E-Rate for California Intermediate/Advanced Applicants

JACK O’CONNELLState Superintendent of Public Instruction

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E-Rate for CaliforniaE-Rate for CaliforniaIntermediate/Advanced

Applicants


E-Rate AcronymsE-Rate Acronyms

BEN – Billed Entity NumberCIPA – Children's Internet Protection ActFCDL – Funding Commitment Decision Letter FRN – Funding Request NumberSPIN – Service Provider Identification NumberSSD – Service Start DateRAL – Receipt Acknowledgement Letter (Form 471)RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch ProgramNIF – Non-Instructional FacilityPIA – Program Integrity AssuranceUSAC Link:

http://www.usac.org/sl/tools/reference-area.aspx

BEN – Billed Entity NumberCIPA – Children's Internet Protection ActFCDL – Funding Commitment Decision Letter FRN – Funding Request NumberSPIN – Service Provider Identification NumberSSD – Service Start DateRAL – Receipt Acknowledgement Letter (Form 471)RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch ProgramNIF – Non-Instructional FacilityPIA – Program Integrity AssuranceUSAC Link:


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E-Rate OrganizationE-Rate Organization

• Federal Communications Commission (FCC), an independent U.S. government agency, oversees the E-rate program

• Universal Service Administrative Company (USAC), a not-for-profit, administers the E-rate program along with three other programs

• Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-rate

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E-Rate RulesE-Rate Rules

•The FCC sets rules and policies through orders– Policies are defined in the text of orders

•USAC/SLD develops procedures for specific actions, such as how to process applications

– USAC submits its procedures to the FCC for approval each year

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E-Rate BudgetE-Rate Budget

•This cap will be adjusted for inflation starting in FY2010

•Once each year, FCC can roll over unused funds from previous funding years into the current funding year

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California Department of Education (CDE)California Department of Education (CDE)& State Library & State Library Do NotDo Not Administer Administer

the Federal E-Rate program.the Federal E-Rate program.CDE & State Library have no statutory authority to administer the federal E-Rate program

CDE & State Library only provide general information about the E-Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources

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E-Rate CycleE-Rate Cycle

• Funding Year is July 1 – June 30

• Funding commitments are made by funding year (services starting on or after July 1 and ending on or before the following June 30)

• The Window

– Form 471 application window –Opens mid to late fall and closes February

– This year Funding Cycle July 1, 2011 to June 30, 2012 (AKA Funding Year 14 or FY 2011)

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E-Rate Timeline: July 1st – June 30thE-Rate Timeline: July 1st – June 30th

*These dates are estimates. In order to derive the Form 470 deadline, applicants must count backwards from the Form 471 deadline.**FCC announces Form 471 filing deadlines each Fall.


6th Report and OrderOverview


• Dark Fiber now eligible from any provider

• Makes permanent after hours, onsite community use

• Indexes funding cap to inflation

• Pilot program for schools providing wireless offsite access

• Technology Plans only for P2

• More on competitive bidding, including gifts

• Changes to ESL – “Unbundled warranties” ineligible

• Disposal of Equipment and SPIN changes

What’s Included?Overview


• Lease of fiber, lit or dark, is eligible in Telecom or Internet Access from any provider (dark fiber must be lit immediately)

• Providers can be telcos; state, regional or research and educations networks; or private networks

* See Eligible Services discussion for further details.

Dark Fiber

Access to Broadband


• After school hours, schools may open their facilities to the general public to use E-rate supported services

• Schools decide whether or not to provide such access• Service must primarily be for educational purposes• Schools cannot purchase additional services to support

community use• Community use is limited to non-operating hours and

only on campus• Schools may not charge for use of services or facilities

purchased through E-rate though they may charge a fee to offset ineligible costs (e.g. security, additional electricity, etc.)

Community Use of Schools’ E-rated Services

Improving Broadband Access


• Funding has been capped at $2.25B since 1999

• Cap will not decrease in event of deflation

• FCC will announce the increase annually

• For FY 2010, inflation is deemed 0.9%

• New cap for FY 2010: $2,272,500,000

• This increase is in addition to any rollover funds

Indexing the Funding Cap to Inflation



• Pilot allows $10M in FY 2011 to support innovative and interactive off-premise wireless device connectivity for schools and libraries.

• FCC will use the pilot to gather more information about issues affecting such use which can later be used for permanent rules.

• FCC expects data reporting by those selected

• Strong preference given to those already implementing such programs

E-rate Deployed Ubiquitously (EDU) 2011 Pilot Program



• New requirements apply for FY 2011 and beyond• No longer required for:

– Priority One (Telecom and Internet Access)• Still required for:

– Priority Two services (internal connections and Basic Maintenance of Internal Connections)

• There may be other reasons to continue to have a current technology plan

*See Tech Plans slides later in presentation for more details on subject.

Technology Plans

Streamlining & Simplifying

JACK O’CONNELLState Superintendent of Public Instruction • Disposal or resale is permitted no sooner than five

years after installation date• Applicants may receive payment or other

consideration in return for disposal• Applicants are not required to use equipment for

five years, nor are they required to dispose of equipment after five years.

