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JACK O’CONNELL State Superintendent of Public Instruction E-Rate for California Intermediate/Advanced Applicants 1 E-Rate Acronyms JACK O’CONNELL State Superintendent of Public Instruction BEN – Billed Entity Number CIPA – Children's Internet Protection Act FCDL – Funding Commitment Decision Letter FRN – Funding Request Number SPIN – Service Provider Identification Number SSD – Service Start Date RAL – Receipt Acknowledgement Letter (Form 471) RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch Program NIF – Non-Instructional Facility PIA – Program Integrity Assurance USAC Link: http://www.usac.org/sl/tools/reference- area.aspx 2 E-Rate Organization JACK O’CONNELL State Superintendent of Public Instruction • Federal Communications Commission (FCC), an independent U.S. government agency, oversees the E-rate program • Universal Service Administrative Company (USAC), a not-for-profit, administers the Erate program along with three other programs • Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-rate 3 E-Rate Rules JACK O’CONNELL State Superintendent of Public Instruction • The FCC sets rules and policies through orders – Policies are defined in the text of orders • USAC/SLD develops procedures for specific actions, such as how to process applications – USAC submits its procedures to the FCC for approval each year 4 E-Rate Budget JACK O’CONNELL State Superintendent of Public Instruction •This cap will be adjusted for inflation starting in FY2010 •Once each year, FCC can roll over unused funds from previous funding years into the current funding year 5 California Department of Education (CDE) & State Library Do Not Administer the Federal E-Rate program. JACK O’CONNELL State Superintendent of Public Instruction CDE & State Library have no statutory authority to administer the federal E-Rate program CDE & State Library only provide general information about the E-Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources 6 E-Rate Cycle JACK O’CONNELL State Superintendent of Public Instruction • Funding Year is July 1 – June 30 • Funding commitments are made by funding year (services starting on or after July 1 and ending on or before the following June 30) • The Window – Form 471 application window –Opens mid to late fall and closes February – This year Funding Cycle July 1, 2011 to June 30, 2012 (AKA Funding Year 14 or FY 2011) 7 E-Rate Timeline: July 1st – June 30th JACK O’CONNELL State Superintendent of Public Instruction *These dates are estimates. In order to derive the Form 470 deadline, applicants must count backwards from the Form 471 deadline. **FCC announces Form 471 filing deadlines each Fall. 8 JACK O’CONNELL State Superintendent of Public Instruction 6th Report and Order Overview 9 Overview What’s Included? JACK O’CONNELL State Superintendent of Public Instruction • Dark Fiber now eligible from any provider • Makes permanent after hours, onsite community use • Indexes funding cap to inflation • Pilot program for schools providing wireless offsite access • Technology Plans only for P2 • More on competitive bidding, including gifts • Changes to ESL – “Unbundled warranties” ineligible • Disposal of Equipment and SPIN changes 10 Access to Broadband Dark Fiber JACK O’CONNELL State Superintendent of Public Instruction • Lease of fiber, lit or dark, is eligible in Telecom or Internet Access from any provider (dark fiber must be lit immediately) • Providers can be telcos; state, regional or research and educations networks; or private networks * See Eligible Services discussion for further details. 11 Improving Broadband Access JACK O’CONNELL Community Use of Schools’ E-rated Services State Superintendent of Public Instruction • After school hours, schools may open their facilities to the general public to use E-rate supported services • Schools decide whether or not to provide such access • Service must primarily be for educational purposes • Schools cannot purchase additional services to support community use • Community use is limited to non-operating hours and only on campus • Schools may not charge for use of services or facilities purchased through E-rate though they may charge a fee to offset ineligible costs (e.g. security, additional electricity, etc.) 12 Improving Broadband Access Indexing the Funding Cap to Inflation JACK O’CONNELL State Superintendent of Public Instruction • Funding has been capped at $2.25B since 1999 • Cap will not decrease in event of deflation • FCC will announce the increase annually • For FY 2010, inflation is deemed 0.9% • New cap for FY 2010: $2,272,500,000 • This increase is in addition to any rollover funds 13 Improving Broadband Access JACK O’CONNELL State Superintendent of Public Instruction E-rate Deployed Ubiquitously (EDU) 2011 Pilot Program • Pilot allows $10M in FY 2011 to support innovative and interactive off-premise wireless device connectivity for schools and libraries. • FCC will use the pilot to gather more information about issues affecting such use which can later be used for permanent rules. • FCC expects data reporting by those selected • Strong preference given to those already implementing such programs 14 Streamlining & Simplifying Technology Plans JACK O’CONNELL State Superintendent of Public Instruction • New requirements apply for FY 2011 and beyond • No longer required for: – Priority One (Telecom and Internet Access) • Still required for: – Priority Two services (internal connections and Basic Maintenance of Internal Connections) • There may be other reasons to continue to have a current technology plan *See Tech Plans slides later in presentation for more details on subject. 