E-Rate Central E-Rate Status, Steps, and Strategies Lansing, Michigan October 22, 2002 10/19/02.
-
Upload
alexander-bailey -
Category
Documents
-
view
214 -
download
0
Transcript of E-Rate Central E-Rate Status, Steps, and Strategies Lansing, Michigan October 22, 2002 10/19/02.
E-Rate Central
Workshop Agenda
• Overview of E-Rate Program• Current year status (FY 2002)
• Application for next year (FY 2003)
• Special Issues– Technology Plans and CIPA – Deadlines– Program Compliance – SLD Databases
• Q & A
Major Focus
E-Rate Central
• Funded by carriers under Telecommunications Act of 1996
• Not a typical government grant program – Funding not based on competitive applications
– Funds are provided indirectly as discounts on
eligible services from the vendors
• Annual applications required – First year was FY 1998
– Current year is FY 2002– Next application year is FY 2003
General Concepts
E-Rate Central
General Framework
• 20-90% discounts on three types of services:– Telecommunications– Internet Access– Internal Connections (Networking)
• Annual applications for funding– Annual cap of $2.25 billion– Priority 1: Telecom and Internet Access – Full funding– Priority 2: Internal Connections – High discount funding only
• Basic SLD overview– http://www.sl.universalservice.org/overview
E-Rate Central
Eligible Services: Telecom/Internet
• Basic telephone (local & long distance)
• Advanced telecom (T-1, ATM, Frame Relay, etc.)
• WANs (only if provided by telecom carrier)
• Mobile services (‘instructional use”)
• PBXs eligible only as Internal Connections• Internet access (not content)
E-Rate Central
Eligible Services: Internal Connections
• Eligible:– Network wiring– Routers and hubs– Switches– Network servers and
operating software– Wireless LANs– PBXs and key systems
• Ineligible:– Personal computers and
modems– Asbestos removal– Electrical wiring– Teacher training– Application software– Internet filters/firewalls
Mixed eligibility issues: http://www.sl.universalservice.org/reference/costallocationguide.asp
E-Rate Central
• Important source of technology funding (FY 1998 – FY 2002)
– $9.4 billion nationwide – $268 million for Michigan
• Time-consuming, bureaucratic, and confusing program
– Forms 470, 471, 472, 479, 486, and 500
– Service eligibility and discount rate issues
– Long lead time competitive bidding procedures
– Strict application review process
– Additional procedures for consortiums
E-Rate Opportunities and Issues
E-Rate Central
Basic E-Rate CyclePre-Commitment
Form 470 - Describes services required(fall) - Posted on SLD Web site
Form 471 - Calculates allowable discount rate(mid-Jan.) - Requests funding for specific services/vendors
- Requires billing or contract documentation
PIA - Detailed SLD review of applications(spring/summer) - Often requires additional documentation
E-Rate Central
Basic E-Rate CyclePost-Commitment
Form 486 - Confirms use of approved services (summer) - Certifies tech plan and CIPA compliance
- Appeals and SPIN Changes as required
Funding Alternatives (throughout year)
SPI - Service provider discounts bills(Form 474) - Schools pay only undiscounted amount
BEAR - Discounts reimbursed after the fact(Form 472) - Based on actual bills paid
E-Rate Central
FY 2002: Current Issues
• Remaining funding waves and “ripples”
• Form 486 requirements– October 29th and later deadlines– Technology plans and CIPA compliance– Form 479s for consortia
• Other issues– Appeal processing– BEARs vs. discounted bills– Non-recurring service deadline
E-Rate Central
New Program Developments
• New forms (in scanning format and/or online)
• Expanded online SLD databases
• New for FY 2003– Updated eligibility list– Yellow SLD correspondence
• Possible changes for FY 2004
E-Rate Central
Form 470: Purpose
• Identifies applicant
• Generally describes services needed
• Begins mandatory 28-day waiting period
• Does not replace state and local competitive bidding rules
E-Rate Central
Form 470: Block 1
• Application #: SLD assigns
• FY 2003: July 1, 2003 — June 30, 2004
• Contact Person: For SLD and vendors
– Can use Item (11) for alternative vendor contact
– Do NOT let a vendor act as applicant contact
E-Rate Central
Form 470: Block 2
• Be broad and inclusive
• Item (7): Check ALL that could apply
• Tariff has specific regulatory connotation
• MTM is an allowable category for:
– Internet, cellular, paging
• Items (8) - (10): Check “YES” or “NO”
E-Rate Central
Service or Function Quantity and/ or Capacity
Telecommunications – Item (8) Local and long distance voice services 50 existing or new phone lines
Cellular/ PCS services 20 existing or new users
Paging services 25 existing or new users
High-speed access (ISDN, DSL, T-1, etc.) 5 buildings
Videoconferencing links 5 buildings
Internet Access – Item (9) Dedicated access services 5 buildings
Dial-up services 25 user accounts Internal Connections – Item (10)
New LAN network 2 buildings, 50 classrooms Upgraded LAN network 1 building, 30 classrooms LAN network maintenance 4 buildings, 100 classrooms New or upgraded telephone systems 2 buildings, 200 lines Telephone system maintenance 5 buildings, 250 lines Internet routers 5 buildings
Form 470: Block 2 Examples
E-Rate Central
Form 470: Automatic Rejection
• Wrong version (should be April 2002)
• Missing applicant and contact information
• Other missing blocks/pages
• Missing or invalid certification
• Wrong program year specified
Not many Form 470s are rejected, but many
are filed too late for Form 471 filings
E-Rate Central
Form 470: Filing Online
• Assures earliest “Allowable Contract Date”
• Provides check on field information
• Use Form 470 Application # to resume data entry at any point before submission
• Important: Must use electronic signature or mail signed certification page to SLD
E-Rate Central
Form 470: Filing by Mail
• 28 day waiting period starts after Form is posted, NOT received.