• No notification to USAC is needed, but update your asset registers

• This does not change the requirement to report transfers of equipment made less than three years from purchase

Disposal of Equipment



• Form 470– All must continue to use the Form 470

process– New, streamlined Form 470 will be

available for use for FY 2011• New form is approved by OMB and

awaiting online implementation• Applicants that file Forms 470 prior to

effective date do not need to refile• Applicants that file Form 470 after the

effective date MUST use the new form

Competitive Bidding Process



• New Order codifies* that competitive bidding process must be fair and open. – All potential bidders must have access

to the same information and must be treated in the same manner throughout the procurement process

– Additions or modifications to the Form 470/RFP must be made available at the same time and in a uniform manner to all potential bidders

*Codification makes this a rule, subject to violation, as opposed to merely a guideline

Fair and Open Competitive Bidding Rule



• Rule violations include (but are not limited to):– Applicant has relationship with the service

provider that unfairly influences the outcome of the competition or provides them with “inside” information

– Someone other than the applicant (or their representative) prepares, signs and submits the Form 470

– Service provider is listed as the contact on the Form 470 and the provider is allowed to bid




• Codification of the Gifts Rules

– Receipt of gifts by applicants from service providers and potential service providers is a competitive bidding violation.

– Exceptions mirror Federal Government regulations

• Modest refreshments not offered as part of a meal (e.g. coffee and donuts at a meeting) are OK

• Items with little or no intrinsic value such as certificates and plaques are OK



JACK O’CONNELLState Superintendent of Public Instruction • Gifts

– Exceptions:• Items worth $20 or less (meals, pencils,

pens, hats, t-shirts etc) as long as those items do not exceed $50 per year per employee from any one source (service provider) are OK.

• This means all gifts from all employees, officers, representatives, agents, independent contractors, or directors of the service provider (including manufacturers).




• Gifts– Gift prohibitions are always applicable, not

just during the competitive bidding process– Prohibition includes soliciting and receiving

any gift or other thing of value from a service provider participating in or seeking to participate in the E-rate program.

– Service providers may not offer or provide any gifts to applicant personnel involved in E-rate



JACK O’CONNELLState Superintendent of Public Instruction • Gifts

– Gift rules are not intended to discourage companies from making charitable contributions to schools, as long as those contributions are NOT directly or indirectly related to an E-rate related procurement.

*Effective…NOW




• Pre-commitment SPIN changes– Corrective SPIN changes only (i.e.. data

entry errors)• Post-commitment SPIN changes

– Operational SPIN changes• Must have legitimate reason to change,

such as Breach of Contract or provider unable to perform

and• Must select provider with next highest point

value in evaluation

SPIN Changes



E-Rate Technology E-Rate Technology PlanningPlanning


Recent Changes to E-rate Recent Changes to E-rate Technology Plan RequirementsTechnology Plan Requirements

• Beginning in FY2011, Tech plans are required for Priority 2 services ONLY (internal connections and basic maintenance of internal connections)

• The budget requirement for the Tech plans has been eliminated


Technology Plan OverviewTechnology Plan Overview1. FFC rules require an “approved” technology plan when receiving E-rate discounts for priority

2 services (internal connections: switches, routers, cabling and basic maintenance)

2. Find your public charter, district or COE Tech Plan status at: http://www.cde.ca.gov/ls/et/rs/techplan.asp

3. *Decision: Decide which tech plan to use: A) E-rate only, B) EETT technology plan (best practice approach because it also qualifies applicant for K12 Microsoft voucher funding) Note: Libraries leverage your master plan in developing your technology plan.

4. Tech Plan must be “written” prior to posting Form 470 for priority 2 services.

5. DOCUMENT the existence of this “Written Plan” – i.e., Letter/E-mail from Cabinet, screen print of file name and date, and physical copy of plan.

6. Must cover all 12 months of the funding year (July 1 – June 30).

7. E-rate only plans should not cover more than 3 years; EETT tech plans that meet E-rate requirements can cover 5 years with progress review during 3rd year.

8. Tech plans must include any priority 2 services for which E-rate discounts are sought.

9 Must be approved by a “Certified Technology Plan Approver” See the Technology Plan approver locator tool on the USAC website: http://www.sl.universalservice.org/reference/tech/default.asp

10. Use the technology plan builder and the expertise of your CTAP regional assistance: http://myctap.org/index.php/techplan/tpb

http://www.cde.ca.gov/ls/et/rs/techplan.asp

http://www.sl.universalservice.org/reference/tech/default.asp

http://myctap.org/index.php/techplan/tpb


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44 Required Elements of a Required Elements of a Technology Plan Used for Technology Plan Used for

E-rateE-rate1. Clear statement of goals and realistic strategy for using

telecommunications and information technology to improve education or library services.

2. Professional Development strategy to ensure staff understands how to use technologies to improve education or library services

3. Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services

4. Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise.

The “Two Tech Plans”The “Two Tech Plans”E-Rate Only Plan:

1. Goals2. Professional

Development3. Needs Assessment4. Evaluation Process

• Tech Plan Helpwww.usac.org/sl/applicants/step02/

Enhancing Education Through Technology (EETT):

• Executive Summary/Introduction

• Stakeholders• Curriculum • Professional Development • Infrastructure• Adult literacy • Research • Funding and Budget• Monitoring and Evaluation www.cde.ca.gov/ls/et/rs/techplan.asp


CTAP Tech Plan Builder ToolCTAP Tech Plan Builder Tool


EETT Tech Plan Cycle EETT Tech Plan Cycle Dates:Dates:

• The final dates to submit your EETT Tech Plan for approval are:

1. Cycle A: September 17, 2010

2. Cycle B: November 19, 2010

3. Cycle C: March 11, 2011


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Under what circumstances do you revise or amend tech plan?

