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
“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
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
9
Resources to Remember*
SLD web site: www.sl.universalservice.org
SLD CSB: 888-203-8100
PA E-rate listserve
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 #)
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
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
13
Funding Priorities
What does this mean?
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
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
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,
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
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.
20
Internet Access
Eligible:
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:
No applicant ownership – ever
No exclusive use
LAN functions without use of equipment
Service provider maintains equipment
Not applicant
22
Eligible Internal Connections
Network and phone
wiring
Routers
Switches
Hubs
Network servers
Video codecs
System operating software
Wireless Access Points
Private branch exchange
(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
23
Ineligible Internal Connections
Personal computers
FAX machines
Asbestos removal
Cameras
Electrical wiring
Teacher training
Network management s/w
Routers used for remote
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
24
Eligibility Issues*
Purchased Wide Area Networks (WANs) are not E-
rate eligible.
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
25
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)
Window normally closes first week in February
Must be inside window to be funded
29
You Must Have a Technology
Plan!*
Five SLD technology plan criteria
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
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
Can be done simultaneously
Only exception is if someone bid it for you (PEPPM)
32
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
33
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)
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
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
If selecting PEPPM, no contract needed, but you must
be able to explain why you chose reseller A over
reseller B
38
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)
41
What is My Discount?*
Two criteria make up discount:
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
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:
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
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%
52
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
Meaning, you can have (1) 471, but (3) 470’s.
All services listed on 471 must have been
listed on a 470
55
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
56
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
57
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
58
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
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
(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
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%
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
Such as ongoing technology-related training for technical staff,
teachers and/or librarians
Software
Such as end-user applications
Maintenance
Such as systems maintenance and operations costs for
ineligible hardware and software and salaries of technical staff
Retrofitting
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
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*
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:
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
78
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
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
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
letter
Consultant agreements
RFP and proof of
publication date
All vendor correspondence
Winning and losing bids
Professional development
records
Contracts signed by both
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
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:
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
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*
Most data on SLD website, using DRT
Download who state, by SPIN, by entity, etc
Updated nightly
Shows:
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.”
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:
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)
Asks for comments on sweeping changes
Formula to Schools/Libraries?
What forms could be eliminated?
What else should be changed?
Comments due Oct. 18/Replies due Dec. 19
Easy to file!
95
Future of E-rate - Congress
House Commerce Committee’s Oversight and
Investigations Subcommittee soon to release findings
of major E-rate probe
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
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.
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