15 Streamlining & Simplifying Disposal of Equipment JACK O’CONNELL State Superintendent of Public Instruction • Disposal or resale is permitted no sooner than five years after installation date • Applicants may receive payment or other consideration in return for disposal • Applicants are not required to use equipment for five years, nor are they required to dispose of equipment after five years. • No notification to USAC is needed, but update your asset registers • This does not change the requirement to report transfers of equipment made less than three years from purchase 16 Streamlining & Simplifying Competitive Bidding Process JACK O’CONNELL State Superintendent of Public Instruction • Form 470 – All must continue to use the Form 470 process – New, streamlined Form 470 will be available for use for FY 2011 • New form is approved by OMB and awaiting online implementation • Applicants that file Forms 470 prior to effective date do not need to refile • Applicants that file Form 470 after the effective date MUST use the new form 17 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • New Order codifies* that competitive bidding process must be fair and open. – All potential bidders must have access to the same information and must be treated in the same manner throughout the procurement process – Additions or modifications to the Form 470/RFP must be made available at the same time and in a uniform manner to all potential bidders *Codification makes this a rule, subject to violation, as opposed to merely a guideline 18 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • Rule violations include (but are not limited to): – Applicant has relationship with the service provider that unfairly influences the outcome of the competition or provides them with “inside” information – Someone other than the applicant (or their representative) prepares, signs and submits the Form 470 – Service provider is listed as the contact on the Form 470 and the provider is allowed to bid 19 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • Codification of the Gifts Rules – Receipt of gifts by applicants from service providers and potential service providers is a competitive bidding violation. – Exceptions mirror Federal Government regulations • Modest refreshments not offered as part of a meal (e.g. coffee and donuts at a meeting) are OK • Items with little or no intrinsic value such as certificates and plaques are OK 20 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • Gifts – Exceptions: • Items worth $20 or less (meals, pencils, pens, hats, t-shirts etc) as long as those items do not exceed $50 per year per employee from any one source (service provider) are OK. • This means all gifts from all employees, officers, representatives, agents, independent contractors, or directors of the service provider (including manufacturers). 21 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • Gifts – Gift prohibitions are always applicable, not just during the competitive bidding process – Prohibition includes soliciting and receiving any gift or other thing of value from a service provider participating in or seeking to participate in the E-rate program. – Service providers may not offer or provide any gifts to applicant personnel involved in E-rate 22 Streamlining & Simplifying Fair and Open Competitive Bidding Rule JACK O’CONNELL State Superintendent of Public Instruction • Gifts – Gift rules are not intended to discourage companies from making charitable contributions to schools, as long as those contributions are NOT directly or indirectly related to an Erate related procurement. *Effective…NOW 23 Streamlining & Simplifying JACK O’CONNELL State Superintendent of Public Instruction SPIN Changes • Pre-commitment SPIN changes – Corrective SPIN changes only (i.e.. data entry errors) • Post-commitment SPIN changes – Operational SPIN changes • Must have legitimate reason to change, such as Breach of Contract or provider unable to perform and • Must select provider with next highest point value in evaluation 24 JACK O’CONNELL State Superintendent of Public Instruction E-Rate Technology Planning 25 Recent Changes to E-rate Technology Plan Requirements JACK O’CONNELL State Superintendent of Public Instruction • Beginning in FY2011, Tech plans are required for Priority 2 services ONLY (internal connections and basic maintenance of internal connections) • The budget requirement for the Tech plans has been eliminated 26 Technology Plan Overview JACK O’CONNELL 1. FFC rules require an “approved” technology plan when receiving E-rate discounts for priority 2 services (internal connections: switches, routers, cabling and basic maintenance) 2. Find your public charter, district or COE Tech Plan status at: http://www.cde.ca.gov/ls/et/rs/techplan.asp 3. *Decision: Decide which tech plan to use: A) E-rate only, B) EETT technology plan (best practice approach because it also qualifies applicant for K12 Microsoft voucher funding) Note: Libraries leverage your master plan in developing your technology plan. 4. Tech Plan must be “written” prior to posting Form 470 for priority 2 services. 5. DOCUMENT the existence of this “Written Plan” – i.e., Letter/E-mail from Cabinet, screen print of file name and date, and physical copy of plan. 6. Must cover all 12 months of the funding year (July 1 – June 30). 7. E-rate only plans should not cover more than 3 years; EETT tech plans that meet Erate requirements can cover 5 years with progress review during 3 rd year. 8. Tech plans must include any priority 2 services for which E-rate discounts are sought. 9 Must be approved by a “Certified Technology Plan Approver” See the Technology Plan approver locator tool on the USAC website: http://www.sl.universalservice.org/reference/tech/default.asp 10. Use the technology plan builder and the expertise of your CTAP regional assistance: http://myctap.org/index.php/techplan/tpb State Superintendent of Public Instruction 27 4 Required Elements of a Technology Plan Used for E-rate JACK O’CONNELL State Superintendent of Public Instruction 1. Clear statement of goals and realistic strategy for using telecommunications and information technology to improve education or library services. 2. Professional Development strategy to ensure staff understands how to use technologies to improve education or library services 3. Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services 4. Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise. 28 The “Two Tech Plans” 1. 2. 3. 