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E-RATE: POST FILING
What happens now that our applications have been filed?
Topics Covered Common E-Rate Terminology Post Filing Processes Funding Awards Receipt of Services Invoicing/Applying Funds Priority Two Project Considerations School Documentation Follow-up and Tracking of Funds 6th Report and Order Overview of Changes 2012/2013 Reminders Contact Information
COMMON E-RATE TERMINOLOGY
Common E-Rate Terminology
FCC: Federal Communications Commission USAC: Universal Service Administrative Company E-Rate: Education Rate Priority One: recurring telecommunication services Priority Two: internal connections Consultant: provides applicant with E-Rate consulting support Service Provider: provides applicant with services related to recurring
telecommunication services or internal connections RAL: Receipt Acknowledgement Letter PIA Review: Program Integrity Assurance; first level of application review BEN: Billed Entity Number; a unique number assigned to the applicant, like a
social security number PIN: a unique number assigned to an applicant’s authorized representative to
be used for filing and certifying forms online; it acts like a banking PIN
Common E-Rate Terminology Application #: a unique number assigned to a form 471 when entered in to the
online E-Rate system; each form 471 receives a unique number FRN: funding request number; a system generated number assigned to each
funding request on a form 471 FCDL: funding commitment decision letter; a letter that is generated by USAC to
communicate funding decision/s Appeal: a pre-defined process for appealing a funding decision Forms 470, 471, 472, 473, 474, 486, 500: will be defined in presentation SPIN: Service Provider Identification Number; a unique number assigned to
service providers CRN: Consultant Resource Number, a unique number assigned to an E-Rate
consultant SPI: Service Provider Invoicing; a discounted method to apply E-Rate funding BEAR: Billed Entity Application RE-imbursement; a method for receiving re-
imbursements of E-Rate funding
POST FILING PROCESSES
Post Filing Processes
RALs Application Review/PIA Other Reviews
RALs Applicants and service providers receive a Form 471 Receipt
Acknowledgment Letter (RAL) to confirm receipt of a timely-certified Services Ordered and Certification Form (Form 471).
Applicants should carefully review the RAL and must notify USAC of any data entry errors by the date specified in the letter.
If data entry or ministerial and clerical errors have occurred applicants may make allowable corrections to their Form 471 without submitting a new Form 471. The applicant must make the correction(s) to the RAL Allowable Correction Section and submit the correction(s) to USAC within 20 days of the letter date above the recipient's address in the RAL.
RAL corrections are included in the original scope of work, therefore IR will complete on behalf of the applicant
Application Review/PIA Each application is reviewed to ensure that Universal Service Fund support is
committed only for eligible products and services as well as eligible uses by eligible entities.
Review of All 471 ApplicationsUSAC reviews all Services Ordered and Certification Forms (Form 471) to verify the accuracy of discount percentages and ensure that support is committed only for eligible products and services. USAC is committed to issuing timely Funding Commitment Decision Letters but its ability to meet that goal depends on efficient processing of application reviews.
Applicants can help speed up application reviews by: Submitting a complete Form 471 including required certifications and Item 21
Attachments for each funding request Responding to requests for additional or clarifying information within 15 days Verifying that USAC has correct contact information Compliance Audits
PIA reviews are included in the original scope of work, therefore IR will complete on behalf of the applicant
Other Reviews
USAC may conduct other levels of review Select Review Procedural Audits Program Compliance Audits
These types of reviews are outside of the original scope of work. If IR’s support is desired, a new agreement will be needed. Please keep in mind that these reviews are time sensitive.