• Tech plans should be reviewed every year for relevancy as technology and situations change (before filing form 470)

• EETT tech plans (5 yr. life) used for E-rate require a “progress review” at year three (must document this)

• If annual review finds major changes: major budget cutbacks (close schools); adding a new technology program (distance learning); or add new technology (internet service) – should revise entire plan

• Major or significant changes require a new tech plan and approval to incorporate these significant changes

• Bottom line – the tech plan should support E-rate services requested on form 470 and contracted for on form 471

• Minor changes add addendum to the tech plan file (does not require re-approval) – E.G Changing of hardware standards, etc.


Technology Plan Technology Plan “Gotchas”“Gotchas”

• Service Providers may not act as technology plan approvers, write/create, or assist in the tech plan in any capacity

• Education Service Agencies (ESA’s) or County Offices (COEs) that act as service providers and applicants – must build appropriate “firewalls” between roles, see USAC guidance: http://www.usac.org/sl/applicants/step01/esa-guidelines/

• Same staff should not work in both roles • Provide functional/organizational separation

within organization


Technology Plan “Must Technology Plan “Must Do” Reminders:Do” Reminders:

1. Must be “Written” prior to posting Form 470 for priority 2 services:– It must be documented that it is written before the posting of the form 470!

(Applicant must document the existence of this plan, i.e., e-mail with plan attached, memo from cabinet level about the plan being written, including the date. “DATE STAMP,” submit EETT tech plans during cycle A [final date November 19, 2010])

2. Must include a sufficient level of detail and cover all priority 2 services for which E-Rate discounts are being sought on the Form 470(s) and subsequent Form 471(s).

3. Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier for priority 2 services

4. E-rate only plans must be approved by a “USAC Certified Technology Plan Approver” see USAC link: http://www.usac.org/sl/tools/reference/tech/default.asp

5. Combination E-rate/EETT Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

6. Must include all four required elements regardless of the type of plan being used (E-rate only or EETT)


Technology Plan HelpTechnology Plan Help• E-rate Plans: John Vardanega, [email protected],

916-323-2241

• EETT Plans: Doris Stephen, [email protected]

• CTAP:http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

• CTAP Tech Plan Builder: http://myctap.org/index.php/techplan/tpb

• Libraries: Rushton Brandis, [email protected] , 916-653-5471


Eligible Services

Overview


• Support for telecom services

• Examples:

– Local and Long Distance service

– Cellular Service• Text messaging

– Ethernet

Priority One – Telecommunications Services

Overview


• Other examples of eligible telecom services– T-1, T-3– DSL– PRI – Satellite service– Interconnected Voice over Internet Protocol (VoIP)– Taxes and fees– Installation and configuration


Overview


• Some examples of services NOT eligible:

– Broadcast “Blast” messaging

– Monitoring services for 911, E911 or alarm telephone lines

– Services to ineligible locations

– End-user devices


Overview


• Telecommunications Services and Telecommunications are now two categories on the Eligible Services List (ESL)

1. Telecommunications Services can only be provided by an eligible telecommunications carrier a. On Form 470/471 as Telecommunications

Services

2. Telecommunications {only} can be provided by non-telecommunications carriers via fiber in whole or in parta. On Form 470/471 as Telecom or Internet

Access

Priority One - TelecommunicationsOverview


• Support for Internet Access includes the Internet Service Provider (ISP) fees and the conduit to the Internet

• Examples also include:

– E-mail Service

– Wireless Internet Access

– Web Hosting

– VoIP

Priority One – Internet Access

Overview

JACK O’CONNELLState Superintendent of Public Instruction • Some examples of services NOT eligible:

– Costs for Internet Content• Subscription services such as monthly

charges for on-line magazine subscriptions

– Internet2 membership dues

– Web site creation fees

– Software, services, or systems used to create or edit Internet content

Priority One – Internet Access

Overview


• Support for equipment and cabling on-site that transport information to classrooms or public rooms of a library

• Does NOT include end-user components such as computers

• Subject to the Two-in-Five Rule

– Entities can only receive funding every two out of five years

Priority Two – Internal Connections

Overview


Priority Two -Internal Connections

Overview


Priority Two -Internal Connections

Overview


• Support for basic maintenance of eligible internal connections

• Examples:

– Repair and upkeep of eligible hardware

– Wire and cable maintenance

– Basic technical support

– Configuration changes

Priority Two – Basic Maintenance of Internal Connections

Overview


• Agreements or contracts must state the eligible components covered, make, model and location

• Service must be delivered within the July 1st to June 30th timeframe

• Two-in-Five Rule does not apply to BMIC

Priority Two – Basic Maintenance of Internal Connections

Overview


Eligible Services

What’s New


• Leased Dark Fiber included as Telecommunications on the FY2011 Eligible Services List

• Support for the lease of fiber, whether lit or dark, as a priority one service, from any entity

• On the FCC Form 471, applicants should select the Telecom box if the leased fiber is provided by a telecom carrier

• In all other cases, the applicant should select the Internet Access box

Leased Dark Fiber for FY 2011

What’s New


• Dark fiber must be lit immediately • Does NOT allow for unneeded capacity or

warehouse dark fiber for future use• Maintenance costs of dark fiber and

installation costs to hook up the dark fiber are eligible– This includes charges for installation within

the property line• The purchase or lease of modulating

electronics in Priority One is NOT eligible


What’s New


• Special Construction charges to build out connections from applicants’ facilities to an off-premise fiber network are NOT eligible