4. E-Rate Only Plan: Goals Professional Development Needs Assessment Evaluation Process • Tech Plan Help www.usac.org/sl/ applicants/step02/ Enhancing Education Through Technology (EETT): • Executive Summary/Introduction • Stakeholders • Curriculum • Professional Development • Infrastructure • Adult literacy • Research • Funding and Budget • Monitoring and Evaluation www.cde.ca.gov/ls/et/rs/techplan.asp 29 CTAP Tech Plan Builder Tool JACK O’CONNELL State Superintendent of Public Instruction 30 EETT Tech Plan Cycle Dates: JACK O’CONNELL State Superintendent of Public Instruction • The final dates to submit your EETT Tech Plan for approval are: 1. Cycle A: September 17, 2010 2. Cycle B: November 19, 2010 3. Cycle C: March 11, 2011 31 Under what circumstances do you revise or amend tech plan? JACK O’CONNELL State Superintendent of Public Instruction • Tech plans should be reviewed every year for relevancy as technology and situations change (before filing form 470) • EETT tech plans (5 yr. life) used for E-rate require a “progress review” at year three (must document this) • If annual review finds major changes: major budget cutbacks (close schools); adding a new technology program (distance learning); or add new technology (internet service) – should revise entire plan • Major or significant changes require a new tech plan and approval to incorporate these significant changes • Bottom line – the tech plan should support E-rate services requested on form 470 and contracted for on form 471 • Minor changes add addendum to the tech plan file (does not require re-approval) – E.G Changing of 32 hardware standards, etc. Technology Plan “Gotchas” JACK O’CONNELL State Superintendent of Public Instruction • Service Providers may not act as technology plan approvers, write/create, or assist in the tech plan in any capacity • Education Service Agencies (ESA’s) or County Offices (COEs) that act as service providers and applicants – must build appropriate “firewalls” between roles, see USAC guidance: http://www.usac.org/sl/applicants/step01/esa-guidelines/ • Same staff should not work in both roles • Provide functional/organizational separation within organization 33 Technology Plan “Must Do” Reminders: 1. Must be “Written” prior to posting Form 470 for priority 2 services: – It must be documented that it is written before the posting of the form 470! (Applicant must document the existence of this plan, i.e., e-mail with plan attached, memo from cabinet level about the plan being written, including the date. “DATE STAMP,” submit EETT tech plans during cycle A [final date November 19, 2010]) 2. Must include a sufficient level of detail and cover all priority 2 services for which E-Rate discounts are being sought on the Form 470(s) and subsequent Form 471(s). 3. Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier for priority 2 services 4. E-rate only plans must be approved by a “USAC Certified Technology Plan Approver” see USAC link: http://www.usac.org/sl/tools/reference/tech/default.asp 5. Combination E-rate/EETT Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp 6. Must include all four required elements regardless of the type of plan being used (E-rate only or EETT) JACK O’CONNELL State Superintendent of Public Instruction 34 Technology Plan Help • E-rate Plans: John Vardanega, [email protected], 916-323-2241 JACK O’CONNELL State Superintendent of Public Instruction • EETT Plans: Doris Stephen, [email protected] 916-324-9943 • CTAP:http://www.cde.ca.gov/ls/et/rs/ctapcoord inators.asp • CTAP Tech Plan Builder: http://myctap.org/index.php/techplan/tpb • Libraries: Rushton Brandis, [email protected] , 916-653-5471 35 JACK O’CONNELL State Superintendent of Public Instruction Eligible Services Overview 36 Overview JACK O’CONNELL Priority One – Telecommunications Services State Superintendent of Public Instruction • Support for telecom services • Examples: – Local and Long Distance service – Cellular Service • Text messaging – Ethernet 37 Overview JACK O’CONNELL State Superintendent of Public Instruction Priority One – Telecommunications Services • Other examples of eligible telecom services – T-1, T-3 – DSL – PRI – Satellite service – Interconnected Voice over Internet Protocol (VoIP) – Taxes and fees – Installation and configuration 38 Overview JACK O’CONNELL Priority One – Telecommunications Services State Superintendent of Public Instruction • Some examples of services NOT eligible: – Broadcast “Blast” messaging – Monitoring services for 911, E911 or alarm telephone lines – Services to ineligible locations – End-user devices 39 Overview Priority One - Telecommunications JACK O’CONNELL State Superintendent of Public Instruction • Telecommunications Services and Telecommunications are now two categories on the Eligible Services List (ESL) 1. Telecommunications Services can only be provided by an eligible telecommunications carrier a. On Form 470/471 as Telecommunications Services 2. Telecommunications {only} can be provided by non-telecommunications carriers via fiber in whole or in part a. On Form 470/471 as Telecom or Internet 40 Access Overview Priority One – Internet Access JACK O’CONNELL State Superintendent of Public Instruction • Support for Internet Access includes the Internet Service Provider (ISP) fees and the conduit to the Internet • Examples also include: – E-mail Service – Wireless Internet Access – Web Hosting – VoIP 41 Overview Priority One – Internet Access JACK O’CONNELL State Superintendent of Public Instruction • Some examples of services NOT eligible: – Costs for Internet Content • Subscription services such as monthly charges for on-line magazine subscriptions – Internet2 membership dues – Web site creation fees – Software, services, or systems used to create or edit Internet content 42 Overview Priority Two – Internal Connections JACK O’CONNELL State Superintendent of Public Instruction • Support for equipment and cabling on-site that transport information to classrooms or public rooms of a library • Does NOT include end-user components such as computers • Subject to the Two-in-Five Rule – Entities can only receive funding every two out of five years 43 Overview Priority Two -Internal