Transcript No Slide Title

JACK O’CONNELL
State Superintendent
of Public Instruction
E-Rate for California
1
Agenda
JACK O’CONNELL
State Superintendent
of Public Instruction
1.
2.
3.
4.
5.
6.
7.
8.
General Program Information
Technology Plans
Competitive Bidding and the Form 470
Form 471
PIA (Program Integrity Assurance)
Form 486 & Invoicing
Program Updates & Gotchas
Audits, Appeals, Cost Effectiveness and
Other Reviews
9. USAC Tools – Training Materials, DRT
10. California Teleconnect Fund
11. Q and A
Afternoon
1. Form 471 Tour
2. Tour of USAC Web Site
3. Calnet 2
2
JACK O’CONNELL
State Superintendent
of Public Instruction
The California
Department of Education (CDE)
does not administer
the federal E-Rate program.
CDE has no statutory authority to
administer the federal E-Rate program
CDE only provides general information
about the E-Rate program including:
training and outreach, reference
materials, and other publicly available
SLD/USAC resources
3
JACK O’CONNELL
State Superintendent
of Public Instruction
1. General Program
Information
4
Discount Calculations
JACK O’CONNELL
State Superintendent
of Public Instruction
• Calculated based on two factors
1. Percentage of students eligible for
National School Lunch Program
http://www.usac.org/sl/applicants/step05/discountmatrix.aspx
2. Urban or Rural status of Entity
http://www.usac.org/sl/applicants/step05/urban-rural/
5
Discount Matrix
% Eligible Students
Urban
Rural
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%
http://www.usac.org/sl/applicants/step05/discount-matrix.aspx
Discount Calculations
and Entities
JACK O’CONNELL
State Superintendent
of Public Instruction
• Instructional Facilities will have a
discount that comes straight from
Matrix
• Non-Instructional Facilities will
use District Weighted Average
(District Office, Maintenance, Bus
Barn, Gardener’s Shed, etc)
–For use on Block 4 of the Form 471
7
Eligibility
JACK O’CONNELL
State Superintendent
of Public Instruction
• Schools – Elementary, Secondary,
Charters, Private, Religious, Adult
Ed (conditional), Pre-K, Juvenile
Justice
• Libraries – public, separate from
school libraries
• Consortia – any combination of the
above
8
Non-Instructional Facilities
(NIFs)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Are eligible for Priority 1 services,
telecommunications and internet
access
• Are NOT eligible for Priority 2
services, internal connections,
UNLESS they are essential for the
effective transport of information to an
instructional building of a school or to
a non-administrative building of a
9
library
Non-Instructional Facility (NIF)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Scenario One: NIF as a hub. This NIF is
essential for the transport of info to the
Schools and is eligible for P2 funding
Ineligible for Priority 2 NIF
JACK O’CONNELL
State Superintendent
of Public Instruction
• Scenario Two: NIF as an end-point. The
schools would maintain service if the NIF were
removed, therefore the NIF is ineligible for P2
support
Eligible Services Categories
JACK O’CONNELL
State Superintendent
of Public Instruction
Four categories of service
– Priority 1 (funded first)
1. Telecommunications Services
2. Internet Access
– Priority 2 (starts with neediest
applicants)
3. Internal Connections
4. Basic Maintenance of Internal
Connections
12
Eligible Services List
JACK O’CONNELL
State Superintendent
of Public Instruction
• Posted on USAC website
(http://www.usac.org/sl/tools/eligibl
e-services-list.aspx)
• Provides guidance to applicants
and service providers on the
eligibility of products and services
under E-rate
• Organized by category of service
• Revised and updated each year in
advance of the application window
13
FY09 Draft ESL updates
JACK O’CONNELL
State Superintendent
of Public Instruction
• Eligible:
– Ethernet
– VoIP user licenses
• Ineligible:
– E-mail Archiving
– Intranet Web Hosting
– Video-on-Demand Servers
– Softphones
Telecommunications
Service
JACK O’CONNELL
State Superintendent
of Public Instruction
• The transmission, between or among
points specified by the user, of
information of the user’s choosing,
without change in the form or content of
the information as sent and received.
– Examples: ATM, T-1, Centrex, Local and
Long Distance Telephone Service, Cellular
Service and Paging Service
– Rule of thumb:
• USAC funds the various types of services
• USAC does NOT fund end-user equipment - e.g.,
telephone sets
15
Internet Access
JACK O’CONNELL
• Basic conduit access to the Internet
State Superintendent
of Public Instruction
• Examples: T-1, DSL, DS-3, and
Wireless service
– Rule of thumb:
• USAC funds the conduit to the Internet
• USAC does NOT fund content
16
Internal Connections
JACK O’CONNELL
State Superintendent
of Public Instruction
• Components at the applicant site that
are necessary to transport information to
the school or library.
– Examples: Access Points, Routers,
Switches, Hubs, Wiring, PBXs and Codecs
– Rule of thumb:
• USAC funds items that get the information to the
classroom or room in the library
• USAC does NOT fund end-user equipment such
as telephones (including IP telephones) or laptops
17
2 in 5 Rule
JACK O’CONNELL
State Superintendent
of Public Instruction
• Applies to Internal Connections
funding requests only
– Is entity specific
– Implemented in Funding Year 2005
18
Basic Maintenance of IC
JACK O’CONNELL
State Superintendent
of Public Instruction
• Ensures the necessary and continued
operation of eligible internal connection
components at eligible locations.
– Ex: Repair and upkeep of eligible hardware,
wire and cable maintenance.