• Some examples of ineligible special construction charges include:

– Design and engineering costs

– Project management costs

– Digging trenches

– Laying fiber


What’s New


Eligible ServicesServices Updates


• Web hosting change:

– Blogging and discussion boards are now eligible

• Status quo:

– Remains eligible for discount as Internet access

– Web features including content created by third party vendors, databases for grades, student attendance files, or other reports are NOT eligible

– These ineligible web features must be cost allocated

Web Hosting

Services Updates


• Wireless IA Applications update:– Wireless service dedicated to an ineligible

service or group of services will be deemed entirely ineligible

• For example, cellular service for the GPS tracking for a bus is entirely ineligible

– Bundled services will require cost allocation• For example, a voice plan for the bus driver

and a data plan for GPS tracking must be cost allocated to remove the data plan

• USAC will conduct outreach to applicants if no reasonable cost allocations were provided

Wireless Internet Access Applications

Services Updates


• Separately priced firewalls in Priority One are not eligible– Bundled firewalls included with Internet

access service is eligible– Firewalls are eligible as Internal Connections

• Intrusion Detection/Intrusion Prevention Devices are not eligible

• Anti-Spam and Anti-Virus Software are not eligible

• On-line backup solutions are not eligible• Scheduling services are not eligible

Other Ineligibles

Services Updates


• Unbundled warranties are NOT eligible

• Unbundled warranties allow for broken equipment to be fixed or if it is beyond repair, replaced

• Unbundled warranties are considered a type of retainer and not as an actual maintenance service

• This does not apply to a manufacturer’s warranty of no more than three years that is included in the price of the equipment OR

• If the retainer is tied to actual service performed

Basic Maintenance of Internal Connections Clarifications

Services Updates


• Applicants may make estimates based on:

– Hours per year of maintenance

– History of needed repairs and upkeep

– Current life of eligible internal connections

• Basic maintenance will be paid on the actual work performed and hours used only

Basic Maintenance of Internal Connections

Services Updates


Questions?Questions?


E-Rate ProgramRevised FCC Forms 470 and 471


• Current FY2011 Form 470 became available July 1, 2010– Applicants can file a Form 470 now and cite it on

an FY2011 Form 471• FY2011 Form 471 window target opening mid-

December with the revised Form 471 (current version can no longer be used)

• When the revised version of Form 470 becomes available, applicants can file a Form 470 using the revised version and cite it on an FY2011 Form 471

• Form 471 window target closing end of February

Target timeline for FY2011 FCC Form 471 filing window

Target Window Timeline

JACK O’CONNELLState Superintendent of Public Instruction • You are STRONGLY encouraged to:

– File AND certify (online or on paper) the current Form 470 before the revised Form 470 becomes available

OR

– File AND certify (online or on paper) the revised Form 470 after it becomes available

“Current” and “revised” FY2011 Form 470

Filing a Form 470


• If you file the current Form 470 online, you must certify it online or on paper before the revised Form 470 is posted

– Client Service Bureau (CSB) will ask you for corrections if your certification does not match your online filing (i.e., if you don’t print your certification using Certify Complete)

• If you file the current Form 470 on paper, you must postmark it before the revised Form 470 goes live on the USAC website

– Otherwise, CSB will preserve your postmark date but you will be required to re-submit on the revised Form 470

“Current” and “revised” FY2011 Form 470

Filing a Form 470


Changes Common to Both Forms

Revised FCC Forms 470 and 471


• Individual school• School district• Library• Consortium• Statewide application for (two-letter state

code) _____– All public schools in state– All non-public schools in state– All libraries in state

Eligible Entities/Type of Application (Additions in red)



– Public

– Private

– Charter

– Tribal

– Head Start

– State Agency

• You must check at least one option

• You may check multiple options

Recipient(s) of Services (check all that apply)



• Applicant will now identify a consultant that is assisting the applicant with the application process

• Client Service Bureau can quickly assign a consultant registration number (CRN)– Each consulting firm has a CRN– If the firm has multiple employees, the

individual employee who assisted with the form is also identified

– In the last block, a checkbox has been added to indicate if the consultant is also the authorized person

Consultant Information



• Consultant Registration Number

• Name (of consulting firm or sole proprietor)

• Name of employee

• Street address/City/State/Zip

• Telephone number with extension

• Fax number

• Email address

Consultant Information Fields



• I certify that, if required by Commission rules, all of the individual schools and libraries receiving services under this form are covered by technology plans that do or will cover all 12 months of the funding year, and that have been or will be approved by a state or other authorized body, or an SLD-certified technology plan approver, prior to the commencement of service OR

• I certify that no technology plan is required by Commission rules.

Technology plan certification



• I certify that the services the applicant purchases at discounts provided by 47 U.S.C. § 254 will be used primarily for educational purposes and will not be sold, resold, or transferred in consideration for money or any other thing of value, except as permitted by the Commission’s rules at 47 C.F.R. §§ 54.500, 54.513.