FUNDING AWARDS
Funding Commitment Decision Letters (FCDL)
Following application review, USAC issues one or more Funding Commitment Decision Letters (FCDLs) to both the applicant and the service provider(s)
Describes the services funded and not funded by FRN and other relevant information for reminders and deadlines
Funding Commitment Decision Letter (FCDL)
You may elect to begin receiving Priority One services or acquire Priority Two hardware/equipment prior to an FCDL, but you can only do so on July 1, 20XX or after
If you elect to begin before an FCDL award, you have to pay all costs in full and seek re-imbursement at a later time and upon receipt of an approved FCDL
IR will notify you directly and provide a copy of your official funding commitment decision letter once received. IR will also file any changes/appeals and begin the Receipt of Services process for your school.
CHANGES AND APPEALS
Changes/Appeals
Changes Reduction in award amount Service Substitution Change Service Provider Change SPIN Changes
Appeals Appeal a denial of funds
Changes
The Form 500 Application is the mechanism used for requesting modifications to submitted FRNs. Within this application you can submit reduction requests (there is no mechanism to request additional funding), change contract beginning and ending dates, and cancellation of an FRN (be sure….as there is no opportunity to change your mind afterwards).
It should be noted that it is the school’s responsibility to register reductions and cancellations of FRNs.
IR can file Changes for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.
Reduction / Cancellation of awards: Form 500
ChangesA Closer Look of What’s Involved: Form 500
Information Needed to Complete the Form:
FRN information…vendor, SPIN number, amount, etc..
Authoritative staff’s contact information
Changes
Make changes as you need them…do not put off for later as this typically leads to the form not being filed in time to be of use to the school
Make a copy of the completed form for your own records Mail at Post Office using the “Notification of Receipt” service.
Retain all such receipts as part of your documentation There is no “deadline” on when to file. This form is based on a
school’s need for modifying certain items within an FRN. Typically, submitted forms are addressed between 3-5 weeks.
Best Practices: Form 500
ChangesService Substitution is a change in the products and/or services specified in the Services Ordered and Certification Form, FCC Form 471.
Criteria to meet for service substitutions: The substituted services or products have the same functionality as
the services or products contained in the original proposal. The substitution does not violate any contract provisions or state or
local procurement laws. The substitution does not result in an increase in the percentage of
ineligible services or functions. The requested change is within the scope of the controlling FCC Form
470, including any Requests for Proposal, for the original service.
ChangesService Substitution process for initiating: Meet criteria for service substitutions Make application for substitutions USAC review of service substitutions Timeline for Requests / Corrections to Installed components Service Substitutions initiated by service providers due to discontinued
products
IR can file Service Subs for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.
ChangesSPIN Changes
Operational SPIN ChangesMay only be requested by the applicant. The SLD permits Operational SPIN changes when an applicant certifies that (1) the SPIN change is allowed under its state and local
procurement rules, (2) the SPIN change is allowable under the terms of any contract between the applicant and its original service provider, and (3) the applicant has notified its original service provider of its intent to change service providers.
Operational SPIN changes must be postmarked or received no earlier than the date of the Funding Commitment Decision Letter (FCDL) and no later than the last date to submit an invoice
ChangesSPIN Changes
Corrective SPIN changes
A request to change a SPIN that usually does not change the actual service provider. There are three categories of SPIN corrections that the SLD will consider upon written request:1. Data entry error2. The original service provider has, in part or whole, merged with, or been acquired by, another company3. Other instances when the service provider indicated on the Form 471 was changed, and the applicant did not initiate the change
Corrective SPIN changes must be postmarked or received no earlier than the date of your Receipt Acknowledgment Letter (RAL), unless you have been contacted by the SLD about this application, and no later than the last date to submit an invoice.
IR can file SPIN changes for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.
Changes
Online Instructions
Lets look at how to make CHANGES…
New Rules for SPIN Changes
Can no longer switch vendors because of lower price Must select vendor that received the next highest point value in
the original bid evaluation, assuming there was more than one bidder
If only one original bidder, an applicant may select a substitute service provider that satisfies its needs most effectively and efficiently
An applicant will not be required to initiate another competitive bidding process by submitting a new Form 470
Split FRNs when transitioning to new service is acceptable Can submit new 470 in mid-year if you want to switch for any
other reason or want to sign new multi-year contract
Appeals
An Appeal is a request to USAC to address any challenges and support in regards to a negative award finding or related to extension of time due to extenuating circumstances (i.e. hospitalization, death, etc..).