– Rule of thumb:
• USAC funds basic technical support of eligible
hardware. (8 X 5, M-F)
• USAC does NOT fund end-user support or help
desk
19
Basic Maintenance of
Internal Connections (BMIC)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Not subject to 2 in 5 rule
• Caution:
– If a contract goes beyond what the FCC
defines as basic maintenance, the entire
contract will be denied
– Eligible as recurring monthly services, i.e. –
SmartNet
– Include the components that the BMIC
Contract will cover on your Item 21
attachment
– BMIC can not be 24/7 coverage
20
Manage the Cycle Teamwork
JACK O’CONNELL
State Superintendent
of Public Instruction
• Authorized signer ( Legally Authorized Signer )
• Designated contact person (Will receive E-rate
calls)
• Organize paper trail
– Written Technology Plan
– Assessment of existing Contracts, with
signatures and dates (expiring contracts, etc)
– Prior years submitted applications
– Correspondence from SLD, Service Providers,
etc.
– All bids received and evaluation documents
– Calendar of Deadlines
21
JACK O’CONNELL
State Superintendent
of Public Instruction
2. Technology Plan
23
Technology Plan Overview
JACK O’CONNELL
State Superintendent
of Public Instruction
1.
FFC rules require an “approved” technology plan when receiving Erate for more than basic telephone service.
2.
Must be “written” prior to posting Form 470.
3.
Must cover all 12 months of the funding year.
4.
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 for E-rate purposes.
5.
Must include all services that the E-Rate discount covers.
6.
Must be approved by a “Certified Technology Plan Approver Locater
Tool”
Technology Plan approver locator tool:
http://www.sl.universalservice.org/reference/tech/default.asp
24
5 Required Elements of a
Technology Plan
JACK O’CONNELL
State Superintendent
of Public Instruction
1. Goals
2. Professional Development
3. Needs Assessment
4. Budget
5. Evaluation
25
Tech Plans for E-rate:
E-Rate Only Plan:
1. Goals & a Realistic
Strategy
2. Professional
Development
3. Needs
Assessment
4. Sufficient Budget
5. Evaluation
Process
• Tech Plan Help
www.usac.org/sl/
applicants/step02/
EETT Plan for E-rate:
• Executive Summary/Introduction
• Stakeholders
• Curriculum
• Professional Development
• Infrastructure
• Adult literacy
• Research
• Funding and Budget
• Monitoring and Evaluation
• Must also include E-Rate
supplemental budget analysis …
and also see:
www.cde.ca.gov/ls/et/rs/techplan.asp
Tech Plan “Written”
JACK O’CONNELL
State Superintendent
of Public Instruction
• Written same as created: When a tech
plan contains all required elements to
support services requested on Form
470 – USAC considers the plan written.
• Must document and keep evidence of
written date prior to filing Form 470 by
e-mailing plan to Assistant
Superintendent, memo with date
announcing that tech plan is written,
“date stamp”
27
Documentation of Tech Plan
Approval
1. E-rate only tech plan:
JACK O’CONNELL
State Superintendent
of Public Instruction
– You can expect to receive an approval letter
from your COE or State Library as the USACcertified technology plan approver. Ask your
COE/State Library for projected approval date.
2. EETT tech plan:
– You can expect to receive an approval message
via email from CDE that confirms your EETT
tech plan has been approved.
– In general, CDE will make a determination
regarding the approval of your EETT tech plan
within 60 to 90 days of due date for review cycle
(Cycles A, B or C).
View Tech Plan approval status at:
http://www.cde.ca.gov/ls/et/rs/ap/county.asp 28
EETT Tech Plan Approval
JACK O’CONNELL
State Superintendent
of Public Instruction
• Due dates (cycles) for submission
of EETT Technology Plan to CTAP
for approval:
– Oct 3, 2008 Cycle A (Best practice)
– Dec 5, 2008 Cycle B
– April 3, 2009 Cycle C
29
Important Tech Plan
Reminders
JACK O’CONNELL
State Superintendent
of Public Instruction
• Include a supplemental budget
analysis if using EETT plan as
your approved E-Rate tech plan –
form located at:
www.cde.ca.gov/ls/et/rs/techplan.
asp
• Ensure all E-rate requested
services/products are included in
your technology plan
30
Technology Plan Help
JACK O’CONNELL
State Superintendent
of Public Instruction
• SLD http://www.usac.org/sl/applicants/step02/
• Libraries http://www.library.ca.gov/services/libraries/e
rate.html
• CDE http://www.cde.ca.gov/ls/et/rs/techplan.asp
• CTAP:
http://www.cde.ca.gov/ls/et/rs/ctapcoo
rdinators.asp
31
Contact Information
• State Library: Rushton Brandis,
JACK O’CONNELL
State Superintendent
of Public Instruction
(916) 653-5471, [email protected]
• CDE: John Vardanega,
(916) 323-2241, [email protected]
• CDE: Tech Plans: Bill Fong,
(916) 322-5898, [email protected]
• Department of General Services
(CMAS): Mary Gilbert,
(916) 375-4377, [email protected]
• K-12 HSN/Butte COE: Russ Selken,
530-532-5678, [email protected]
32
Technology Plan Help
JACK O’CONNELL
State Superintendent
of Public Instruction
• SLD - http://www.usac.org/sl/applicants/step02/
• Libraries http://www.library.ca.gov/services/libraries/erate.html
• CDE - http://www.cde.ca.gov/ls/et/rs/techplan.asp
• Recent News Brief from SLD http://www.usac.org/sl/tools/newsbriefs/preview.aspx?id=116
33
JACK O’CONNELL
State Superintendent
of Public Instruction
3. Competitive Bidding
and the Form 470
34
Preparation for Posting of
Form 470
JACK O’CONNELL
State Superintendent
of Public Instruction
• Document ALL of your eligible
existing services, contracts and their
expiration dates
• Identify existing contracts and
services
• Expected growth – (P1 and P2)
• National School Lunch Program
(NSLP) data for discount percentage
• Identify bidding restrictions (i.e.,
CMAS, geographic restrictions, etc.)