Connections JACK O’CONNELL State Superintendent of Public Instruction 44 Overview Priority Two -Internal Connections JACK O’CONNELL State Superintendent of Public Instruction 45 Overview JACK O’CONNELL State Superintendent of Public Instruction Priority Two – Basic Maintenance of Internal Connections • Support for basic maintenance of eligible internal connections • Examples: – Repair and upkeep of eligible hardware – Wire and cable maintenance – Basic technical support – Configuration changes 46 Overview JACK O’CONNELL State Superintendent of Public Instruction Priority Two – Basic Maintenance of Internal Connections • Agreements or contracts must state the eligible components covered, make, model and location • Service must be delivered within the July 1st to June 30th timeframe • Two-in-Five Rule does not apply to BMIC 47 JACK O’CONNELL State Superintendent of Public Instruction Eligible Services What’s New 48 What’s New Leased Dark Fiber for FY 2011 JACK O’CONNELL State Superintendent of Public Instruction • Leased Dark Fiber included as Telecommunications on the FY2011 Eligible Services List • Support for the lease of fiber, whether lit or dark, as a priority one service, from any entity • On the FCC Form 471, applicants should select the Telecom box if the leased fiber is provided by a telecom carrier • In all other cases, the applicant should select the Internet Access box 49 What’s New Leased Dark Fiber for FY 2011 JACK O’CONNELL State Superintendent of Public Instruction • Dark fiber must be lit immediately • Does NOT allow for unneeded capacity or warehouse dark fiber for future use • Maintenance costs of dark fiber and installation costs to hook up the dark fiber are eligible – This includes charges for installation within the property line • The purchase or lease of modulating electronics in Priority One is NOT eligible 50 What’s New Leased Dark Fiber for FY 2011 JACK O’CONNELL State Superintendent of Public Instruction • Special Construction charges to build out connections from applicants’ facilities to an off-premise fiber network are NOT eligible • Some examples of ineligible special construction charges include: – Design and engineering costs – Project management costs – Digging trenches – Laying fiber 51 JACK O’CONNELL State Superintendent of Public Instruction Eligible Services Services Updates 52 Services Updates Web Hosting JACK O’CONNELL State Superintendent of Public Instruction • Web hosting change: – Blogging and discussion boards are now eligible • Status quo: – Remains eligible for discount as Internet access – Web features including content created by third party vendors, databases for grades, student attendance files, or other reports are NOT eligible – These ineligible web features must be cost allocated 53 Services Updates Wireless Internet Access Applications JACK O’CONNELL State Superintendent of Public Instruction • Wireless IA Applications update: – Wireless service dedicated to an ineligible service or group of services will be deemed entirely ineligible • For example, cellular service for the GPS tracking for a bus is entirely ineligible – Bundled services will require cost allocation • For example, a voice plan for the bus driver and a data plan for GPS tracking must be cost allocated to remove the data plan • USAC will conduct outreach to applicants if no reasonable cost allocations were provided 54 Services Updates Other Ineligibles JACK O’CONNELL State Superintendent of Public Instruction • Separately priced firewalls in Priority One are not eligible – Bundled firewalls included with Internet access service is eligible – Firewalls are eligible as Internal Connections • Intrusion Detection/Intrusion Prevention Devices are not eligible • Anti-Spam and Anti-Virus Software are not eligible • On-line backup solutions are not eligible 55 • Scheduling services are not eligible Services Updates Basic Maintenance of Internal Connections Clarifications JACK O’CONNELL State Superintendent of Public Instruction • Unbundled warranties are NOT eligible • Unbundled warranties allow for broken equipment to be fixed or if it is beyond repair, replaced • Unbundled warranties are considered a type of retainer and not as an actual maintenance service • This does not apply to a manufacturer’s warranty of no more than three years that is included in the price of the equipment OR • If the retainer is tied to actual service performed 56 Services Updates JACK O’CONNELL State Superintendent of Public Instruction Basic Maintenance of Internal Connections • Applicants may make estimates based on: – Hours per year of maintenance – History of needed repairs and upkeep – Current life of eligible internal connections • Basic maintenance will be paid on the actual work performed and hours used only 57 Questions? JACK O’CONNELL State Superintendent of Public Instruction 58 JACK O’CONNELL State Superintendent of Public Instruction E-Rate Program Revised FCC Forms 470 and 471 59 Target Window Timeline Target timeline for FY2011 FCC Form 471 filing window JACK O’CONNELL State Superintendent of Public Instruction • Current FY2011 Form 470 became available July 1, 2010 – Applicants can file a Form 470 now and cite it on an FY2011 Form 471 • FY2011 Form 471 window target early January 2011 with the revised Form 471 (current version can no longer be used) • When the revised version of Form 470 becomes available, applicants can file a Form 470 using the revised version and cite it on an FY2011 Form 471 • Form 471 window target closing mid to end of March 2011 60 Filing a Form 470 “Current” and “revised” FY2011 Form 470 JACK O’CONNELL State Superintendent of Public Instruction • You are STRONGLY encouraged to: – File AND certify (online or on paper) the current Form 470 before the revised Form 470 becomes available OR – File AND certify (online or on paper) the revised Form 470 after it becomes available 61 Filing a Form 470 “Current” and “revised” FY2011 Form 470 JACK O’CONNELL State Superintendent of Public Instruction • If you file the current Form 470 online, you must certify it online or on paper before the revised Form 470 is posted – Client Service Bureau (CSB) will ask you for corrections if your certification does not match your online filing (i.e., if you don’t print your certification using Certify Complete) • If you file the current Form 470 on paper, you must postmark it before the revised Form 470 goes live on the USAC website – Otherwise, CSB will preserve your postmark date but you will be required to re-submit on the revised Form 470 62 JACK O’CONNELL State Superintendent of Public Instruction Revised FCC Forms 470 and 471 Changes Common to Both Forms 63 Changes Common to Both Forms Eligible Entities/Type of Application (Additions in red) JACK O’CONNELL State Superintendent of Public Instruction • • • • • Individual school School district Library Consortium Statewide application for (two-letter state code) _____ – All public schools in state – All non-public schools in state – All libraries in state 64 Changes Common to Both Forms Recipient(s) of Services (check all that apply) JACK O’CONNELL State Superintendent of Public Instruction – Public – Private – Charter – Tribal – Head Start – State Agency • You must check at least one option • You may check multiple options 65 Changes Common to Both Forms Consultant Information JACK O’CONNELL State Superintendent of Public Instruction • Applicant will now identify a consultant that is assisting the applicant with the application process • Client Service Bureau can quickly assign a consultant registration number (CRN) – Each consulting firm has a CRN – If the firm has multiple employees, the individual employee who assisted with the form is also identified – In the last block, a checkbox has been added to indicate if the consultant is also 66 the authorized person Changes Common to Both Forms Consultant Information Fields JACK O’CONNELL State Superintendent of Public Instruction • • • • • • • Consultant Registration Number Name (of consulting firm or sole proprietor) Name of employee Street address/City/State/Zip Telephone number with extension Fax number Email address 67 Changes Common to Both Forms Technology plan certification JACK O’CONNELL State Superintendent of Public Instruction • I certify that, if required by Commission rules, all of the individual schools and libraries receiving services under this form are covered by technology plans that do or will cover all 12 months of the funding year, and that have been or will be approved by a state or other authorized body, or an SLDcertified technology plan approver, prior to the commencement of service OR • I certify that no technology plan is required by Commission rules. 68 Changes Common to Both Forms Educational purposes certification JACK O’CONNELL State Superintendent of Public Instruction • I certify that the services the applicant purchases at discounts provided by 47 U.S.C. § 254 will be used primarily for educational purposes and will not be sold, resold, or transferred in consideration for money or any other thing of value, except as permitted by the Commission’s rules at 47 C.F.R. §§ 54.500, 54.513. 69 Changes Common to Both Forms Email addresses JACK O’CONNELL State Superintendent of Public Instruction • All email addresses featured on these forms must now be entered twice – Both e-mail address entries will be compared – If they don’t match, both fields will be cleared and the applicant must try again – This process helps to guarantee the accuracy of this important information 70 JACK O’CONNELL State Superintendent of Public Instruction Revised FCC Forms 470 and 471 Form 470 71 Form 470 - Changes Changes to Form 470 JACK O’CONNELL State Superintendent of Public Instruction • Block 1: Applicant Address and Information – Eligible entities that will receive services / Recipient(s) of services added – Consultant information added • Block 2: Summary Description of Needs or Services – Tariffed/month-to-month, contracted services (multi-year, voluntary extensions), contracts signed before July 19, 1997 deleted – SPI/BEAR/no preference checkboxes deleted 72 Form 470 – Deleted Fields T/MTM or contract information (Current Items 7a – 7c) JACK O’CONNELL State Superintendent of Public Instruction 73 Form 470 – Deleted Fields JACK O’CONNELL State Superintendent of Public Instruction SPI/BEAR/No preference (Current Items 8b, 9b, 10b, and 11b) 74 Form 470 – Deleted Fields Basic Telephone Service (Current Item 14) JACK O’CONNELL State Superintendent of Public Instruction 75 Form 470 - Changes Changes to Form 470 JACK O’CONNELL State Superintendent of Public Instruction • Block 3: Technology Resources deleted – Basic telephone service deleted – Necessary resources deleted • Block 4: Recipients of Service – Statewide recipients of services moved to Block 1 – Telephone numbers and prefixes for multiple eligible entities deleted – Ineligible participating entities deleted 76 Form 470 – Deleted Fields Necessary Resources (Current Items 15a-15f) JACK O’CONNELL State Superintendent of Public Instruction 77 Form 470 – Deleted Fields JACK O’CONNELL Phone numbers and prefixes (Current Item 16c) State Superintendent of Public Instruction 78 Form 470 – Deleted Fields Ineligible participating entities (Current Item 18) JACK O’CONNELL State Superintendent of Public Instruction 79 Form 470 - Overview Changes to Form 470 (continued) JACK O’CONNELL State Superintendent of Public Instruction • Block 5: Certifications and Signature – Some certification language changed (next slide) – Consultant as authorized person checkbox added. 80 Form 470 – Certifications Block 4 - Changes to certification pages JACK O’CONNELL State Superintendent of Public Instruction • Item 17 – Technology plan certification (slide 19) • Items 18 and 19 – Current Item 21 has been split into two separate certifications – The text contained in the two certifications remains the same as on the original combined certification • Item 20 – Educational purposes certification (slide 20) • Item 21 – The following sentence has been added: – I certify that I have considered what financial resources should be available to cover these costs. 