Transcript Document

E-rate Training
Workshop for
Beginners
Presented by:
Julie Tritt Schell
Fall 2005
Agenda
 115 slides in 180 minutes = 1.5 min/slide
 History of Program
 Rules/Eligibility Issues
 Process, Step-by-Step
 Completion of Forms = 12 - 1
 What does * Mean?
2
What is E-rate?
 Telecommunications Act of 1996 established
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“Universal Service Discount Program for Schools and
Libraries”
Annual $2.25 billion program
Provides 20-90% discounts on telecommunications
services, Internet access, and internal connections
Fund made up from charges on your phone bills
Most public libraries, public and private K-12 schools,
including charters and vo-techs are eligible
3
Who Administers E-rate?*
 FCC
 Created program and its rules
 USAC
 Universal Services Administrative Company
 Created by FCC to run E-rate and other universal
service programs
 Pays invoices
 SLD
 Schools and Libraries Division
 Entity within USAC that runs E-rate
 Makes no policy decisions
4
Why is PDE involved?
 PA schools and libraries apply along side
30,000 other schools and libraries in U.S
 We want to make sure you know how to
complete forms, etc so you can get $ you
deserve
 PDE does not administer program, they
simply provide information and conduct
workshops for applicants
5
Fair Warning!
 E-rate is not an easy process
 Only for the strong willed and determined
 Long process, a lot of paperwork, some frustration
 Patience is needed, in addition to diligence in
reading correspondence
 Rewards can be great
 Never ever try to cheat the program
6
Rules and Reasons
 Random audits over last 2 years found that 70%+ of
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applicants were in violation of program rules
Several high-profile cases of WFA
Congressional hearings held
$11 million dedicated to audits next year
1000 additional mini-audit site visits being conducted
annually
Result… 95% of applicants that AREN’T cheating the
program are now required to comply with additional
rules designed to close the loopholes
Remember: If it is too good to be true, it probably is!
7
Getting Organized
 E-rate Binder contains everything:
 Forms, Instructions, Samples
 Tips, checklists, contact sheets
 Powerpoint handouts
 Timeline
 Rule 1 – Get Organized
 Create your Own Year 9 Binder
 Keep copies of all forms, letters, bids, correspondence,
etc.
8
E-rate Admin Acronyms
 Client Service Bureau (CSB)
E-rate “Help Desk” where applicant & service providers can
get answers to questions
 Accessed via toll-free number
 Technical Client Service Bureau (TCSB)
 Team answering technical questions about eligible services
& program rules.
 Also accessed via same toll-free number. CSB will refer you
to this area.
 Program Integrity Assurance (PIA)
 Team that reviews every application for compliance w/FCC
rules.
 Everyone receives calls from PIA before funding
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9
Resources to Remember*
 SLD web site: www.sl.universalservice.org
 SLD CSB: 888-203-8100
 PA E-rate listserve
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use notecard to sign-up
 PA E-rate website: www.e-ratepa.org
10
Applicants
 Must use E-rate Entity Number in order to participate
 One for every building in your district or library
 All applicants already have unless it’s a new building
 Must have FCC Registration Number (FCCRN)*
 Just for billed entity
 All applicants should have obtained in Yr 7
 Must have NCES code (schools) or FSCS (libraries)
 Listed on PA E-rate website under Helpful Documents
 Leave blank if non exists
11
Service Providers*
 Must obtain Service Provider Identification Number in
order to participate (9 digit #)
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Info on SLD web site under Vendor Area
Service Provider/SPIN Search on SLD web site
 Not required to pay into Fund to get SPIN
 Only telecom carriers must pay
 Only sign contracts with providers that have SPIN
 Providers should update contact info on Form 498,
Block 11
 File Form 473 (SPAC) annually to USAC to get paid
12
Funding Priorities
 Needed because demand exceeds cap of $2.25 billion
 Priority One: Telecommunications and Internet Access
All approved-inside the window-likely to be funded
 Priority Two: Internal Connections / Basic Maintenance of IC
 Funds go first to neediest applicants (90% discount level),
then to others in order of discount until funds are exhausted
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Year 1 -- funded to 70%
Year 2 – all approved applications funded
Year 3 – down to 82%
Year 4 – down to 87%
Year 5 – down to 81%
Year 6 – down to 70% - significant rollover funds
Year 7 – down to 81%
Year 8 – only at 90% so far
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Funding Priorities
 What does this mean?