35
Forms 470
•
JACK O’CONNELL
State Superintendent
of Public Instruction
•
•
•
Indicates the services and categories
of service which you are seeking
discounts
Must be based on tech plan
Must be posted for 28 days
Indicates if you are planning/have
issued RFP
–
•
•
Can only correct this by posting new
Form 470
Indicates any special requirements
and/or disqualification factors
Indicates who will be receiving the
services
File Online!
JACK O’CONNELL
State Superintendent
of Public Instruction
• Once the Form 470 is posted you must
1.Certify online using a PIN, OR
2.Print the certification page, sign and
mail
• Mail this form immediately
• View form online to get the Allowable
Contract Date
– Also provided in the Receipt
Acknowledgement Letter
37
Special Notes for Form 470
Processing
JACK O’CONNELL
State Superintendent
of Public Instruction
•
When does the 28 day bidding period
begin?
1. The day that ALL material for public
viewing (i.e. RFP) is made available
AND
2. The day the Form 470 is posted
online
–
If RFP is released AFTER the posting of
the Form 470 the 28 day bidding period
begins with the day the RFP was released
38
Form 470 Reminders
• Allow adequate time
JACK O’CONNELL
State Superintendent
of Public Instruction
–
–
–
–
Competitive Bidding – minimum of 28 days
Local Procurement
Board Approval
Signing Contracts
• CMAS - Letter of Intent (LOI)
• CALNET 2 – 3 signatures needed
• Understand
– Your existing services
– Products and services you will need in the coming year
• Identify E-rate category for each product and
service, P1 or P2
39
Receipt Notification Letter
(RNL)
JACK O’CONNELL
State Superintendent
of Public Instruction
• GOLDEN Opportunity to review
application and correct minor
errors
• http://www.universalservice.org/_re
s/documents/sl/pdf/sampleletters/4
70RNL.acc.pdf
40
Competitive Bidding
JACK O’CONNELL
State Superintendent
of Public Instruction
• Fair and open competitive bidding
process
• Avoid conflicts of interests
–Independent Consultant vs. Service
Provider
–Applicant vs. Service Provider
• Follow the rules – FCC, State and local
• Read the contract fine print
• Document the process!!!
41
Competitive Bidding and
Program Compliance
JACK O’CONNELL
State Superintendent
of Public Instruction
• http://www.sl.universalservice.org/reference/B
estPractices.asp
– Keep copies of all bids, winning and losing
– Documentation on the award process and the
rationale for the bid award
– Complete copies of all related contracts
• Best Practice: Use standard evaluation
process for all bids. Keep evaluation
documentation for each bid.
42
Program Compliance
JACK O’CONNELL
State Superintendent
of Public Instruction
• If you get NO bids – document this
for audit purposes
–Same is true if you get only ONE bid
• You may need to be proactive in
soliciting for bids (If not using
CMAS)
43
Evaluation Criteria
JACK O’CONNELL
State Superintendent
of Public Instruction
Price must be the most heavily weighted
factor
•Do not include Intent to Award or
Evaluation Criteria in CMAS Request for
Proposal
•Can choose most responsive and
responsible response, but must
DOCUMENT the choice and process
•Have District official SIGN and DATE the
completed rubric as acknowledgement
44
SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE
Vendor A
Selection
Criteria
Weight*
(%)
Vendor B
Raw
Weighted
Raw
Weighted
Score**
Score***
Score
Score
Prices/Charges
40%
1
0.4
2
0.8
Understanding of Needs
15%
2
0.3
1
0.15
Prior E-Rate Experience
10%
2
0.2
1
0.1
Prior District/Service Prov
experience
10%
2
0.2
1
0.1
Completeness of Response
15%
2
0.3
1
0.15
References
10%
2
0.2
1
0.1
Overall Ranking
100%
1.6
1.4
Form 470 – Multi Year
Contracts
JACK O’CONNELL
State Superintendent
of Public Instruction
• You may not need to file Form 470 every
year if:
– The language on the Form 470/RFP covered
all services on the contract AND
– The applicant indicated on the Form 470 that
a contract was being sought AND
– The applicant indicated on the Form 470/RFP
that a multi year contract (perhaps
w/voluntary extensions)
46
Contracts
JACK O’CONNELL
State Superintendent
of Public Instruction
• Must be signed AFTER 28 days have
elapsed but BEFORE you file your
Form 471
• Must be signed and dated by BOTH
parties – applicant and service provider
– CALNET 2 ATO must have three signatures
to be binding contract
• Be prepared to explain documents that
don’t look like a traditional contract.
47
JACK O’CONNELL
State Superintendent
of Public Instruction
4. Form 471
48
Form 471 – Your application
for Funds
JACK O’CONNELL
State Superintendent
of Public Instruction
• Must be filed every funding year:
• This is your actual funding request
• Based on posted on Form 470(s)
• One or more funding requests
• This is your Who, What, When, Where, &
How
–Service providers chosen
–Services being requested
–Dates for services
–Service Delivery locations
– Signed contracts or tariffed services
49
Form 471 Filing Deadline
JACK O’CONNELL
State Superintendent
of Public Instruction
• The Window for the Form 471 filing window
has not been announced yet.
• If you are on CDE E-rate List SERV, you will
be notified when FCC determines filing
deadline, which then determines Form 471
filing deadline
• If you receive USAC weekly newsbriefs,
notification will be published there.