81 Form 470 – Certifications Block 4 - Changes to certification pages JACK O’CONNELL State Superintendent of Public Instruction • Item 22 – I certify that I am authorized to procure eligible services for the eligible entity(ies)… Signature page • Item 27b – Checkbox for consultant as authorized person 82 JACK O’CONNELL State Superintendent of Public Instruction Revised Forms 470 and 471 Form 471 83 Form 471 - Changes Changes to Form 471 JACK O’CONNELL State Superintendent of Public Instruction • Block 1: Billed Entity Address and Information – FCC Registration Number added • If you do not already have an FCC RN, you can visit https://fjallfoss.fcc.gov/coresWeb/publicHome.do – Type of application and Recipient(s) of services added – Consultant information added • Block 2: Impact of Services Ordered – Collection of broadband services data added • Block 3: [reserved] 84 Form 471 - Changes Changes to Form 471 (continued) JACK O’CONNELL State Superintendent of Public Instruction • Block 4: Discount Calculation Worksheet – Libraries must now provide urban/rural and student count information on the worksheet – Certain entity-level data added or requested in a different format • Block 6: Certifications and Signature – Some certification language changed – Consultant as authorized person checkbox added (slide 17) 85 Form 471 JACK O’CONNELL State Superintendent of Public Instruction Changes to Form 471 • Block 2: Impact of Services Ordered – BEFORE ORDER column removed • “AFTER ORDER” columns to complete: – Individual schools and school districts complete the “Schools” column – Libraries and library consortia complete the “Libraries” column – Consortia complete one or both as appropriate depending on the consortium members 86 Form 471 Block 2: Impact of Services Ordered – Items 7a through 7g JACK O’CONNELL State Superintendent of Public Instruction • Number of students (schools) or patrons (libraries) • Number of (class)rooms with telephone service • Number of drops (direct Internet connections) • Number of (class)rooms with Internet access • Number of computers or other devices with Internet access • Number of dial-up (<56K) Internet connections • Direct broadband services (next slide) 87 Form 471 Block 2: Impact of Services Ordered – Item 7g JACK O’CONNELL State Superintendent of Public Instruction • Direct broadband services: Number of buildings served at the following speeds: __ __ __ __ < 200 kbps 200 kbps – 1.5 mbps 1.5 – 3 mbps 3 – 10 mbps __ __ __ __ 10 – 25 mbps 25 – 50 mbps 50 – 10 mbps > 100 mbps 88 Form 471 Block 4: Discount Calculation Worksheet JACK O’CONNELL State Superintendent of Public Instruction • Basic structure of worksheet remains the same • Schools and libraries must provide urban/rural status, student counts, and certain specific information – Total number of students – Number of students eligible for National School Lunch Program (NSLP) – New construction – Administrative entity or non-instructional facility (NIF) – Alternative discount mechanism 89 Form 471 Block 4: Discount Calculation Worksheet (continued) JACK O’CONNELL State Superintendent of Public Instruction • Schools must also include the following information if applicable (more than one may apply): – Pre-kindergarten – Head Start – Adult Education – Juvenile Justice – Educational Service Agency (ESA) – Dormitory 90 Form 471 Block 4: Discount Calculation Worksheet (continued) JACK O’CONNELL State Superintendent of Public Instruction • School districts and library systems must create one worksheet listing all eligible entities in order to calculate the shared discount for the district or system – This allows USAC to verify the calculation for • New school or library construction when the student population is not known • Eligible discount for non-instructional facilities (NIFs) such as administration buildings – This worksheet will not affect Two-in-Five status unless it is cited in Item 22 of a funding 91 request Form 471 Block 5: Discount Funding Request(s) JACK O’CONNELL State Superintendent of Public Instruction No changes 92 Form 471 – Certifications Block 6: Certifications and Signature JACK O’CONNELL State Superintendent of Public Instruction • Item 26 – Technology plan certification • Item 27 – I certify that (if applicable) I posted my Form 470 and (if applicable) made any related RFP available for at least 28 days… • Item 29 – Educational purposes certification Signature page • Checkbox for consultant as authorized person 93 JACK O’CONNELL State Superintendent of Public Instruction Revised Forms 470 and 471 Questions? 94 JACK O’CONNELL State Superintendent of Public Instruction Form 486 Receipt of Services Confirmation 95 Form 486 Review JACK O’CONNELL State Superintendent of Public Instruction • Notifies USAC that services started or are scheduled to start and invoices can be paid • Applicant makes additional program certifications • Filed AFTER receipt of FCDL –Form 486 must be filed online or postmarked, no later than • 120 days after Service Start Date OR • 120 days after FCDL date – Whichever is later 96 Late 486….potential consequences Example what happens if Form 486 is submitted “late”: JACK O’CONNELL State Superintendent of Public Instruction • 2009/2010 (Yr 12) FCDL for $100,000 dated February 1, 2010 received • Services began on July 1, 2009 • 120th day after FCDL = May 31 • Form 486 submitted & certified on June 2 • “New Service Start Date” is now Feb 2 • Therefore, District loses opportunity to receive E-rate discounts for costs incurred between 7/1/09 – 2/2/10; approximately $58K in costs that District cannot recover. 97 Form 486 Reminders JACK O’CONNELL State Superintendent of Public Instruction • DO include all applicable Funding Request Numbers (FRNs). • DO verify FRNs and SPINs against Form 471 and FCDL. • DO understand early filing rules if filing BEFORE July 1. • DO review Form 486 Notification Letter to verify all FRNs were included. • DON’T ignore Form 486 Reminder Letter. • DO maintain open communication with your service provider regarding non-recurring services. SP cannot invoice USAC until Form 486 is filed. • DON’T wait until last minute. • DO file within 120 days of service start date (July 1 for recurring services) or FCDL date, WHICHEVER IS LATER. 