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

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E-rate is not a short, easy processRead listserve messages Read form certificationsBe prepared for an auditStay organized! –

USE THE BOX or BINDER!

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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

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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

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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

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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

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QUESTIONS ABOUT APPLICANT OR

SERVICE ELIGIBILITY ISSUES?

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APPLICATION FLOWCHART

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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

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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

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TECHNOLOGY PLAN APPROVALS*

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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)

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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

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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

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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

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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

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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!

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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

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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

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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!

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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

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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!

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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

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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?