• Must be submitted BEFORE close of window
• [email protected]
• http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp
50
Form 471 Filing Deadline
JACK O’CONNELL
State Superintendent
of Public Instruction
– Submit BEFORE close of window
• DEADLINE DATE = ??
51
Form 471 Best Practices
JACK O’CONNELL
State Superintendent
of Public Instruction
– Get a Partner
– Do your own Timeline of milestones
– File Online
– Certify BEFORE close of window
•Online if using PIN
•By trackable mail if you do not use
your PIN
–File EARLY!!
– Do everything before Deadline
– Allow enough time to fully complete
process & paperwork
– Organize your paperwork
52
Keep Your Dates in Order
JACK O’CONNELL
State Superintendent
of Public Instruction
•
Remember the correct order for dates:
– Allowable Contract Date (28 days
after 470)
THEN
– Contract Award Date
THEN
– Form 471 filing
THEN
– Form 471 Certification date
ALL BEFORE
– Window close
Form 471
JACK O’CONNELL
State Superintendent
of Public Instruction
• Apply Online =
http://www.sl.universalservice.org/
menu.asp
• Form 471 Test page =
http://usactrain.solixinc.com/Traini
ngSiteWarning.asp?
54
FORM 471 DON’TS
JACK O’CONNELL
State Superintendent
of Public Instruction
•DON’T file Priority One and Priority Two funding
requests on the same Form 471
•DON’T forget to wait at least 28 days after any
mandatory processes associated with your
competitive bidding before selecting a service
provider or signing any contracts
•DON’T submit your Form 471 BEFORE signing all
related contracts
•DON’T forget to CERTIFY your submitted
application (whether electronic or paper
certification)
55
Form 471 Reminders
JACK O’CONNELL
State Superintendent
of Public Instruction
• Separate your Priority 1 and Priority 2
funding requests onto separate Form
471s.
• Verify that you are using correct
establishing Form 470 number on each
Block 5 Funding Request.
• Choose the correct category of service
(e.g., Telecom, Internet, etc.)
• Check your math, check it again
• Review your application
• Validate the information
56
Pre-Commitment Review
Things to do before PIA contacts you
JACK O’CONNELL
State Superintendent
of Public Instruction
•
Submit your Item 21 Attachments
online or paper.
–
–
–
–
–
–
Place application number(s),FRN(s), Attachment
ID, and page numbers on Item 21 Attachments
Indicate Bandwidth when you are requesting
telecom or Internet access
Indicate the entities receiving services and
locations
Clearly label ineligible items and costs
Indicate product make and model for each product
requested
Provide a detail product or service description
Item 21 Attachment
• Samples available on USAC website
JACK O’CONNELL
State Superintendent
of Public Instruction
– http://www.sl.universalservice.org/refere
nce/Form471item21Attachments.asp
• Remove ineligible costs – be careful
– 30% rule –30% or more of funding
request dollar value cannot be for
ineligible products and services. the
entire request may be denied unless…
– Can be rectified during your PIA
process: Remove it-Split it up- separate
FRN
• Work with service provider(s) to
create your Item 21 attachment(s)
58
Reciept Acknowledgment
Letter Process
JACK O’CONNELL
State Superintendent
of Public Instruction
• Opportunity to verify information
one more time
• Three weeks from date of letter to
submit corrections
http://www.usac.org/_res/documents
/sl/pdf/sampleletters/471RAL.pdf
One Last Chance….
JACK O’CONNELL
State Superintendent
of Public Instruction
• ** Bishop Perry Order – 15 day
grace period for certifications
made after the deadline
http://www.usac.org/_res/documents/sl/pdf/List
-of-Correctable-Ministerial-and-ClericalErrors.pdf
60
JACK O’CONNELL
State Superintendent
of Public Instruction
5. Program Integrity
Assurance
61
Program Integrity Assurance
(PIA)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Applications are reviewed for
compliance with program rules
concerning areas such as:
– Properly executed contracts
– Discount calculation
– Establishing Form 470
– Eligibility of services being requested
– Eligibility of entities requesting discounted
services
– Proper completion of all of blocks/item 21
62
PIA Reviewer
JACK O’CONNELL
State Superintendent
of Public Instruction
• Be nice to your reviewer – even if
they are not nice to you!!!
Be Responsive
JACK O’CONNELL
State Superintendent
of Public Instruction
• Respond promptly, be sure to answer
questions in their entirety
• Document communication with PIA,
send e-mail to PIA as a confirmation of
your phone conversations
• Ask for more time if you need it
– Be advised that if you ask for more time
the Reviewer will move on to another
application
• Don’t assume that Reviewer has all of
the information you sent in as part of
your Item 21 attachment.
64
If corrections are needed
•
Services Cost Allocations
–
JACK O’CONNELL
–
State Superintendent
of Public Instruction
–
Work with the service provider to identify the
ineligible services, so they are clearly identified
On the Item 21 Attachment identify the ineligibles
services and associated costs
Prepare a “revised” Form 471 Block 5 to reflect the
cost allocations
•
•
Best Practice – Break out FRN with PIA’s assistance
Entity Removal
–
–
–
On the “original” Form 471 Block 4 worksheet
identify the entities to be removed
Prepare a “revised” Form 471 Block 4 worksheet if
new discount calculations and student counts
On the Block 5 funding request, indicate your
revision to the dollars requested based on the
share of the funding request for the entities being
removed
What Happens After PIA
Review
JACK O’CONNELL
State Superintendent
of Public Instruction
• A Decision – FCDL (Funding
Commitment Decision Letter)
– Funded
– Not Funded
– As Yet Unfunded (Priority 2 requests)
– Cancelled
– IMPORTANT – Check all entries in the
FCDL carefully to make sure there are
not data entry errors.