Appeals must be received or postmarked no later than 60 days after the date of USAC's decision letter. It should be noted an appeal process could take anywhere from several months to several years to come to a conclusion.
Appeals
Specific process for initiating an Appeal:
Compose a letter/narrative identifying the nature of the appeal request (on letterhead).
Utilize on-line request capability through SLD homepage under “submit a question”
Include any supporting documentation that justifies your request
If appropriate, IR can file Appeals related to the original scope of work at no additional cost.
RECEIPT OF SERVICES
Receipt of Services
Establishing Roles Begin Receipt of Services Getting Set up with Service Providers
Establishing Roles
Establish who at your school will be responsible for the following: Setting up service installs/start dates, project starts, signing service
provider related paperwork/work orders, etc.. Liaison to Intelagent Resources to provide relevant service related
materials, i.e. invoices
Intelagent Resources will handle the following on behalf of the applicant: Form 486 filing (Receipt of Services form) Setting up invoicing method with each Service Provider - SPI/BEAR Filing and monitoring of the BEAR re-imbursement process
Begin Receipt of ServicesRelevant Forms
Form 472 – Also known as the “BEARS” (Billed Entity Applicant Reimbursement ) Form is used to inform USAC of the school’s intent to submit an invoice for reimbursement of discounts.
Form 500 – Is used to request changes within filed FRNs (i.e.: contract dates, reductions in originally requested funds, cancellation of the entire FRN)
Form 486 – Informs USAC that services and/or equipment identified within a filed 471 has either been received or is process of being received and allows for the program to start receiving and process corresponding requests for funds.
Form 474 – Also known as “SPI”. The Form 474 informs USAC of the amount of the discounts provided to eligible schools and libraries and for which the service provider seeks universal service support.
Begin Receipt of Services
You may begin your service pre-funding, but you will have to pay the invoices in full until award, unless otherwise established with your service provider
Depending on when you are awarded, your discount options may change. For example the service provider may not allow credits/discounts after a certain timeframe and you will have to file BEAR re-imbursements
Important Reminder:
Getting Set-up with Service Providers
Service providers may have their own unique process for setting up a customer for E-Rate discounts, but discounts are only offered via credit (SPI) or re-imbursement (BEAR).
Service providers may contact you before or after an FCDL is issued to elect a invoicing method, please notify Intelagent Resources when contacted
INVOICING/APPLYING FUNDS
Funding Discount Options & Forms
If SPI method has been set up, your Service Provider will submit a Form 474 to USAC, as well as their annual service provider certification, Form 473
Your invoices should arrive with credits already applied to your totals. For example if you are funded at 80%, your invoice will show an 80% credit and you will be responsible for paying the remaining 20% which should be indicated on the statement
Service Provider Invoice (SPI): Form 474
Funding Discount Options & Forms
The Form 472 Application identifies to the SLD that the school has received services/equipment and is seeking to be reimbursed for the items which have already been paid in full
A separate Form 472 Application must be filed for each service provider
Intelagent Resources will file BEARs on a quarterly or annual basis for applicants on an as needed basis using the online BEAR system
Billed Entity Applicant Reimbursements (BEAR)
Funding Discount Options/Forms
Lets look at the online filing tool…
BEAR Invoice System Login
PRIORITY TWO PROJECT CONSIDERATIONS
Moving Forward
Your infrastructure implementation strategy is contingent on the following:
Pre funding commitment: July 1, 20XX or after without receipt of FCDL)
Post funding commitment: July 1, 20XX or after receipt of FCDL)
Moving Forward
Pre-funding commitment: Identify central point of contact for all E-Rate related business and
become familiar with E-Rate documentation especially the form 471 and Item 21 attachments
Identify any changes or substitutions with FRNs and file appropriate E-Rate paperwork
Collaboratively create a project plan, project schedule and communication strategy and share with all relevant parties