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Always apply for all telecommunications
services and Internet access
Make judgement call on internal connections
depending on discount level and time
available to complete application
14
Exactly what services
ARE and are NOT
eligible?
Eligible Telecom Services
 MUST be provided by regulated
telecommunications carrier
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Must have Y on SPIN search
 Basic Telecom Services
 Local, long distance & voice mail
 Advanced Telecom Services
 T-1, ATM, Frame Relay, ISDN, lit fiber, etc.
 Satellite services and leased dishes
16
Eligible Telecom Services, cont.
 Wireless Services
 Cellular service – all staff eligible
 Paging service
 Calling cards
 Not pre-paid cards
 Centrex, custom calling features
 Installation fees OK
 Can be installed before funding year begins
so services are ready by July 1
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Limited to priority 1 services
17
Ineligible Telecom Services
 Sharing of bandwidth
 900 Calls
 Payphones
 Cost of not-publishing phone numbers
 Cost of additional directory listings
 End user equipment (phones, beepers, cell phones,
fax machines, etc.)
 VOIP as an actual service
18
Tariffed Services/MTM*
 Services that are purchased mainly from a phone company,
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such as T1
OR
Monthly services such as cell or Internet Access
For which no contract is signed
Must competitively bid every year, regardless of competition in
your area for those services
E-rate does not recognize multi-year tariffs… these must be
contracts.
19
Fiber Networks*
 Dark Fiber (unlit) is not eligible
 Lit Fiber is eligible … IF
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Modulating electronics are bundled with the
lease cost of the fiber
Applicant will never own fiber
Applicant cost allocates any lease of fiber that
isn’t being used in that funding year.
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Internet Access
 Eligible:
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Subscription fee to ISP
E-mail
Firewall fees
Webhosting – be careful!
Internet bandwidth
 Ineligible:
 Filtering
 Any remote access
outside school
property to internet
 Blackberry services
presumed ineligible
21
On-premise, Priority 1 Equipment*
 Permitted if bundled from telco or ISP
 Must certify:
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No applicant ownership – ever
No exclusive use
LAN functions without use of equipment
Service provider maintains equipment
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Not applicant
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Eligible Internal Connections
 Network and phone
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wiring
Routers
Switches
Hubs
Network servers
Video codecs
 System operating software
 Wireless Access Points
 Private branch exchange
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(PBXs)
Firewalls
Anything needed for transport –
not end user devices
Installation of eligible internal
connections
“Basic” Maintenance contracts
on eligible internal connections
 New category for basic
maintenance on 470/471
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Ineligible Internal Connections
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Personal computers
FAX machines
Asbestos removal
Cameras
Electrical wiring
Teacher training
 Network management s/w
 Routers used for remote
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access
Curriculum software
Phones, beepers
Owned WANs
Salaries of SD staff to
install or maintain network
or components
Any equipment used for
remote access to network
or Internet
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Eligibility Issues*
 Purchased Wide Area Networks (WANs) are not E-
rate eligible.
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If leased from a regulated telecommunications provider
then it’s eligible as a Telecommunications Service
Local Area Networks (LANs) are eligible
 SLD has made the WAN/LAN distinction as follows:
 If the network crosses a public right-of-way, it’s
considered a WAN.
 Connections considered LANs:
 computer to computer
 classroom to classroom
 building to building on the same campus that does not
cross a public right-of-way
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Gotcha!
Words to Never Use
 2-way Radios/walkie-
 Cellular phones
talkie (direct connect
OK as a cell service)
 Filtering
 Network monitoring
 Directory
advertising/listings
 Management
 Redundancy
 Helpdesk
 24 hour technical
support
 Insurance policies
 Remote access
26
Questions about
Eligibility Issues?
Application process at a Glance*
28
Year 9 Details
 For services rendered 7/1/2006 - 6/30/2007
 Application process has begun!