66
Post-Commitment
•
JACK O’CONNELL
State Superintendent
of Public Instruction
Review the FCDL for Accuracy
– Read the FCDL comment to
determine if modifications have
occurred to the FRN to ensure you
invoice for the correct services.
– Verify SPIN, discount, fund request,
start and end dates, and contract
number (if applicable)
– If you disagree with the decision, you
may file an appeal.
What next?
JACK O’CONNELL
State Superintendent
of Public Instruction
• FCDL should be your “trigger” to file
subsequent forms
• Starts deadline clock for appeal on
denial(s)
– Note: Appeals must be done within 60 days of
the date of FCDL
68
JACK O’CONNELL
State Superintendent
of Public Instruction
6. Form 486 & Invoicing
69
Purpose of 486
JACK O’CONNELL
State Superintendent
of Public Instruction
• Notifies USAC that entity is ready to receive
services, services have started or are
scheduled to start and invoices can be paid
• Certifies that Tech Plan is approved and
meets program requirements
• Certifies status of compliance with Children’s
Internet Protection Act (CIPA)
• Do NOT miss Form 486 deadline for your
district; LATE FILINGS WILL LOSE $$
–
http://www.universalservice.org/sl/applicants/step10/form4
86-filing-information.aspx
70
What is the Form 486
deadline?
JACK O’CONNELL
State Superintendent
of Public Instruction
– Filed AFTER receipt of FCDL
– Form 486 must be filed online or postmarked no
later than
• 120 days after the Service Start Date OR
• 120 days after the date of the FCDL
– Whichever is later
– Grace period from USAC – SLD will send letter
giving reminder to file Form 486 – (Alaska
Gateway order)
• Take this letter seriously; you have 20 days from date
of the SLD letter to take action!
71
Form 486 Compliance
Review
JACK O’CONNELL
State Superintendent
of Public Instruction
• USAC may review Form 486 for
compliance with program requirements
for technology planning before the form
is successfully processed.
• If Form 486 undergoes review, USAC
does not issue a Form 486 Notification
Letter until all compliance issues have
been resolved. (i.e. Approved Tech
Plan)
72
Form 486 Notification Letter
(486NL)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Letter received after filing of Form
486
– Verify that ALL FRNs are on letter
– Verify service start dates for each FRN
• USAC is now ready to begin
receiving invoices for payment on
these FRNs
– Form 472 – filed by Applicant OR
– Form 474 – filed by Service Provider
73
Receipt of Funds
JACK O’CONNELL
State Superintendent
of Public Instruction
• One of two ways:
– Applicant pays entire bill up-front and
gets reimbursed
• Form 472 (BEAR) – BEAR submitted by
Applicant
– Service Provider applies discounts to bills
and submits invoices to USAC for
reimbursement
• Form 474 (SPI) – filed by Service Provider
74
Special Note on Form 472
JACK O’CONNELL
State Superintendent
of Public Instruction
• Note – Form 472 (BEAR) cannot be
filed if applicant is also receiving
California Teleconnect Fund (CTF)
discounts on same services.
• Applies only to Telecommunications
(data-voice)
– Internet services may also be eligible for
CTF discounts
75
Important Reminders
•Print and retain copies of everything
JACK O’CONNELL
State Superintendent
of Public Instruction
•Keep E-Rate files organized
•Create a timeline of E-Rate
deadlines
•Share this information with others at
your site
76
JACK O’CONNELL
State Superintendent
of Public Instruction
7. Program Updates & Gotchas
77
Forms
JACK O’CONNELL
State Superintendent
of Public Instruction
• Form 470
– Be careful when specifying services
– Understand the categories of service
– Can combine all services that cover
Priorities 1 and 2 on the same Form 470
• Form 471
– File separate forms for Priorities 1 and 2
– File separate forms for different discount
bundles
78
California Pre-K and Adult Ed
JACK O’CONNELL
State Superintendent
of Public Instruction
• These student populations are eligible for
E-Rate discount in California except
• Adult Ed. enrichment VS secondary curriculum
• Children under age of 3
• Treat same as traditional classrooms or
facilities
• Obtain entity numbers and establish
poverty level
• Head Start is 90%
• May use alternative discount methods
• Be sure to add their plans to your District
technology plan to ensure compliance
79
Non-Instructional Facilities
Priority Two GOTCHA
JACK O’CONNELL
State Superintendent
of Public Instruction
 Educational Purposes – Priority 2
–Priority 2 services to Non Instructional
Facilities (NIFs) are eligible ONLY IF
those internal connections are essential
for the effective transport of information
to an instructional building of a school or
to a non-administrative building of a
library.
80
2 in 5 Rule for IC
JACK O’CONNELL
State Superintendent
of Public Instruction
• Determined on an individual entity basis or
shared worksheet (bundle)
• All entities on a Block 4 worksheet that
utilize approved funding for IC, are counted
as taking a year
• 2009 is the fifth year for the rule (if applicant
applied in 2005)
• Must file Form 500 to cancel FRN if
approved and not utilized
• Establish a matrix for tracking the
UTILIZATION of funds for approved goods
or services
• USAC tool does not track pending or utilized,
just funded
81
October Important
Deadlines
JACK O’CONNELL
State Superintendent
of Public Instruction
• Complete your BEAR for 07-08 prior to
Oct 28th, 2008
• Pay attention to 486 deadlines, Due
120 days after FCDL (Note: this is due
Oct 28th if you received your FCDL for
08-09 on or prior to July 1st)
• Have your tech plan written PRIOR to
posting your Form 470 for 09-10 if it
expires June 30th 2009 or sooner
• File your Form 470 for 09-10 NOW!
