-RATE AND YOU A RELATIONSHIP MADE IN H…

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