 Write tech plan now
 File 470 now
 File 471 when window opens (normally
beginning of November)
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Window normally closes first week in February
 Must be inside window to be funded
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You Must Have a Technology
Plan!*
 Five SLD technology plan criteria
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Goals and Strategies for using technology
Needs Assessment
Professional Development
Budget – including sources of funding
Evaluation
 Must align with 470 request for services
 Must be “written” before 470 is filed
 Must cover full 12 months of NEXT funding
year
30
Technology Plans, cont.
 Vendors cannot write or approve technology plans
 No tech plan required for basic phone service or long
distance (includes cell and voice mail)
 Centrex is not basic phone service
 Be sure to include dates of tech plan!
 Get approval letter by July 1
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then Print/Maintain Approval Letter
 Tech plans approved for no more than 3 years
 Certify on 486 who approved plan
 Can amend technology plan if yours is not specific
enough
31
Competitive Bidding
 Everyone must do it
 Even if no competition in your area
 Even if bidding under state law
 Must be done when signing any new contracts
 Must be done each year for all tariffed/MTM services
 Bidding on web site does not exempt you from
bidding under state law
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Can be done simultaneously
Only exception is if someone bid it for you (PEPPM)
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Competitive Bidding on SLD web site
using Form 470*
 File Form 470 any time to begin procurement process
Listserve reminder sent out
Should align with technology plan
Provide as much detail as possible so bidders can respond – a
mini RFP
 If you have an RFP, list where it can be obtained, AND
provide description of what’s in RFP
Make sure you list possibility of multi-year contract and/or
contract with voluntary extensions
Vendors cannot help with RFP/470 process
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Form 470
 File online
 Posted on SLD web site 28-days
 Must have form posted on web at least 29 days
before the Form 471 window close (example: Feb 4
close = Jan 7 deadline)
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Don’t wait this long
File 470 by Thanksgiving, if possible
 Mail certification page to SLD ASAP unless
eCertifying
Read the
Instructions!
34
Get 470 Information Immediately!*
 Posted 470 available on SLD web site to view
 Upper right corner of online application shows:
 Posting date of application
 Earliest date that your contract can be signed and thus
471 submitted
 Date that certification page was received at the SLD
 View and print immediately after posting
 SLD also sends this info in Receipt Notification
Letter*
35
Next: Bid Evaluation*
 After 470 is posted for at least 28 days, review all
bids received for all services
 Cannot consider “free services” such as “I’ll give you
20 computers if you purchase my service”
 Cannot consider ineligible services in price evaluation
factor
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Can be considered in another category
 Keep documentation of criteria used to select vendor
 Keep all winning and losing bids
 Retain all correspondence between applicant and all
vendors (winning and losing)
36
Choosing the Winning Bid
 Applicant must to pick “most cost-effective bid”
 Cost doesn’t have to be only factor, but must be most heavily
weighted factor
 For example, if you have 3 bid evaluation criteria, price must
be at least 34% of total weight.
 Examples of other specified factors:
 Prior experience
 Personnel qualifications
 Technical excellence
 Management capability
 Cost of switching providers
 Etc.
37
Signing E-rate Contracts*
 Signing Contracts/Selecting Provider must be done
before you submit 471
 Be careful not to make any decisions, sign anything
or file any forms during 28 day waiting period.
 Contracts must be signed and dated by both parties
 Must sign contracts unless tariff or MTM service
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If selecting PEPPM, no contract needed, but you must
be able to explain why you chose reseller A over
reseller B
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Signing E-rate Contracts*
 List contract extensions and contract expiration dates
 These also must be listed in RFP or 470, Item 7b
 Include non-E-rate funding out clauses
 Separate internal connections/wiring portions of
contracts for highest discount schools
39
Questions about Bidding /
Form 470 / Bid Evaluation /
Signing Contracts?