82
JACK O’CONNELL
State Superintendent
of Public Instruction
8. Audits, Appeals, Cost
Effectiveness and Other Reviews
83
Compliance Attestation
Examination
JACK O’CONNELL
State Superintendent
of Public Instruction
• AKA “The Big Audit”
• Directed by the FCC’s Office of
Inspector General (OIG)
• Randomly selected by FCC
• Annually between November and
July 1st
84
Compliance Attestation
Examination
JACK O’CONNELL
State Superintendent
of Public Instruction
• Examine payments made during a
single fiscal year – May include
examination of MUTIPLE funding years!
• Conducted by third party auditing firms
who may be on-site 2 to 8 weeks
• Purpose: Did applicant comply with
FCC rules? (not just looking for waste,
fraud, and abuse)
• Applicant must be able to prove
85
compliance with rules
Examples of Rule Violations that
Warrant Recovery of Funds
JACK O’CONNELL
State Superintendent
of Public Instruction
• Insufficient documentation of the competitive bidding
process
• Lack of necessary resources – equipment not fully utilized
• Service substitutions not meeting criteria established in the
rules
• Failure to pay (or show proof of payment) of nondiscounted share
• Failure to complete services within funding year
• Discount calculation violation
• Technology Plan not approved and/or not containing
required elements and requested services
• More specific examples located on USAC Audit training
slides located at:
http://www.universalservice.org/sl/about/trainingpresentations/training-presentations-archive/training-86
2008/fall/materials.aspx
How To Prepare For The
Audit
JACK O’CONNELL
State Superintendent
of Public Instruction
• Follow All E-rate Rules
• Retain – Retain – Retain – Lessen your
pain!!
• Document, Document, Document!
• Plan ahead for an audit by documenting
every step of the process
• Create an E-Rate Binder for EACH
funding year
• USAC Compliance Documentation Checklist
for audits
• http://www.usac.org/_res/documents/sl/pdf/Comp
DocChecklist.pdf
87
JACK O’CONNELL
State Superintendent
of Public Instruction
88
Who Should Be Available During
Audits?
JACK O’CONNELL
State Superintendent
of Public Instruction
• Person(s) who
– filed the E-rate forms
– managed the bidding and award process
– reviewed and approved invoices
– prepared E-rate invoices
– is responsible for budget (CBO)
– Is responsible for NSLP documentation
– is knowledgeable about the network and the
location of equipment
• Appoint a single contact person who can manage
interactions between auditors and staff members
89
Document Retention
Requirements
JACK O’CONNELL
State Superintendent
of Public Instruction
• Keep for 5 years after last date of
service
– Be aware of contract dates and extensions
as the 5-year minimum may be extended
– All USAC correspondence, including
Quarterly Disbursement Reports
• Make sure all departments understand
documentation retention requirements
for E-Rate
• Align Board policy with E-rate
requirements
Technology Plan
Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• Copy of Technology Plan that covers
entire year being audited (should be
part of your ANNUAL e-rate
documentation)
• Copy of Draft and creation date
documentation
• Proof of approval of Technology Plan
• Supplemental Budget analysis (if using
EETT Plan)
• Summary of the technology
environment and a high-level network
91
diagram
Bidding Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• Copy of State and Local procurement policies
• Form 470 and all request for bid documentation
• RFP/RFB/RFQ, announcements, advertisements,
addendums, etc…
• ALL correspondence between applicant and
service providers (email, phone log, job walk signin sheet, etc…)
• Copy of all bids received (winning and losing)
• Document if NO bids are received
• Bid evaluations
• Notice of Award to winning vendor
• Contract
• Board Award
• Copy of any change orders
92
Invoicing Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• Proof of payment to service providers
• Copies of warrants or cancelled checks, check register
• Auditors will ask for reconciliation of payment by invoice
• Copies of all invoices, phone bills
• Invoices should be detailed
• Copies of BEAR Forms
• Reconciliation (by FRN) of service provider
invoices to BEARs submitted to SLD (removal of
all ineligible costs)
• Copy of reimbursement check from service
provider to prove receipt of E-rate funds if
applicable
93
Priority Two Services
Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• Equipment purchased using E-Rate
• Detailed vendor invoices
• Packing slips showing date of delivery
• Walk through or sign off that shows when
services were delivered
• Asset register see detailed USAC example
• http://www.usac.org/_res/documents/sl/pdf/2007_traini
ng/samples-checklist-inventory-list.pdf
• Well-marked equipment
• Service Substitution
• Equipment Transfer documentation
• Basic Maintenance
• Maintenance log
94
CIPA Documentation
• Internet safety policy
JACK O’CONNELL
State Superintendent
of Public Instruction
• Local governing board adoption of the
Internet safety policy
• The date and a copy of the minutes of the
public hearing regarding the Internet safety
policy [Local Board adopted policy]
• Internet filtering reports
• Copies of invoices for Internet filtering
services
• Copies of Forms 479 and/or Forms
486, if applicable
95
Discount Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• NSLP Method
– Proof of discount calculations including
source data and reports
– Auditors may ask for a sampling of actual