• Form 470 receipt acknowledgment letter will show “Allowable Contract Date”
• Can check posting on SLD web site
E-Rate Central
Problem: Narrow and Early Contract Window
Form 470 Posting
Form 471 Application Window
Oct./Nov. Dec. Jan.
Contract Signing Window
Jan. 16th
E-Rate Central
Contracting Tips• Broadly define service requirements in Form 470• Work closely with vendors
– Structure contract– Prepare eligibility exhibits– Set contract signing date
• “Contract” can be a contingent agreement– Subject to final board and budget approval– Allow substitution of equipment models– Prices subject to change
• Consider use of OGS contracts– Can serve as “standing bids”– Must specify specific vendor in multi-vendor contracts– Request best and final prices or use mini-bid
E-Rate Central
Form 471: Purpose
• Calculation of discount rate(s)
• Requests specific discount on each tariffed, monthly, and contract service
• Separates eligible from ineligible costs
An important and complex form
E-Rate Central
Discount Rates
• All flow from individual school data • All other applicants use weighted or simple average
depending on type of applicant• Based on need
– Poverty• Defined by National School Lunch Program http://www.fns.usda.gov/cnd/IEGs&NAPs/IEGs.htm
– Location• Rural vs. Urban
E-Rate Central
Discount Percentages
Urban Rural
<1% 20% 25%
1-19% 40% 50%
20-34% 50% 60%
35-49% 60% 70%
50-74% 80% 80%
75-100% 90% 90%
% of Students Eligible for School Lunch Program Discounts
E-Rate Central
Alternative Measures
• Comparable measures (milk/breakfast programs, Medicaid/public housing data)
• Survey (can extrapolate from 50% response rate)
• Sibling searches
• Feeder system not approved
Note: SLD reviews using state lunch program participation
data, so document all higher eligibility data
E
E-Rate Central
Individual School
1 3 4 5Name of School Urban or
Rural
U or R
Total
# of
Students
# of Students
Eligible for NSLP
Oak Elementary U 100 55
6% Students
Eligible for
NSLP
Col. 5/Col. 4
55%
7Discount
% from
Discount
Matrix
80%
Complete Worksheet A, Columns (1)-(7) Columns (3)-(7) step through discount calculation
E-Rate Central
School District
1 3 4 5 8Name of School Urban or
Rural
U or R
Total
# of
Students
# of Students
Eligible 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% Students
Eligible for
NSLP
48% 70%
7Discount
% from
Discount
80%70%
Complete Worksheet A, all columnsColumn (7) gives site-specific discounts
Item (10c) gives the shared (weighted average) discount
E-Rate Central
Library System
1 3Name of Library System
(if all on one site) or Individual Library Outlets
(if multiple sites)
Urban or
Rural
U or R
Treetop Branch Library RGreenleaf Branch Library UAcorn Branch Library U
System Totals for calculating Shared Discount
Name of School District
in which site in Column 1 is located Weighted Average Discount
for the School District in Column 4
(round to nearest %)
Treetop School DistrictShady Grove School District
67%10c Shared Discount % (Col. 5 total divided by # of sites in Col. 1. Round to nearest %)
200%
71%46%
Nutburg School District 83%
4 5
Complete Worksheet B, all columnsColumn (5) provides site-specific discounts
Item (10c) gives the shared discount
E-Rate Central
Consortium
1
ELIGIBLE MEMBER ENTITIES Name of each individual school, school district and/or
library/library system in consortium
Treetop School District
Woodsville Library System
Forest 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
Complete Worksheets A or B, as appropriate Complete Worksheet C to calculate consortium discount(s).