Next: Filing the 471
 Very important form
Watch listserve for reminders
Filed by entity that actually pays the bills
Shows discount calculations
Requests discounts (funding)
Describes services ordered and details contract
information
Must be filed at least 29-days after posting Form 470
eCertify!! Or submit signed certification page ASAP
(postmarked within window)
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41
What is My Discount?*
 Two criteria make up discount:
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Poverty
Location
42
Poverty – NSLP Data*
 Based on National School Lunch Program Eligibility
 Eligibility based on % of student whose family’s income
is within 185% of federal poverty level
 Doesn’t matter if school serves lunch or participates
in NSLP
 AVTS and nonpublic schools use their students’ data,
not sending schools’ data
43
Location*
 Urban/Rural defined by Counties
 Uses Metropolitan Statistical Area data
 Many counties in PA seem misclassified
 List by county in binder
44
Discount Matrix for Single School*
% of Students Eligible for
School Lunch Program
Discounts
Urban
Rural
<1%
20%
25%
1-19%
40%
50%
20-34%
50%
60%
35-49%
60%
70%
50-74%
80%
80%
75-100%
90%
90%
45
Alternative Measures to NSLP Data*
 Goal: Discounts based on true eligibility – not
participation.
 2 Ways to do this
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Take existing participation data and add to it
 Using sibling match
 Using existing family income data
Conduct family income survey
 Must survey 100% of families. If 50% response rate,
then OK to extrapolate the rest
 Maintain complete records
 Sample survey available*
 Valid for 2 years
46
Alternative Measures to NSLP*
 Also, participation in these programs also
qualifies:
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TANF
Medicaid
Food Stamps
Supplementary Security Income
Federal public housing assistance (section 8)
Low income home energy assistance (LIHEAP)
47
Alternative Measures*
 Not acceptable eligibility measures
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Title 1
Feeder schools method
Principal’s estimate
48
Discount Calculations by Entity*
 Schools: Use straight matrix discount
 Districts: Use weighted average of schools’ individual
discounts
 Library: Use the total number of students eligible for
NSLP in the school district in which the library is
located divided by the total number of students in that
school district, then use matrix discount
 Library System: Uses simple average of member
libraries’ discounts
 Consortium: Uses simple average of members’
discounts
49
If You Are an Individual School*
1
3
4
5
6
7
Name of School
Urban or
Total
# of Students
% Students
Discount
Rural
# of
Eligible for NSLP
Eligible for
% from
U or R
Students
NSLP
Discount
Col. 5/Col. 4
Matrix
50%
80%
Oak Elementary
R
100
50
Always uses straight matrix discount for single schools.
50
If You Are a School District*
District discounts are based on weighted average discounts,
based on individual school discounts.
1
3
4
Name of School
Urban or
Rural
U or R
Students
R
R
R
100
212
566
Oak Elementary
Spruce Jr. High
Elm High School
5
6
7
Total
# of Students
% Students
Discount
Weighted Product
# of
Eligible for NSLP
Eligible for
% from
for Calculating Shared Discount
NSLP
Discount
(Col. 4 x Col. 7)
50%
46%
48%
80%
70%
70%
80.00
148.40
396.20
50
98
273
8
District Totals for calculating
Weighted Average Discount
878
10c Weighted Average Discount % for Shared Services
(Col. 8 total divided by Col. 4 total. Round to nearest %)
624.60
71%
51
If You are a Library Outlet/Branch or
Library System*
1
2
3
4
5
6
7
8
Name of Eligible Entity
Entity Number and
Urban or
# of Students in
# of
% of
Discount from
Entity
FSCS of Library
Rural
District
Students
Students
Matrix
Number of
Eligible for
Eligible for
School
NSLP in
NSLP
District in
District
which Library
is Located
Treetop Branch Library 123123
Greenleaf Branch Library 123234
Acorn Branch Library
123122
U 987654321
525
U
800
U
1220
200
130
350
38%
16%
29%
60%
40%
50%
125246
125400
125659
System Totals for calculating Shared Discount
10c Library Systems % (Col. 7
total divided by # of sites in Col. 1.
50%
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If You Are a Consortium*
1
ELIGIBLE MEMBER ENTITIES
Name of each individual school, school district and/or
library/library system in consortium
Treetop School District
Woodsville Library System
Forest Academy
Totals for calculating Shared Discount
10c Shared Discount %
(Col. 4 total divided by # of sites in Col. 1. Round
to nearest %)
4
ENTITY DISCOUNT
Individual School: Discount from Worksheet A
School District: Weighted average discount calculated in Worksheet A
Library System : Shared discount from Worksheet B
71%
67%
60%
198%
66%
53
Questions about Discount
Calculations?