Educational purposes certification



• All email addresses featured on these forms must now be entered twice

– Both e-mail address entries will be compared

– If they don’t match, both fields will be cleared and the applicant must try again

– This process helps to guarantee the accuracy of this important information

Email addresses



Revised FCC Forms 470 and 471

Form 470


• Block 1: Applicant Address and Information– Eligible entities that will receive services /

Recipient(s) of services added– Consultant information added

• Block 2: Summary Description of Needs or Services– Tariffed/month-to-month, contracted services

(multi-year, voluntary extensions), contracts signed before July 19, 1997 deleted

– SPI/BEAR/no preference checkboxes deleted

Changes to Form 470

Form 470 - Overview


• Block 3: Technology Resources deleted

– Basic telephone service deleted

– Necessary resources deleted

• Block 4: Recipients of Service

– Statewide recipients of services moved to Block 1

– Telephone numbers and prefixes for multiple eligible entities deleted

– Ineligible participating entities deleted

Changes to Form 470

Form 470 - Overview


• Block 5: Certifications and Signature

– Some certification language changed

– Consultant as authorized person checkbox added (slide 17)

Changes to Form 470 (continued)

Form 470 - Overview


T/MTM or contract information (Current Items 7a – 7c)

Form 470 – Deleted Fields


SPI/BEAR/No preference (Current Items 8b, 9b, 10b, and 11b)



Basic Telephone Service (Current Item 14)



Necessary Resources (Current Items 15a-15f)



Phone numbers and prefixes

(Current Item 16c)



Ineligible participating entities

(Current Item 18)



• Item 17 – Technology plan certification (slide 19)

• Items 18 and 19 – Current Item 21 has been split into two separate certifications– The text contained in the two certifications remains

the same as on the original combined certification

• Item 20 – Educational purposes certification (slide 20)

• Item 21 – The following sentence has been added:– I certify that I have considered what financial

resources should be available to cover these costs.

Block 4 - Changes to certification pages

Form 470 – Certifications


• Item 22 – I certify that I am authorized to procure eligible services for the eligible entity(ies)…

Signature page

• Item 27b – Checkbox for consultant as authorized person (slide 17)

Block 4 - Changes to certification pages



Revised Forms 470 and 471Form 471


• Block 1: Billed Entity Address and Information– FCC Registration Number added– Type of application and Recipient(s) of

services added (slides 15 and 16) – Consultant information added (slides 17 and

18)

• Block 2: Impact of Services Ordered– Collection of broadband services data added

• Block 3: [reserved]

Changes to Form 471

Form 471 - Overview


• Block 4: Discount Calculation Worksheet

– Libraries must now provide urban/rural and student count information on the worksheet

– Certain entity-level data added or requested in a different format

• Block 6: Certifications and Signature

– Some certification language changed

– Consultant as authorized person checkbox added (slide 17)

Changes to Form 471 (continued)

Form 471 - Overview


• Block 1: Billed Entity Address and Identifications– Item 3b – FCC Registration Number (FCC RN)

added• Persons and entities doing business with the FCC

must obtain an FCC RN and supply it when doing business with the FCC (Form 471 Block 1 entities only)

• If you do not already have an FCC RN, you can visit https://fjallfoss.fcc.gov/coresWeb/publicHome.do

– Items 5a and 5b – Type of application/Recipient(s) of service added

– Item 6g – Consultant information added

Changes to Form 471Form 471


• Block 2: Impact of Services Ordered

– BEFORE ORDER column removed

• “AFTER ORDER” columns to complete:

– Individual schools and school districts complete the “Schools” column

– Libraries and library consortia complete the “Libraries” column

– Consortia complete one or both as appropriate depending on the consortium members

Changes to Form 471

Form 471

JACK O’CONNELLState Superintendent of Public Instruction • Number of students (schools) or patrons

(libraries)• Number of (class)rooms with telephone service• Number of drops (direct Internet connections)• Number of (class)rooms with Internet access• Number of computers or other devices with

Internet access• Number of dial-up (<56K) Internet connections• Direct broadband services (next slide)

Block 2: Impact of Services Ordered – Items 7a through 7g

Form 471


• Direct broadband services: Number of buildings served at the following speeds:

__ < 200 kbps __ 10 – 25 mbps

__ 200 kbps – 1.5 mbps __ 25 – 50 mbps

__ 1.5 – 3 mbps __ 50 – 10 mbps

__ 3 – 10 mbps __ > 100 mbps

Block 2: Impact of Services Ordered – Item 7g

Form 471


• Basic structure of worksheet remains the same

• Schools and libraries must provide urban/rural status, student counts, and certain specific information– Total number of students – Number of students eligible for National School

Lunch Program (NSLP)– New construction– Administrative entity or non-instructional facility

(NIF)– Alternative discount mechanism

Block 4: Discount Calculation Worksheet

Form 471


• Schools must also include the following information if applicable (more than one may apply):

– Pre-kindergarten

– Head Start

– Adult Education

– Juvenile Justice

– Educational Service Agency (ESA)

– Dormitory

Block 4: Discount Calculation Worksheet (continued)

Form 471


• School districts and library systems must create one worksheet listing all eligible entities in order to calculate the shared discount for the district or system– This allows USAC to verify the calculation for

• New school or library construction when the student population is not known

• Eligible discount for non-instructional facilities (NIFs) such as administration buildings

– This worksheet will not affect Two-in-Five status unless it is cited in Item 22 of a funding request

Block 4: Discount Calculation Worksheet (continued)

Form 471


No changes

Block 5: Discount Funding Request(s)

Form 471


• Item 26 – Technology plan certification

• Item 27 – I certify that (if applicable) I posted my Form 470 and (if applicable) made any related RFP available for at least 28 days…

• Item 29 – Educational purposes certification

Signature page

• Checkbox for consultant as authorized person

Block 6: Certifications and Signature



Questions?