E-Rate Central
Form 471: Form 470 Link
• Item (12): Form 470 application number
• Items (17) - (18): Allowable Vendor Selection/Contract
Date must be earlier than Contract Award Date
• Item (22): Block 4 Entity or Worksheet number
• Item (23), Column (J): Discount rate from Worksheet
Form 471: Discount Rate Link
E-Rate Central
Form 471: Vendor Link
• Item (13): SPIN– Source: SLD’s BEAR & SPIN Contact Search
• Item (14): Beware “d.b.a” names
• Item (16): Billing Account Number
E-Rate Central
Form 471: Contract Link
• Item (15): Contract ID, “T”, or “MTM”
• Items (17) - (18): Contract Award Date must be later than Allowable Vendor Selection/Contract Date
• Item (19a): No earlier than 07/01/2003
• Item (19b): Normally 06/30/2004
• Item (20): Hopefully 06/30/2004 or later
• Item (21): Attachment #
• Item (23): Charges, eligibility, and funding request
E-Rate Central
Form 471: Block 5 Examples
• Local telephone• Cellular• Internet (direct)• PBX maintenance• New LANs
– Tariff (monthly)– Month-to-month billing– Annual contract (quarterly)– 2nd year of 3 year contract– Contract (non-recurring)
E-Rate Central
Local Telephone (tariff)Form/Item Description
Form 470 Service request posted annually
From 471 One FRN
Category Telecommunications
Contract Number "T"
Billing Account Number Main telephone number
Form 470 Application Number From current Form 470
Allowable Contract Date From current Form 470
Contract Award Date blank
Service Start and End Dates 07/01/2003 and 06/30/2004
Contract Expiration Date blank
Attachment Summary pages of recent bill
Ineligible Portion Voice mail, pay phones
Recurring Charges Est. average monthly charges
E-Rate Central
Cellular (month-to-month)Form/Item Description
Form 470 Service request posted annually
From 471 One FRN
Category Telecommunications
Contract Number “MTM"
Billing Account Number Account number
Form 470 Application Number From current Form 470
Allowable Contract Date From current Form 470
Contract Award Date blank
Service Start and End Dates 07/01/2003 and 06/30/2004
Contract Expiration Date blank
Attachment Recent bill, user list
Ineligible PortionBus drivers, maintenance personnel, equipment
Recurring Charges Est. average monthly charges
E-Rate Central
Internet - Direct (quarterly)Form/Item Description
Form 470 Service request posted annually
From 471 One FRN
Category Internet Access (and internal connections?)
Contract Number “MTM”
Billing Account Number Account number
Form 470 Application Number From current Form 470
Allowable Contract Date From current Form 470
Contract Award Date blank
Service Start and End Dates 07/01/2003 and 06/30/2004
Contract Expiration Date blank
Attachment Contract or recent bill
Ineligible Portion Content (router may be internal connections)
Recurring Charges Quarterly charges/3
E-Rate Central
PBX Maintenance (2nd year)Form/Item Description
Form 470 Posted last year
From 471 One or more FRNs
Category Internal Connections
Contract Number Identifier
Billing Account Number If applicable
Form 470 Application Number From current Form 470
Allowable Contract Date From current Form 470
Contract Award Date After Allowable Contract Date
Service Start Date 07/01/2003
Contract Expiration Date On or after 06/30/2004
Attachment Contract or recent bill
Ineligible Portion Telephone set maintenance, MACs, etc.
Recurring Charges Monthly (or one-time) charges
E-Rate Central
LANs (new contract)Form/Item Description
Form 470 Service request posted annually
From 471 One or more FRNs
Category Internal Connections
Contract Number Identifier
Billing Account Number If applicable
Form 470 Application Number From current Form 470
Allowable Contract Date From current Form 470
Contract Award Date After Allowable Contract Date
Service Start and End Dates On or after 07/01/2003
Contract Expiration Date On or after 09/30/2004
Attachment Contract and eligibility breakout
Ineligible Portion Workstations, training, etc.
Non-recurring Charges One-time charges
E-Rate Central
Form 471: Attachment
Attachment
State contract selected after Allowable Contract Date
1
Tariff or month-to-month. No contract needed.Contract signed after Allowable Contract Date
Documentation included with Attachment:Contract (applicable pages)Sample bill summary
Service Description:
Service Provider:
Contract Status:
Entity NumberContact Person
Applicant's Form IdentifierPhone Number
E-Rate Central
Eligibility Warning & Tip
• If SLD determines that more than 30% of requested amount is ineligible, entire FRN may be denied
• When in doubt — break it out!