Form 471 Filing Tips
 File and certify online!
 Multiple forms OK
 No one-to-one correlation with 470 required
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Meaning, you can have (1) 471, but (3) 470’s.
 All services listed on 471 must have been
listed on a 470
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30% Rule - Important
 30% or more of FRN Ineligible
SLD will deny entire request
 29% or less of FRN is Ineligible
 SLD will attempt to remove ineligible costs and
approve only eligible costs
 Why? SLD Time Allocation Issues
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Cost Allocation Guidelines*
 If service or component is part eligible/part ineligible:
 Must perform cost allocation based on percentage of
function that is eligible
 Cannot request discounts on ineligible portion
 Can subtract ineligible costs before 471 OR
 Can subtract ineligible costs on 471, Block 5
 Cannot list any ineligible service/component on
attached description of services.
 Example: networks shared by district and community
(ineligible) organization
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Item 21: Description of Services*
 Probably most crucial piece of 471
Part of form used to deny applications
Never, ever list an ineligible item
PIA will call applicants with specific questions
Must have separate description for each FRN
(funding request)
Detailed list of products with associated prices that
add up to funding request
 Maintenance request showing equipment being
maintained
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Item 21 Attachments – Paper*
 Provide enough information, but not too much
 Identify each attachment
 Be sure to mail with signature page or fax to SLD
 Not required to be postmarked or faxed within window, but
should do so a few days after window closes
 Copies of bills if ongoing service, and explanation if
request exceeds documented costs

Quote sheet from service provider if new tariff or
month-to-month service -- Itemized details of one-time
costs associated with Internet access or
telecommunications services
 Copies of contract
59
Item 21:
New Online Description of Services*
 Consistent format
 Don’t need to submit bills or contracts
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But must have available and may be asked to
submit during application review
 Should speed processing of application
 Online Demo (if available)
60
471 Certifications - Important
 Have secured access to all non-eligible resources
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(computers, training, software, maintenance, etc)
Tech plan written (covering all 12 months)
Carefully considered all bids
Selected most cost effective solution with price being
primary factor
Complied with state procurement laws
Won’t resell services or products
Will retain all documents for 5 years
61
471 Certs, cont.
 Authorized to submit application
 Acknowledge that if you lie or cheat that you’ll be
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disbarred from program and prosecuted
Have cost-allocated out any ineligible functions or
components
Haven’t violated 2/5 rule
Non-discounted portion won’t be paid or waived by
service provider
Nothing free offered by service provider
62
Paying Non-Discounted Portion
 If your discount is 65%, you MUST have the ability to
pay the remaining 35%
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Cannot come from outside source
Must have the nondiscounted portion in budget
 Many vendors will say they can get a “grant” for this
amount – NOT PERMITTED
 90% discount applicants beware.
63
Paying for Non-Eligible
Resources*
 Applicant must certify that they can also pay
for the non-E-rate eligible items that are
needed to effectively use the E-rate eligible
services/equipment
 Future budget tally now required on 471, Item
25b
 If you file multiple Forms 471 for this funding
year, you must calculate your total budgeted
amount allocated for these resources and
enter that total on Item 25d of each Form 471.
64
Item 25d, cont.
 Hardware

Such as computers, printers, fax machines, video equipment,
scanners, CD-ROM drives, and application servers
 Professional development
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Such as ongoing technology-related training for technical staff,
teachers and/or librarians
 Software
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Such as end-user applications
 Maintenance
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Such as systems maintenance and operations costs for
ineligible hardware and software and salaries of technical staff
 Retrofitting
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Such as electrical wiring, asbestos removal, building
modifications, renovations, and repairs.
65
Questions on Form 471?
Next: SLD Sends 471 Receipt
Acknowledgment Letter (RAL)*
 Confirms receipt
 Verifies block 5 information
 Confirms successful data entry of application into
SLD system
 Example in binder
 Service provider receives similar letter when they are
listed as SPIN on 471
 Make corrections, if any, and fax back to SLD ASAP
 Cannot ask for more $
67
Next: Application moves to Program Integrity
Assurance (PIA) Review*
 Checks for rule compliance – Audit phase
 Eligible Services
 Eligible Entities
 Appropriate discount
 Almost everyone receives a PIA call
 Document contacts with PIA
 May be sent to Selective Review Process
 Copies of budget, tech plan, all correspondence,
winning and losing bids, bid evaluation process and
documentation, etc.