Sign any work/install orders, issue purchase orders, etc.. for July 1, 20XX or after
As services/hardware is received, capture all E-Rate related documentation and keep for records
Pay all invoices in full and file for BEARs after FCDL is issued
Moving Forward
Post funding commitment: Identify central point of contact for all E-Rate related business and
become familiar with E-Rate documentation especially the form 471 and Item 21 attachments
Identify any changes or substitutions with FRNs and file appropriate E-Rate paperwork
Collaboratively create a project plan, project schedule and communication strategy and share with all relevant parties
Sign any work/install orders, issue purchase orders, etc.. for July 1, 20XX or after. Be sure to inform the service provider to SPI invoicing so that your invoices come discounted
As services/hardware is received, capture all E-Rate related documentation and keep for records
SCHOOL DOCUMENTATION
School Documentation
Documentation Compliance Rules Application Documentation Post Application Documentation
Documentation Compliance Rules
Applicants and service providers must maintain program documentation for five years after services are received
All applicants and service providers are required to retain receipt and delivery records relating to the technology plans, pre-bidding, bidding, contracts, application process, invoices, provision of services, and other matters relating to the administration of the Universal Service Fund
Application Documentation
Myeratedocs: myeratedocs.com
Password and Login required Contains all application paperwork from bid docs, quotes,
bid/quote responses, Forms 470 & 471, Item 21 attachments, RALs, etc..
Contains some customer provided E-Rate materials like the online E-Rate survey data
Post Application Documentation
Purchase and Delivery of Services – Beneficiaries and service providers should retain all documents related to the purchase and delivery of E-rate eligible services and equipment. Beneficiaries must retain purchase requisitions, purchase orders, packing slips, delivery and installation records showing where equipment was delivered and installed or where services were provided. Service providers must retain all applicable documents listed above
Invoicing – Both service providers and beneficiaries must retain all invoices. Beneficiaries must retain records proving payment such as accounts payable records, service provider statement, beneficiary check, bank statement or ACH transaction record. Beneficiaries and service providers must also be able to show proof of service provider payment to the beneficiary of the GEAR
Contracts – Both beneficiaries and service providers must retain executed contracts, signed and dated by both parties. All amendments and addendums to the contracts must be retained, as well as other agreements relating to E-rate between the beneficiary and service provider, such as up-front payment arrangements
Contracts, Purchase Orders, Invoices, etc.:
FOLLOW-UP AND TRACKING
Follow-up and Tracking
You can use the Data Retrieval Tool on USAC’s site to access applications, funding commitments and funding disbursements
Access the tool here:Online Data Retrieval Tool
Or from the myeratedocs portal:www.myeratedocs.com
Important Reminders
If your school's Internet Safety Policy (or Acceptable Use Policy) doesn't contain at least this minimal language, you need to revise your policy before July 1, 2012:
"The school district will educate all students about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response.“
Internet Safety Education must specifically cover the following topics:•Cyber-bullying •Social Networking•Chatrooms
Important Reminders Technology Plans need to be certified by your state prior to accepting
any funds for that particular funding year
2013 Official Application filing window will most likely open in Dec. 2012 and close the first week of Feb. 2013
Income Data Collection Process: 2012/13 income levels have been released. Please use this link to access this data:http://www.fns.usda.gov/cnd/Governance/notices/iegs/IEGs.htm
Set your application strategy meeting/conference call with IR for July and August 2012. Proposals will be provided to schools by September 14, 2012 with expectation that contracts can be signed at October board meetings
Intelagent Resources Contact
Remy BibaudPhone: 412-231-1515 or 412-334-1888Email: [email protected]
Delana MurphyPhone: 412-231-1515 Email: [email protected]