Revised Forms 470 and 471

JACK O’CONNELLState Superintendent of Public Instruction Form 486Form 486

Receipt of Services Receipt of Services ConfirmationConfirmation


Form 486 ReviewForm 486 Review

• Notifies USAC that services started or are scheduled to start and invoices can be paid

• Applicant makes additional program certifications

• Filed AFTER receipt of FCDL–Form 486 must be filed online or

postmarked, no later than• 120 days after Service Start Date

OR• 120 days after FCDL date

– Whichever is later


Late 486….potential consequencesLate 486….potential consequencesExample what happens if Form 486 is

submitted “late”:• 2009/2010 (Yr 12) FCDL for $100,000 dated

February 1, 2010 received• Services began on July 1, 2009• 120th day after FCDL = May 31• Form 486 submitted & certified on June 2• “New Service Start Date” is now Feb 2• Therefore, District loses opportunity to

receive E-rate discounts for costs incurred between 7/1/09 – 2/2/10; approximately $58K in costs that District cannot recover.


Form 486 RemindersForm 486 Reminders

• DO include all applicable Funding Request Numbers (FRNs).

• DO verify FRNs and SPINs against Form 471 and FCDL.

• DO understand early filing rules if filing BEFORE July 1.

• DO review Form 486 Notification Letter to verify all FRNs were included.

• DON’T ignore Form 486 Reminder Letter.• DO maintain open communication with your service

provider regarding non-recurring services. SP cannot invoice USAC until Form 486 is filed.

• DON’T wait until last minute. • DO file within 120 days of service start date (July 1

for recurring services) or FCDL date, WHICHEVER IS LATER.


Invoicing Invoicing “Getting the Money”“Getting the Money”


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Once you have submitted your Form Once you have submitted your Form 486, then what?486, then what?

• Applicants receive E-rate reimbursements from Service Providers (SP)

o One of two ways:

Form 472 (BEAR): Applicant pays entire bill up-front & in full and gets reimbursed

OR

Form 474 (SPI): SP applies discounts to applicant’s bills


Receipt of FundsReceipt of Funds• BEAR process:

1. Applicant pays entire SP bill up-front2. Applicant submits BEAR to SP & then to

USAC for reimbursement3. BEAR Notification is sent from SLD to

both Applicant and Service Provider– Check sent by USAC to Service Provider– From the date SP receives funds from USAC,

SP has 20 days to reimburse Applicant

*BEAR can be done online

Notes Regarding CTF discounts: Only use BEAR for services you are NOT requesting CTF

discounts for. Only telecommunications services & some Internet

services are eligible for CTF discounts. Usage & installation costs are not eligible for CTF

discounts


Receipt of Funds, contReceipt of Funds, cont• SPI Process

– Allows SP to apply discounts to applicant’s bills • AFTER funding commitment has been issued • AFTER SP’s forms have been submitted• SP then submits reimbursement request to USAC

– Allows applicant to eventually pay only their non-discounted portion

Notes:• Telecommunications Services & Internet Access

eligible for CTF Discounts must use SPI process• Work with your Accounts Payable resource(s)• Get familiar with your bills; • If applicable & available:

Request consolidated billing from SPs; receiving individual bills makes it very challenging to verify discounts, identify eligible costs, etc.

Request online access to your invoices


Service Provider SPI processService Provider SPI processEvery service provider has their own process and

suggested/required deadline:• Each SP (each SPIN) sends GRID, Data Gathering

Form, etc., paperwork to applicants via email• Applicants complete paperwork to match FRNs to bill

telephone #s, circuit IDs, etc. & identify new services (ckts, lines, etc.) to be installed

• Complete SP’s data gathering documentation & send back to SP as soon as possible.

• E-rate is self-certifying program; you will have to certify SP documentation is correct, eligible, etc.

• Once SP reviews what you submit, applicants will generally begin realizing discounts 2-3 bill cycles.

• Discounts typically show up April-July bills before funding year ends.

• Review your bills to ensure discounts received & accounted for.

• The sooner you fill out SP’s data gathering documentation & certify information is correct, the sooner applicant will realize E-rate discount credits.


SPI Timeline ExampleSPI Timeline ExampleEvery service provider has their own process and

suggested/required deadline:• FCDL received July 15• Applicant’s Bill Round = 1st of every month• Applicant receives SP’s paperwork to complete on

August 1.• Applicant returns SP’s paperwork on September 1.• Errors in applicant’s SP’s paperwork; SP contacts

applicant & identifies corrections to be made to SP’s paperwork

• Applicant returns SP’s paperwork on November 1.• SP submits paperwork to IT for processing for

discounts on November 25, too late for bill round deadline of the 20th of every month

• Discounts are processed by IT on Dec 20 submission.

• Discounts begin showing on Feb 1, 2009 bill.


What to do if you have not What to do if you have not received expected discounts received expected discounts

Every service provider has their own process. General Roadmap:

• Contact the E-rate Center for the respective SPIN.

• Speak to the representative• If representative cannot assist, ask to speak to a

supervisor• If the representative & the supervisor cannot

assist, contact your SP assigned account representative

• If all else fails, contact the SP E-rate specialist assigned to that territory for assistance on who to go to.