68
Next Step?
 Wait
 Return PIA calls within 7 days

Ask for extension if absolutely necessary
 E-mail Julie if you’re not sure how to answer a
question
 Watch PA E-rate listserve and mail to see
which wave of funding you’re in!
69
Next: SLD Sends Funding
Commitment Decision (FCDL) Letter!*
 Tells you which funding requests (block 5’s) of
Form 471 are approved or denied
 Provides information for Form 486
 Can appeal if you don’t agree with your
decision


Must do so within 60 days
Can appeal to the SLD for their errors, or FCC if policy
decision. If SLD denies, can appeal to the FCC within
60 days
70
Next: Applicant Files 486*
 Must be postmarked no later than:
120 calendar days after the Service Start Date featured on
the Form 486 or
 120 calendar days after the date of the Funding Commitment
Decision Letter
whichever is later.
Signifies that it’s OK for SLD to pay any invoices for that FRN
Lists who approved tech plan
Certifies CIPA compliance
Submit online (using pdf version – not interview)
Most information contained on FCDL
Use 07/01/2006 as service start date for Yr 9
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71
CIPA*
 Filtering and Internet Safety Policies
 Required for any school or library receiving:
Either Internal connections or Internet access
 Recipients of only Telecommunications
services are exempt from E-rate CIPA
compliance
 Consortium members submit Form 479 to
consortium leader certifying compliance
 Details in binder
72
How do YOU get E-rate $?
 Two choices
 Discounts on bills
 OR
 Reimbursement process
 Must select one or the other for entire year
 Try to determine choice in contract or prior to
choosing service provider

Now a non-binding choice on 470
 If you want discounted bills, call provider as soon
as you are funded
73
Discounted Billing Method*
 Discounts appear on applicant’s bill
 Service providers submit Form 474.
 the Service Provider Invoice Form (SPIF)*
 Provider should get reimbursed by SLD within 60 –
90 days from date of submission.
 Applicants do nothing except make sure they are
getting discounts they deserve on bills.

Do the math!
74
Reimbursement Method*
 Applicant pays bill in full
 Applicant submits Form 472 – BEAR Form for
reimbursement*
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Quarterly, semi-annually, or at end of year
Complete one BEAR for each SPIN
Must contain SPIN signature on last page
 Send or fax to SPIN
 SPIN will mail or fax back
 AT&T has signed copy on web www.att.com/erate
 Must be submitted by Oct. 28 (following funding year)
for recurring services; by Jan. 28 for non-recurring
services.
75
Reimbursement Method, cont.
 SLD approves BEAR and sends approval letter to
vendor and copy of letter to applicant
 SLD then waits 20 days and sends check to SPIN
 SPIN must send check to applicant within 20 days
 Call SLD if:
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You don’t get a check in a timely manner after receiving
approval letter or SPIN takes too long to sign BEAR
76
Invoicing Scrutiny
 Auditors found that many applicants were:
 Substituting products or services without receiving Erate approval
 Not basing reimbursement requests on actual bills
 Result: BEAR and SPIF invoices are being heavily
scrutinized
 Be careful not to switch services/products in midfunding year. If so, seek clarification whether it’s
allowable. If it is, get official permission from the SLD
 SLD may ask you to sign service cert for SPIF
 SLD may ask for copies of bills for BEAR
77
Quarterly Disbursement Reports
 Sent only to applicants
Authorized person
 Billed Entity (BEN) address
 Contains all invoice (Form 472 and Form 474)
payment authorization amounts for the Billed
Entity for all funding years approved during that
quarter
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78
Optional Form 500*
 File Form 500 to either:


Change a service start date or a contract
expiration date
Cancel or reduce a funding commitment
 Warning: reductions or cancellations of
funding commitments are irreversible
 But: Auditors are citing applicants for leaving
significant $ on the table and not filing a Form
500
79
Questions?