NSLP applications
– USDA and FCC agreement
http://www.fns.usda.gov/cnd/Governance/PolicyMemos/2008/SP_29-2008.pdf
• Alternative Methods
– Keep copies of every survey and a
summary report
– Source data and annual poverty guidelines
Other Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• SPIN change requests including copy of notice to
original service provider
• School closure, consolidation or construction
documentation
• ALL communication regarding E-Rate
• Service Providers
• SLD/USAC
• Case Numbers
• PIA questions and responses
• Documentation of other services necessary to
make effective use of E-rate discounts, such as
• Training
• End user equipment
97
Other Documentation
JACK O’CONNELL
State Superintendent
of Public Instruction
• Reports from any other audits conducted
that relate to either E-rate program or the
NSLP
• Eligible Services List for every funding year
• Board minutes and policies relating to
document retention or other E-rate related
issues
• Financial statements and annual budgets
98
Other Levels of Scrutiny
JACK O’CONNELL
State Superintendent
of Public Instruction
• Site Visits
• Selective Review Information
Request (SRIR)
• Cost Effectiveness Review
99
Site Visits
JACK O’CONNELL
State Superintendent
of Public Instruction
• Single FRN reviewed
• On-site 4 hour visit
• Review of
– Asset register
– Equipment in the field
– Staff development
– Invoices/payments
– Technology plan approval
– Competitive bidding
• Best practices feedback
100
Item 25 Selective Reviews
JACK O’CONNELL
State Superintendent
of Public Instruction
• PIA on steroids
• Intensive review of the “Item 25” Block 6
certification from Form 471
• Complete documentation of necessary
resources
• hardware, software, professional
development, retrofitting, maintenance
• Competitive bidding documentation
• Technology Plan
• Budget – matching funds and support for non
E-rate items
101
Cost Effectiveness Review
JACK O’CONNELL
State Superintendent
of Public Instruction
• Occurs during PIA
• Must be able to justify that the selected solution is
‘cost effective’, not just the MOST cost effective
• Bright line test:
•Routers that cost two to three times the
commercially available price
• Single bid received does not equal cost effective
• Think about reasons why the price may be inflated
• Location
• Structural challenges
• Anticipated growth of student population, etc
102
Appeals
JACK O’CONNELL
State Superintendent
of Public Instruction
• Submitted to USAC if you feel
program rules were not upheld by
the denial of funds
• Submitted to FCC if you are
questioning the existing program
rules or if USAC denies the initial
appeal
103
JACK O’CONNELL
State Superintendent
of Public Instruction
USAC Appeals –
Approved for Limited
Circumstances
• When the appeal makes it clear that
USAC erred in its initial review
• When the applicant provides USAC with
information it did not provide when the
original request was made
• When USAC obtains policy clarification
or new policies that impact the original
decision
• http://www.usac.org/sl/about/appeals/ap
104
peals-guidelines.aspx
JACK O’CONNELL
State Superintendent
of Public Instruction
9. Tools – Data Retrieval
Tool and Other
105
Data Retrieval Tool
JACK O’CONNELL
State Superintendent
of Public Instruction
• Comprehensive data regarding status of
applications, past and present
– Search by Funding Year, Entity number, State, Type of
Service, etc
– Provides deadline information for forms
– Columns to look at on the DRT for deadline information
• B: 471 Status
• E: 470 Status
• P: Commitment Status (If funded then look at R to
see if 486 has been filed)
• R: 486 SSD (If blank, no 486 on file)
• T: FCDL date (this date + 120 calculates the
deadline for the Form 486)
• AX: BEAR or SPI
– www.usac.org/sl
106
View Prior Years’
Applications
JACK O’CONNELL
State Superintendent
of Public Instruction
• www.usac.org/sl
– Apply Online
• Form 470 – Search Posted
• Form 471 –
– Application Status (if you don’t know the
application number)
– Display (must have application number)
107
JACK O’CONNELL
State Superintendent
of Public Instruction
10. California Teleconnect
Fund
108
11. Q and A
JACK O’CONNELL
State Superintendent
of Public Instruction
• Questions?
109
Contact Information
JACK O’CONNELL
State Superintendent
of Public Instruction
• State Library: Rushton Brandis,
(916) 653-5471,
[email protected]
• CDE: John Vardanega, (916) 3232241, [email protected]
• CDE: Tech Plans: Bill Fong, (916)
322-5894
• K-12 HSN/Butte COE: Russ Selken,
530-532-5678 [email protected]
110
JACK O’CONNELL
State Superintendent
of Public Instruction
3. CALNET 2
111
CALNET 2 - What is it and
how does it fit with E-rate?
JACK O’CONNELL
State Superintendent
of Public Instruction
• Contract (s) held and administered by State
– CALNET 2 Contract effective date:
1/30/2007
– CALNET 2 contract expiration date:
1/29/2012
• Master contract purchasing vehicle for all
telecom services
• Available to all “Public Sector” Customers
• Competitively bid contract - Result of an 18
month bid process (already bid)
• Full range of products and services
• Service Level Agreements
112
CALNET 2 MSAs
• All four MSAs were signed on January 30, 2007
JACK O’CONNELL
State Superintendent
of Public Instruction
• Each MSA is for a 5-Year Term (to January 29, 2012) with
the Potential for 2 One-Year Extensions at the State’s
Option (2014)
• Each MSA is a separate contract called CALNET 2, along
with their MSA number. They are also collectively called
CALNET 2.