INVOICE RECONCILIATIONINVOICE RECONCILIATION


Invoice Reconciliation

• Expectation of USAC that applicants are verifying that they are receiving the correct discounts

• Will be asked to provide this during an audit

• Application of Discounts frequently overlaps funding years

• Work with service provider representatives in verifying discounts received

• Ask for reports and compare to your invoices


Invoice ReconciliationTracking Eligible Charges and

Payments

• Tally costs by Billed Telephone Number (BTN) by month for both E-Rate eligible and ineligible costs

• Understand how CTF discounts are applied to invoices by carrier– E-Rate is applied to eligible costs prior to the

application of the CTF discount

• Track payments made of applicant share of costs

• Calculate the estimated E-rate amount for the year and compare to disbursements on DRT and Quarterly Disbursement Reports




Sample Reconciliation

• You have been funded for:– FRN 1111xx, Telecommunications Services for

Service Provider ABC Telecom for a maximum of $32,500.

– FRN 1112xx, Internet Access for Service Provider 123Internet for a maximum of $10,345.

– FRN 1113xx, Telecommunications Services for Service Provider Z Long Distance for a maximum of $567.

– Discount level is 90%


Sample reconciliation

Acct # Invoice Date Total ChargesLong Distance

FRN 113xxInternet Access

FRN 112xx IneligibleTotal Eligible for FRN 111xx

(530) 555-5555 521 9 7/28/2009 129.22 6.42 35.00 19.50 68.30

(530) 555-5555 521 9 8/28/2009 129.06 6.42 35.00 19.50 68.14

(530) 555-5555 521 9 9/28/2009 133.91 6.17 35.00 19.50 73.24

(530) 555-5555 521 9 10/28/2009 141.26 13.12 35.00 19.50 73.64

(530) 555-5555 521 9 11/28/2009 129.58 7.00 35.00 19.50 68.08

(530) 555-5555 521 9 12/28/2009 136.80 14.11 35.00 19.50 68.19

(530) 555-5555 521 9 1/28/2010 129.24 6.25 35.00 19.50 68.49

(530) 555-5555 521 9 2/28/2010 129.03 6.22 35.00 19.50 68.31

(530) 555-5555 521 9 3/28/2010 129.78 6.97 35.00 19.50 68.31

(530) 555-5555 521 9 4/28/2010 183.08 6.27 35.00 69.49 72.32

(530) 555-5555 521 9 5/28/2010 145.59 18.45 35.00 20.00 72.14

(530) 555-5555 521 9 6/28/2010 180.04 6.63 35.00 69.99 68.42

(530) 555-5555 521 9 SUMMARY 1696.59 104.03 420.00 334.98 837.58

Invoice from ABC Telecom

Multiple service providers can be included on one invoice.•Break these out so that you invoice the correct $$ to the correct service provider.


Invoice ReconciliationChallenges

• Receipt of Discounts overlaps funding years

• Discounts received many months and sometimes years after FCDL

• Disputed charges and late payments may affect the application of discounts

• CTF adjustments


If you missed the deadline?If you missed the deadline?

Invoice Deadline Extension request

• Must be submitted to USAC.• There is no official “form”, but there is a format &

criteria for the request(s)• Typically the request is submitted by applicant to

USAC. • Format for request @

http://www.universalservice.org/sl/applicants/step11/invoice-deadlines-extension-requests.aspx

Notes: →You may have to do FRN split(s), SPIN change(s), or

both, to realize E-rate discounts for eligible services. → If you do request FRN split, you must issue Form 486

for new FRN(s).


Invoicing Best PracticesInvoicing Best Practices

• DO submit Form 486 in a timely manner. • DO ensure all SP forms are completed and returned to

SP quickly to realize E-rate discounts sooner. • DO verify discounts posted on your invoices.• DO submit BEAR form in ADVANCE of Invoice

Deadline.• DO document your BEAR form calculations and retain

for audit purposes.• DO file Invoice Deadline Extension Request if your

FRN does not show any or incomplete disbursement of funding by Invoice Deadline.

• DO work with your Accounts Payable• DON’T assume posted E-rate discounts are correct.• DON’T include ineligible costs in your BEAR form

amount.


Invoicing Reminders

• NOTES:→Invoicing cannot occur until Form

486 is filed and certified.→Discounts cannot be realized until

SP forms are completed & certified.


Childrens Internet Childrens Internet Protection Act (CIPA) Protection Act (CIPA)

Protecting Children in the Protecting Children in the

2121stst Century Act Century Act


CIPACIPA ComplianceCompliance• Public Notice & Public Hearing• Technology Protection Measure (Filter)• Internet Safety Policy (required elements)

– Access by minors to inappropriate matter on the Internet – Safety & security of minors when using electronic mail, chat

rooms, and other forms of direct electronic communications – Unauthorized access including "hacking“ & other unlawful

activities by minors online – Unauthorized disclosure, use, & dissemination of personal

information regarding minors – Measures designed to restrict minors' access to materials

harmful to minors

• CIPA affects every funding year from FY2001 going forward, so you must maintain proof of CIPA compliance on an ongoing basis


Protecting Children in the 21Protecting Children in the 21stst Century ActCentury Act

• Enacted in Fall 2008 to address Internet Safety in schools, specifically cyberbullying awareness and response

• Before USAC can enforce new requirements the following must occur:– FCC will issue a Notice of Proposed

Rulemaking (NPRM) seeking comment on the Act

– FCC will draft new rules and the new rules must be voted by the FCC Commissioners

– FCC will release guidance to USAC in an Order


Audits and Other Reviews


How To Prepare for an Audit How To Prepare for an Audit or ANY Type of Review or ANY Type of Review

• Follow All E-rate Rules• Document, Document, Document!