Funding Commitments / Form 486 / CIPA
/ Reimbursements / Discounted Billing?
But wait! There’s more!
Changing Service Providers*
 Can change providers
 Only after receiving funding commitment letter
 Must write a letter to the SLD requesting change
 Must certify that you are permitted in your contract and
by state law to do so, and that you have informed your
current provider.
 Sample letter/form in binder
 Can also submit on web at “Submit a Question”
 Can request to split an FRN
 Allocate $ to 2 providers in same funding year
82
eCertification*
 If a person signed a previous 470, 471 or 486, SLD
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will be mailing you a new PIN in early November.
PIN then may be used to 470, 471, 486 Forms
PIN is given to a person and is specific to that entity.
Not given to an entity
Must accept terms/conditions before use
Can change PIN to your own password
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6-8 characters, at least 1 special character (*&%$#@)
 Applicants are highly encouraged to use their PINs
 Previous PINs will be discarded eventually
83
Document Retention*
 Rules now require all applicants to retain ALL
E-rate and related documents for 5 years
from last day of service in a particular funding
year
 If auditor visits in 4 years, and documents are
missing, it will be the basis to recover all
funding from that funding year
84
Documents to Retain*
 Tech plan and approval
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letter
Consultant agreements
RFP and proof of
publication date
All vendor correspondence
Winning and losing bids
Professional development
records
 Contracts signed by both
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parties
NSLP documentation
Budgets
Purchase orders
Packing slips
Asset or inventory records
Installation records
Invoices
Proof of payment to SLD
85
2/5 Rule*
 An entity may only receive discounts 2 out of
every 5 years for internal connections

Doesn’t include basic maintenance
 Building level, not district level
 Plan accordingly to maximize discounts
 “Strikes” related to FCDL, not 471 or invoices
86
Transfer of Equipment*
 E-rate funded equipment must remain at approved
site for 3 full years after installation
 After which it may be moved to another eligible
location, providing documentation is retained
describing transfer
 If school or library closes, equipment may be moved
to another entity, regardless of discount
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Must send letter to SLD outlining closing of school and
transfer of equipment
Must keep documentation regarding transfer for 5
years
87
Service Substitutions*
 SS required when a change is made to any service on your
approved 471, Item 21 attachments
 After FCDL issued
 Applicant must seek SLD approval which meets all of these
conditions:
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The substituted services or products have the same functionality as the
services or products contained in the original proposal.
The substitution does not result in an increase in the requested prediscount amount. (The substitution amount may be higher, but will only
be funded at the amount originally approved.)
The substitution does not violate any contract provisions or state or
local procurement laws.
The substitution does not result in an increase in the percentage of
ineligible services or functions.
The substitution is consistent with the establishing Form 470 posting
and original RFP, if any.
88
Red Light Rule/FCCRN*
 Says if a service provider or applicant owe $
to the feds, no E-rate $ will be paid until all
debts are cleared
 Must now have FCCRN for billed entity, in
addition to E-rate entity number
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https://svartifoss2.fcc.gov/cores/CoresHome.html

Most entities’ FCCRNs are now in SLD system
 Ask service provider if they are on red-light list
89
Consortia*
 Letters of Agency
 Follow standards listed on website
 Name of consortium leader, consortium member
name, type of service, signature, date and title of
people signing document.
 Sample LOA available for review
 Must be dated before filing of Form 471
 Avoid common pitfalls:
 Didn’t specify type of service (can’t just say “E-rate
eligible services”)
 Forgot to sign and/or date LOA.
90
E-rate Consultants
 Not a bad idea if complex application
 Be certain that the consultant:
 Is in constant communication with you
 Provides you with copies of all forms
 Provides you with periodic updates on your
applications
 Does not sign your forms
 Does not have any relationships with vendors
 Sign Letter of Agency
91
Data Retrieval Tool*
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Most data on SLD website, using DRT
Download who state, by SPIN, by entity, etc
Updated nightly
Shows:
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Entity info / 471# / FRN # / 470 # / SPIN
if FRN funded
whether 486 was submitted
last date to invoice
original requested amount & committed amount
discount
invoice paid and by what mode
etc.
92
Let’s Talk Katrina
 FCC will open a special 2005 “E-rate window for
Katrina-affected entities.”