98 JACK O’CONNELL State Superintendent of Public Instruction Invoicing “Getting the Money” 99 Once you have submitted your Form 486, then what? JACK O’CONNELL State Superintendent of Public Instruction • Applicants receive E-rate reimbursements from Service Providers (SP) o One of two ways: Form 472 (BEAR): Applicant pays entire bill up-front & in full and gets reimbursed OR Form 474 (SPI): SP applies discounts to applicant’s bills 100 Receipt of Funds • BEAR process: JACK O’CONNELL State Superintendent of Public Instruction 1. Applicant pays entire SP bill up-front 2. Applicant submits BEAR to SP & then to USAC for reimbursement 3. BEAR Notification is sent from SLD to both Applicant and Service Provider – Check sent by USAC to Service Provider – From the date SP receives funds from USAC, SP has 20 days to reimburse Applicant *BEAR can be done online Notes Regarding CTF discounts: Only use BEAR for services you are NOT requesting CTF discounts for. Only telecommunications services & some Internet services are eligible for CTF discounts. Usage & installation costs are not eligible for CTF discounts 101 Receipt of Funds, cont • SPI Process – Allows SP to apply discounts to applicant’s bills JACK O’CONNELL State Superintendent of Public Instruction • AFTER funding commitment has been issued • AFTER SP’s forms have been submitted • SP then submits reimbursement request to USAC – Allows applicant to eventually pay only their nondiscounted portion Notes: • Telecommunications Services & Internet Access eligible for CTF Discounts must use SPI process • Work with your Accounts Payable resource(s) • Get familiar with your bills; • If applicable & available: Request consolidated billing from SPs; receiving individual bills makes it very challenging to verify discounts, identify eligible costs, etc. Request online access to your invoices 102 Service Provider SPI process Every service provider has their own process and suggested/required deadline: JACK O’CONNELL State Superintendent of Public Instruction • Each SP (each SPIN) sends GRID, Data Gathering Form, etc., paperwork to applicants via email • Applicants complete paperwork to match FRNs to bill telephone #s, circuit IDs, etc. & identify new services (ckts, lines, etc.) to be installed • Complete SP’s data gathering documentation & send back to SP as soon as possible. • E-rate is self-certifying program; you will have to certify SP documentation is correct, eligible, etc. • Once SP reviews what you submit, applicants will generally begin realizing discounts 2-3 bill cycles. • Discounts typically show up April-July bills before funding year ends. • Review your bills to ensure discounts received & accounted for. • The sooner you fill out SP’s data gathering documentation & certify information is correct, the 103 sooner applicant will realize E-rate discount credits. SPI Timeline Example JACK O’CONNELL State Superintendent of Public Instruction Every service provider has their own process and suggested/required deadline: • FCDL received July 15 • Applicant’s Bill Round = 1st of every month • Applicant receives SP’s paperwork to complete on August 1. • Applicant returns SP’s paperwork on September 1. • Errors in applicant’s SP’s paperwork; SP contacts applicant & identifies corrections to be made to SP’s paperwork • Applicant returns SP’s paperwork on November 1. • SP submits paperwork to IT for processing for discounts on November 25, too late for bill round deadline of the 20th of every month • Discounts are processed by IT on Dec 20 submission. • Discounts begin showing on Feb 1, 2009 bill. 104 What to do if you have not received expected discounts JACK O’CONNELL State Superintendent of Public Instruction Every service provider has their own process. General Roadmap: • Contact the E-rate Center for the respective SPIN. • Speak to the representative • If representative cannot assist, ask to speak to a supervisor • If the representative & the supervisor cannot assist, contact your SP assigned account representative • If all else fails, contact the SP E-rate specialist assigned to that territory for assistance on who to go to. 105 JACK O’CONNELL State Superintendent of Public Instruction INVOICE RECONCILIATION 106 Invoice Reconciliation JACK O’CONNELL State Superintendent of Public Instruction • Expectation of USAC that applicants are verifying that they are receiving the correct discounts • Will be asked to provide this during an audit • Application of Discounts frequently overlaps funding years • Work with service provider representatives in verifying discounts received • Ask for reports and compare to your invoices 107 Invoice Reconciliation Tracking Eligible Charges and Payments JACK O’CONNELL State Superintendent of Public Instruction • Tally costs by Billed Telephone Number (BTN) by month for both E-Rate eligible and ineligible costs • Understand how CTF discounts are applied to invoices by carrier – E-Rate is applied to eligible costs prior to the application of the CTF discount • Track payments made of applicant share of costs • Calculate the estimated E-rate amount for the year and compare to disbursements on DRT and Quarterly Disbursement Reports 108 JACK O’CONNELL State Superintendent of Public Instruction 109 JACK O’CONNELL State Superintendent of Public Instruction 110 Sample Reconciliation • You have been funded for: JACK O’CONNELL State Superintendent of Public Instruction – FRN 1111xx, Telecommunications Services for Service Provider ABC Telecom for a maximum of $32,500. – FRN 1112xx, Internet Access for Service Provider 123Internet for a maximum of $10,345. – FRN 1113xx, Telecommunications Services for Service Provider Z Long Distance for a maximum of $567. – Discount level is 90% 111 Sample reconciliation Invoice from ABC Telecom JACK O’CONNELL State Superintendent of Public Instruction Acct # Invoice Date Total Charges Long Distance Internet Access FRN 113xx FRN 112xx Ineligible Total Eligible for FRN 111xx (530) 555-5555 521 9 7/28/2009 129.22 6.42 35.00 19.50 68.30 (530) 555-5555 521 9 8/28/2009 129.06 6.42 35.00 19.50 68.14 (530) 555-5555 521 9 9/28/2009 133.91 6.17 35.00 19.50 73.24 (530) 555-5555 521 9 10/28/2009 141.26 13.12 35.00 19.50 73.64 (530) 555-5555 521 9 11/28/2009 129.58 7.00 35.00 19.50 68.08 (530) 555-5555 521 9 12/28/2009 136.80 14.11 35.00 19.50 68.19 (530) 555-5555 521 9 1/28/2010 129.24 6.25 35.00 19.50 68.49 (530) 555-5555 521 9 2/28/2010 129.03 6.22 35.00 19.50 68.31 (530) 555-5555 521 9 3/28/2010 129.78 6.97 35.00 19.50 68.31 (530) 555-5555 521 9 4/28/2010 183.08 6.27 35.00 69.49 72.32 (530) 555-5555 521 9 5/28/2010 145.59 18.45 35.00 20.00 72.14 (530) 555-5555 521 9 6/28/2010 180.04 6.63 35.00 69.99 68.42 1696.59 104.03 420.00 334.98 837.58 (530) 555-5555 521 9 SUMMARY Multiple service providers can be included on one invoice. • Break these out so that you invoice the correct $$ to the correct service provider. 