• Until CALNET I expires you will see “I” and “II” or “1”
and “2” after the word CALNET to try to avoid “Contract
Confusion”
• In some cases you will see just “CALNET” - that will
mean both CALNET I and CALNET II as applicable; as
CALNET I phases out, it will mean CALNET 2
113
CALNET 2 MSAs
JACK O’CONNELL
State Superintendent
of Public Instruction
MSA 1 – Voice, Data & Video Services – AT&T
MSA 2 - Long Distance and Network Based Services – AT&T
MSA 3 – Internet Protocol Voice, Data, and Video Services
– Verizon Business (VzB)
MSA 4 – Broadband Fixed Wireless Access Data Services – VzB
 10% Lower Pricing Overall From CALNET I
114
CALNET 2 MSAs
Transition of Existing CALNET Services to MSAs I & 2 – No
Cost
JACK O’CONNELL
State Superintendent
of Public Instruction
Transition Out Will Eventually Impact Your Agency; CALNET I
Expires by 12/03/08 based on Individual ATO Agreements
 CALNET 2 – Each ATO is for a Two Year Term – When Term is
Up,
Can Use the MSAs Without another ATO For Those
Services on the ATO; Adding Services Requires New ATO, New
term
 New Pricing Starts Within 120 Days of Each Approved
CALNET 2 ATO
http://www.dts.ca.gov/stnd/calnet-transition.asp
115
CALNET 1 to CALNET 2
• State Posted Form 470 267290000544188 on Sept
15, 2005
JACK O’CONNELL
State Superintendent
of Public Instruction
–
–
–
–
Includes Telecommunications Services
Did NOT Include ISP
Limited Internal Connections (extended demarc)
CALNET 2 Contract was signed on January 30th,
2007 (State Master Contract)
– CALNET 2: http://www.dts.ca.gov/stnd/calnetII/calnetII.asp
– RFP: http://www.dts.ca.gov/stnd/calnet-II/revised-calnetIIrfp.asp
• May wish to post your own form 470 for all services
you will apply for (See additional hand-outs)
• Do your own analysis to determine best choice
for your agency
• Three Signatures are required on a CALNET 2
116
contract
CALNET 2 MSAs 1 and 2 includes
MSA 1
• High Speed Optical
Services (Enhancements
and Additional Services)
– ATM
– Opt-e-MAN
– CSME
JACK O’CONNELL
State Superintendent
of Public Instruction
• Enhanced Data Services
– MPLS (AVPN)
– Remote VPN (Anira)
– Interlata Data Services
• Internet Services
• Unified Messaging
• Enhanced Centrex Features
– VoIP
•
•
•
•
MSA 2
• Enhanced Toll
Free
• Long Distance
Voice
• Audio
Conferencing
• Net Conferencing
• Complete Suite of
Call Center
Capabilities
– ACD
– IVR
Business Centrex lines
Voice mail
Local trunks
Frame relay
117
IP Voice, Data, and Video Services
(MSAs 3 & 4)
Internet Protocol (IP) based solutions to
provide voice, video, and data services
JACK O’CONNELL
State Superintendent
of Public Instruction
• Voice Over IP
(VOIP) Services
• Converged
Services – VOIP
• Converged
Services - IP
Transport
• Converged
Services Required Premise
Equipment
• IP Contact Center
Services
• Other IP Services
• Wiring and Support
Services
118
SLD Guidance for E-rate
Yr 11
JACK O’CONNELL
State Superintendent
of Public Instruction
• See Page 5 of SLD Decision Grid
for SLD guidance (handout and
next slide)
• Clients either:
– post own Form 470 OR
– use State’s Form 470
#267290000544188, posted on
9/15/2005.
119
SLD Decision Grid
How to decide if schools/libraries
should post their own Form 470?
JACK O’CONNELL
State Superintendent
of Public Instruction
1. Are the services you are seeking
included in State’s RFP?
2. Are services you are seeking included in
State’s Form 470?
A. Telecommunications services (Priority 1 services)
B. Limitations to State’s Form 470:
• Form 470 did not include Internet Access
• Form 470 included Internal Connections defined as:
Service or Function: Extended D-Marc
• Form 470 did NOT include Basic Maintenance on
Internal Connections (Priority 2 services)
• You can do a specific form 470 if the service
you need is not covered by the state form 470
(see the limitations described above as
examples)
121
Moving from CALNET to
CALNET 2 “Steps in Ordering”
JACK O’CONNELL
State Superintendent
of Public Instruction
Work with your Account team to sign
ATO & create product list attachment
• To be legal binding contract, CALNET 2
contract requires 3 signatures: customer +
AT&T + State
– ATO
– Attachment to ATO (product list attachment for
svcs to be covered by ATO) has to be initialed
by customer
122
CALNET 2 – Multiple SPINS
JACK O’CONNELL
State Superintendent
of Public Instruction
CALNET 2 awarded to two service providers
•Each Service Provider may have multiple
SPINs
•Verify SPIN with service provider BEFORE
filing the Form 471
123
CONTACTS
JACK O’CONNELL
State Superintendent
of Public Instruction
• CALNET Transition Questions and Requests
for Information
– Phone: (916) 657-9150
– Email: [email protected]
• CALNET Transition Homepage
– URL: www.dts.ca.gov/stnd/calnet-transition
• Statewide Telecommunications and Network
Division Homepage
– URL: www.dts.ca.gov/stnd
• Department of Technology Services
Homepage
– URL: www.dts.ca.gov
DTS-STND and Contractor’s CALNET
Homepages, etc.
www.calnet.ca.gov
124
CALNET 2 Contract
Resources AT&T
www.CALNETII-Info.com
JACK O’CONNELL
State Superintendent
of Public Instruction
• Customer Sales & Support Center:
•
877-972-6279
• CALNET Billing:
•
877-9-CALNET, 877-922-5638
• Account Team:
– Contact your account team
– Bev Agron, E-rate Specialist (925)
824-0615
• calnet.ca.gov (select AT&T logo)
126
JACK O’CONNELL
State Superintendent
of Public Instruction
CALNET 2 Contract
Resources
Verizon Business
• Verizon Business
– 800-477-0221
– http://calnet2.verizonbusiness.com
– http://CALNET.ca.gov (click on
Verizon link)
127