• You can’t prove that you abided by the rules if you don’t document your processes

• Plan ahead for an audit or review by documenting every step of the process

• Create E-Rate binders for EACH funding year

• Retain – Retain – Retain – Lessen your pain!! Retain ALL E-rate related documents

• Contact your service providers • USAC Compliance Documentation Checklist for

audits• http://www.usac.org/_res/documents/sl/pdf/

CompDocChecklist.pdf


Document Retention Document Retention RequirementsRequirements

• Keep for 5 years after last date of service– Be aware of contract dates and extensions – All USAC correspondence, including Quarterly

Disbursement Reports• Make sure all departments understand

documentation retention requirements for E-Rate• Align Board policies with E-rate requirements• Per 5th Report and Order: if applicant can’t prove

compliance with rules through documentation, they must assume that you didn’t follow the rules

• No documentation = Recovery of Funds(Applicant may have to pay back the SLD for E-rate

discounts they already received)


Payment Quality Assurance (PQA)Payment Quality Assurance (PQA)

• Started in August of 2010• Randomly selected USAC invoices are now

being audited on a monthly basis– CHALLENGE: USAC invoice SLC # may not directly

reference any service providers invoices the applicant has received

• Since USAC invoice selected may be a SPI (Service Provider Invoice) you may need to contact your service provider for assistance in securing information requested

• MUCH less invasive and painful than previous processes


Beneficiary and Contributor Beneficiary and Contributor Audit Program (BCAP)Audit Program (BCAP)

• Audits have been revamped – USAC listened!

• No audits during last 2 weeks of window. Auditors more flexible in accommodating applicants’ schedules

• USAC Engagement lead – more visibility and oversight of audit firms

• Auditors will spend more time on planning and review of materials and less time on site


Invoice Reconciliation

• Expectation of USAC that applicants are verifying that they are receiving the correct discounts

• Will be asked to provide this during an audit• Application of Discounts frequently

overlaps funding years• Work with service provider representatives

in verifying discounts received• Ask for reports and compare to your invoices


Other Levels of ScrutinyOther Levels of Scrutiny• H.A.T.S Visits

•Helping Applicants To Succeed

• Primarily for applicants that have had funding issues in the past

• Welcome the help…do not be afraid• Special Compliance Reviews

• Typically during PIA• Item 25 Selective Review• Cost Effectiveness Review• CIPA Compliance and Competitive Bidding

Selective Reviews


RemindersReminders•Create YOUR OWN timeline of E-Rate deadlines

–Opening and closing of the Form 471–Form 486 deadline based on FCDL

•Be aware of timelines and adhere to them•Share this information with others at your site (keep administration informed)•Have a backup person (succession planning)•Keep E-Rate files organized•Print and retain copies of everything

–USAC Link to Document Retention: http://www.usac.org/sl/about/audits/e-rate-binder.aspx.

•Additional 2009 USAC Training Audit Information: http://www.usac.org/sl/about/training-presentations/training-presentations-archive/training-2009/fall/materials.aspx

•Get on the CDE E-rate list Serv Today !!http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp


Contact InformationContact Information• State Library: Rushton Brandis,

(916) 653-5471, [email protected]• CDE/E-rate: John Vardanega,

(916) 323-2241,

[email protected]• CDE/EETT: Tech Plans: Doris Stephen,

916-324-9943

[email protected]• K-12 HSN/Butte COE: Russ Selken,

530-532-5678

[email protected]

Determine Needs Review new E-rate eligible services, determine budget, calculate E-rate discounts, update Technology Plan

Go out to Bid/ E-Rate Form 470

Prepare and post RFP/RFB, post E-Rate Form 470, Conduct job walks, answer vendor questions

Select ServicesReview proposals, develop decision matrix, select services and sign contracts

File E-Rate Application Form 471

Estimate Costs Review existing recurring services, estimate eligible costs, and determine growth

Complete application and file with USAC to request E-rate discounts on eligible services. Prepare Item 21 Attachments to support funding request

Program Integrity Review (PIA)

Item 25 Selective Review

Respond to USAC’s questions regarding application for standard PIA review. If necessary, provide extensive documentation for Selective Review.

Funding Decision/ E-Rate Form 486

Upon funding approval, file Form 486 to inform USAC of intention to use funds

Service Provider DGF Forms

File required DGF forms with service providers to start discounts (local phone and data services)

E-Rate BEAR Form 472Analyze actual costs and file BEAR form to release discounts as refund check (long distance and cellular services)

Service Certification Form File Service Certification Form if requested by USAC (internal connections)

E-Rate AuditE-Rate Site Visit

If selected for an audit or site visit, collect and prepare documentation and answer questions

USAC and FCC AppealsIf necessary, file appeals regarding denied funding requests with USAC and/or the FCC

Overview of E-Rate ProcessOverview of E-Rate ProcessStep Description Timing

Sept – Dec

Sept - Dec

Sept - Dec

Sept - Dec

January

Feb – Dec

July-Jun

Jan-June

August-Oct

Varies

Varies

Varies

Documents

E-Rate for California Intermediate/Advanced Applicants