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All entities will receive highest discount (90%?)
Proposed $130+ million
 Rollover funds?
 Year 8 internal connections funding?
 Waiver of almost all deadlines and record-keeping
requirements for affected entities.
 Entities receiving Katrina evacuees will be able to
raise discounts in Year 8.
 Affected States want:
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More money
Expedited priority for future years’ requests
93
Impact of Katrina Window
 Year 8
 Further slow review and commitments b/c of
implementation of Katrina window?
 Eat into internal connections $?

Will SLD rescind announcement that IC will go to 87%
applicants?
 Year 9
 Delay 471 filing window?
 Delay processing and funding of non-Katrina
applications?
 Will there be any internal connections $ for any nonKatrina-related entities?
94
Future of E-rate - FCC
 New FCC Chairman, Kevin Martin
 Appears to be supportive of E-rate
 Released Notice of Proposed Rule Making
(NPRM)
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Asks for comments on sweeping changes
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Formula to Schools/Libraries?
What forms could be eliminated?
What else should be changed?
Comments due Oct. 18/Replies due Dec. 19
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Easy to file!
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Future of E-rate - Congress
 House Commerce Committee’s Oversight and
Investigations Subcommittee soon to release findings
of major E-rate probe
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Anticipated to propose major changes
Won’t be pretty
 Reauthorization of Telecom Act of 96
 Is E-rate still needed?
 Should some services NOT receive discounts?
 Aren’t all the schools/libraries wired by now?
 Is broadband for schools more important than
affordable broadband for communities?
 Who should pay into the fund
 ISPs? Internal connections vendors?
96
Year 8: Remaining Issues
 Many PA applicants still not funded for Yr 8,
priority 1
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If you’re listed as “certified – in window”,
you’re fine
 After receiving FCDL, file Form 486
 Ask vendors to set up discounted bills, if
wanted
 File BEARs if paying 100% of bills
 File for SPIN change if providers change
97
Application process at a Glance *
98
Questions?
Time to take an E-rate
Quiz
E-rate Quiz
 You must have the non-
discounted share of the
service in your budget?
 True
 False
101
E-rate Quiz
 You don’t need a
contract for any tariffed
service.
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True
False
102
E-rate Quiz
 A school must use
NSLP participation to
calculate discounts.
 True
 False
103
E-rate Quiz
 Under the FCC rules
of priority, who
receives E-rate
funding first?
Everyone who applies
for telecom services
and internet access
2. Applicants with
discounts of 90%
3. Applicants who have
never applied before
1.
104
E-rate Quiz
 Which of these
services is not
eligible for E-rate
discounts?
1.
2.
3.
4.
5.
Basic phone service
T1 lines
Leased satellite dishes
Voice mail
Filtering
105
E-rate Quiz
 Which of these
instances of remote
internet access is
eligible for E-rate
discounts?
 A teacher dials-in from
home to District’s computer
system to access the
Internet.
 The superintendent dials-in
from a conference to the
District’s computer system
to access the Internet.
 The technology director
uses her Blackberry phone
to access the internet from
home.
106
E-rate Quiz
 E-rate contracts may be
signed on or after what
day?
1st day after 470 is
posted to web
2. 28th day after 470 is
posted to web
3. Anytime
4. 29th day after 470 is
posted to web
1.
107
E-rate Quiz
 A Form 470 is not
required if you bid
under state law.
 Contracts may be
voluntarily extended if
such extensions were
listed in the 470/RFP
OR in the contract?
 True
 False
 True
 False
108
E-rate Quiz
1. Return unused funds
 A Form 486 is used to:
to the SLD
2. Request discounts
3. Post requests to SLD
web site
4. Tell the SLD to turn on
funding/CIPA
certification
109
E-rate Quiz
 The 486 must be
submitted by July 1.
 True
 False
110
E-rate Quiz
 For recurring services,
the BEAR Form (472)
must be submitted by:
 November 4
 January 16
 July 1
 October 28
111
E-rate Quiz
 An applicant-owned
WAN is not eligible.
 True
 False
112
How Did You Do?
Now that you know the
rules…
Let’s complete the forms,
step-by-step