E-Rate Central
Service Warning & Tip
• If SLD determines that more than 30% of the requested amount is not Priority 1, the entire FRN may be categorized as Priority 2– Typical problem: On-premise equipment included in
telecommunications or Internet access services
• When in doubt — break it out!
E-Rate Central
Form 471: Automatic Rejection• Wrong version (should be Oct. 2000)
• Missing applicant and contact information
• Other missing blocks/pages– At least one Block 4 worksheet
– At least one valid Block 5 funding request
• Invalid certification
• Filed after the window closes (January 16, 2003)
Form 471s can be rejected completely,or funding can be reduced or denied on individual FRNs
E-Rate Central
Form 471: Filing Online
• Promotes early SLD processing
• Provides check on field information
• Use Form 471 Application # to resume data entry at any point before submission
• Important: Must use electronic signature or mail signed certification page to SLD within the application window
• Attachments must be mailed to SLD
E-Rate Central
Form 471 Review Process
• Data entry of mailed applications– Problem resolution review– Receipt Acknowledgment Letter (“RAL”)
• Program Integrity Assurance (“PIA”)– Requests for supporting documentation– Seven day response cycles– Separate 471 for Priority 1 may speed approval– Item 25 and Selective Reviews
• Funding Commitment Decision Letter (“FCDL”)
E-Rate Central
SLD and FCC Appeals
• Must be received within 60 days of decision
• Appeal cycle is lengthy
• Post-decision procedures, if successful– SLD decisions have two-steps: Decision + FCDL– FCC decisions often referred back to SLD for resolution
When in doubt, appeal
E-Rate Central
Post-Commitment Form 486
• Confirmation of service usage and start date– The SLD won’t process any E-rate invoices on any
FRN without a valid Form 486
• Certification of technology plan and CIPA
• Filing deadlines are critical– October 29th or 120 days from FCDL or service start
E-Rate Central
Form 486: Other Issues
• Penalty for missing FY 2002 filing deadline:
Discounts paid only from 120 days prior to final filing date
• Before consortium can file Form 486:
Must collect Form 479s from all members or reduce funding accordingly
E-Rate Central
Post-Commitment Changes
• Can change services/equipment/terms– Requires Service Substitution letter
(http://www.sl.universalservice.org/reference/ServiceSub.asp)
– Tip: Keep contract specifications flexible
• Can change service provider (SPIN)– Requires SPIN Change Request letter
(http://www.sl.universalservice.org/reference/SpinChange.asp)
• Use Form 500 to cancel or reduce funding
E-Rate Central
Funding: Vendor Discounts
• Discounts applicant bills and files Form 473 (“SPI”) with SLD
• May ask applicant for applicable account and eligible usage data
• Must pay non-discounted amount• Should carefully review discount calculations
Service Provider:
Applicant:
E-Rate Central
Funding: Discount Reimbursements
• Pays bills in full and summarizes eligible payments• Files Form 472 (“BEAR”) with SLD• Must carefully track BEAR payments
• Must acknowledge BEAR before submission• Is paid by SLD, then must pay applicant
Applicant:
Service Provider:
E-Rate Central
BEAR Payment Issues
• After processing, SLD sends BEAR Notification Letter to vendor and applicant– Approval is on individual FRN basis
– Denials or rejections may require resubmission or appeal
– Checks sent to vendors approximately 20 days later
• Vendors should pay applicants within 10 days of receipt– No standard vendor practices on applicant payments
• Bankruptcy of vendor may require “Good Samaritan”
E-Rate Central
Technology Plan
• Five SLD technology plan criteria Goals and Objectives Needs Assessment Professional Development Budget Evaluation
• No Tech plan required for “basic” phone service• Tech plans approved for no more than 3 years
E-Rate Central
Children’s Internet Protection Act (“CIPA”)
• Requires “technology protection measures”– Applies to all Internet-connected computers– Libraries currently exempt
• Requires Internet Safety Policies – Need for public hearing– May be more than a student Acceptable Use Policy
• Applies only to Internet and Internal Connection discounts
E-Rate Central
Must Block or Filter Internet Access to Visual Depictions that are:
• Obscene• Child pornography
• Harmful to minors Key points: - Based on existing and precise legal definitions
- Only courts – not filter suppliers – can determine
• Otherwise deemed “inappropriate for minors” Key point: - As determined locally
E-Rate Central
N-CIPA Establishes Separate Policy Requirements for Minors re.
• Monitoring of online activity• E-mail• Chat rooms• Other electronic communications (e.g. IM)
• Hacking and other unlawful activities• Unauthorized disclosure of personal information
Key Point: Existing Acceptable Use Policy may not suffice
E-Rate Central
CIPA E-Rate Issues
• Timing:– First year (FY 2001): “Undertaking action”– Second year (FY 2002): Compliance
– Form 486 certification and timing is critical
• Special requirements for consortiums (Form 479s)
• FCC administration relies heavily on certification
• E-Rate Central’s CIPA primer and checklist– http://e-ratecentral.com/help/cipa_policy_primer.pdf– http://e-ratecentral.com/help/cipa_checklist.pdf
E-Rate Central
Critical Deadline Issues
Form 470 (Allowable Contract Date) 28 days after SLD posting
Form 471 Filing window closes 1/16/2003
PIA or invoice review inquiries 7 day response cycle
Tech plan and CIPA compliance Service start date (usually July 1)
Form 486 120 days after service start or FCDL (often October 28)
Service delivery June 30 or September 30 (unless extended)
Invoices (BEARs or SPIs) 120 days after last day of service or 486 notification (often October 28)
Appeals (SLD or FCC) 60 days after decision
E-Rate Central
Critical Deadline Issues, cont.
• Consequences of missed deadlines– Denial or loss of funding– Partial year funding
• Deadline extension requests– Service delivery (or FRN) extensions http://www.sl.universalservice.org/reference/ServiceDeliveryDeadlines.asp
– Invoice deadline extension requests http://www.sl.universalservice.org/reference/InvoicingDeadlines.asp
– PIA response exceptions
E-Rate Central
Program Compliance Issues
• Greater focus on “waste, fraud, and abuse”– PIA scrutiny, including Item 25 and selective reviews– Audits by SLD, FCC, and contractors– Vendor investigations by SLD, FCC, DOJ, etc.
• Consequences for applicants and vendors– Denied or reduced funding– Delayed funding decisions– Retroactive commitments (“COMAD”)
– Criminal indictments?
E-Rate Central
Suggested Recordkeeping
• Support of Form 471 calculations– Discount percentages– Requested dollar amounts
• Bid documents (including losing bids)
• Contracts
• Delivery, testing, and inventory documents
• Bills and proof of payment
E-Rate Central
Questionable Applicant/Vendor Practices
• Vendor involvement in the selection process– Vendor can not be the contact on the Form 470– FCC expects fair and open bidding process
• Applicants not paying non-discounted portion– Vendor cannot forgive or offset with “free” services– Vendor-arranged “grants” are suspect
• Non-competitive pricing or excessive services– Service cost must be primary factor in selection– Increasing requests for bid documentation
Primary Targets: Small 90% schools
E-Rate Central
• Numerous applicants cite the “XYZ Foundation” as the source of the funds for their share.
• Applicants have no contact information for the foundation.
• This foundation has made commitments only to applicants that have chosen this one service provider.
• All applicants are 90% Schools.
• Service provider leases applicants a server (by SP’s own admission worth $20,000) for $20,000 per year…
• Then charges $96,000 per year as maintenance on that server.
SLD’s Worst Case Scenario
E-Rate Central
SLD Online Database Resources
• Service Provider names, SPINs, and contacts
• Form 470s and Form 471s
• Funding status information
• FRN Extension Table
• New: Detailed FRN “Data Requests”– Funding– Form 486 filing– Authorized disbursements
E-Rate Central
Portal to the SLD Databases
• Service provider information
• Detailed FRN funding data
• Local, state, and national funding data
• Detailed Form 470 and Form 471 data
• Form 471 application status
• FRN extension status
E-Rate Central
Portal to the SLD Databases
• Service provider information
• Detailed FRN funding data
• Local, state, and national funding data
• Detailed Form 470 and Form 471 data
• Form 471 application status
• FRN extension status
E-Rate Central
Portal to the SLD Databases
• Service provider information
• Detailed FRN funding data
• Local, state, and national funding data
• Detailed Form 470 and Form 471 data
• Form 471 application status
• FRN extension status
E-Rate Central
Portal to the SLD Databases
• Service provider information
• Detailed FRN funding data
• Local, state, and national funding data
• Detailed Form 470 and Form 471 data
• Form 471 application status
• FRN extension status
E-Rate Central
Portal to the SLD Databases
• Service provider information
• Detailed FRN funding data
• Local, state, and national funding data
• Detailed Form 470 and Form 471 data
• Form 471 application status
• FRN extension status