112 Invoice Reconciliation Challenges JACK O’CONNELL State Superintendent of Public Instruction • Receipt of Discounts overlaps funding years • Discounts received many months and sometimes years after FCDL • Disputed charges and late payments may affect the application of discounts • CTF adjustments 113 If you missed the deadline? Invoice Deadline Extension request JACK O’CONNELL State Superintendent of Public Instruction • Must be submitted to USAC. • There is no official “form”, but there is a format & criteria for the request(s) • Typically the request is submitted by applicant to USAC. • Format for request @ http://www.universalservice.org/sl/applicants/step11 /invoice-deadlines-extension-requests.aspx Notes: → You may have to do FRN split(s), SPIN change(s), or both, to realize E-rate discounts for eligible services. → If you do request FRN split, you must issue Form 486 for new FRN(s). 114 Invoicing Best Practices JACK O’CONNELL State Superintendent of Public Instruction • DO submit Form 486 in a timely manner. • DO ensure all SP forms are completed and returned to SP quickly to realize E-rate discounts sooner. • DO verify discounts posted on your invoices. • DO submit BEAR form in ADVANCE of Invoice Deadline. • DO document your BEAR form calculations and retain for audit purposes. • DO file Invoice Deadline Extension Request if your FRN does not show any or incomplete disbursement of funding by Invoice Deadline. • DO work with your Accounts Payable • DON’T assume posted E-rate discounts are correct. • DON’T include ineligible costs in your BEAR form amount. 115 Invoicing Reminders JACK O’CONNELL State Superintendent of Public Instruction • NOTES: → Invoicing cannot occur until Form 486 is filed and certified. → Discounts cannot be realized until SP forms are completed & certified. 116 JACK O’CONNELL State Superintendent of Public Instruction Childrens Internet Protection Act (CIPA) Protecting Children in the 21st Century Act 117 CIPA Compliance • Public Notice & Public Hearing • Technology Protection Measure (Filter) • Internet Safety Policy (required elements) JACK O’CONNELL State Superintendent of Public Instruction – Access by minors to inappropriate matter on the Internet – Safety & security of minors when using electronic mail, chat rooms, and other forms of direct electronic communications – Unauthorized access including "hacking“ & other unlawful activities by minors online – Unauthorized disclosure, use, & dissemination of personal information regarding minors – Measures designed to restrict minors' access to materials harmful to minors • CIPA affects every funding year from FY2001 going forward, so you must maintain proof of CIPA 118 compliance on an ongoing basis Protecting Children in the 21st Century Act JACK O’CONNELL State Superintendent of Public Instruction • Enacted in Fall 2008 to address Internet Safety in schools, specifically cyberbullying awareness and response • Before USAC can enforce new requirements the following must occur: – FCC will issue a Notice of Proposed Rulemaking (NPRM) seeking comment on the Act – FCC will draft new rules and the new rules must be voted by the FCC Commissioners – FCC will release guidance to USAC in an Order 119 JACK O’CONNELL State Superintendent of Public Instruction Audits and Other Reviews 120 How To Prepare for an Audit or ANY Type of Review JACK O’CONNELL State Superintendent of Public Instruction • Follow All E-rate Rules • Document, Document, Document! • You can’t prove that you abided by the rules if you don’t document your processes • Plan ahead for an audit or review by documenting every step of the process • Create E-Rate binders for EACH funding year • Retain – Retain – Retain – Lessen your pain!! Retain ALL E-rate related documents • Contact your service providers • USAC Compliance Documentation Checklist for audits • http://www.usac.org/_res/documents/sl/pdf/CompDoc Checklist.pdf 121 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 – All USAC correspondence, including Quarterly Disbursement Reports • Make sure all departments understand documentation retention requirements for E-Rate • Align Board policies with E-rate requirements • Per 5th Report and Order: if applicant can’t prove compliance with rules through documentation, they must assume that you didn’t follow the rules • No documentation = Recovery of Funds (Applicant may have to pay back the SLD for E-rate discounts they already received) 122 Payment Quality Assurance (PQA) JACK O’CONNELL State Superintendent of Public Instruction • Started in August of 2010 • Randomly selected USAC invoices are now being audited on a monthly basis – CHALLENGE: USAC invoice SLC # may not directly reference any service providers invoices the applicant has received • Since USAC invoice selected may be a SPI (Service Provider Invoice) you may need to contact your service provider for assistance in securing information requested • MUCH less invasive and painful than previous processes 123 Beneficiary and Contributor Audit Program (BCAP) JACK O’CONNELL State Superintendent of Public Instruction • Audits have been revamped – USAC listened! • No audits during last 2 weeks of window. Auditors more flexible in accommodating applicants’ schedules • USAC Engagement lead – more visibility and oversight of audit firms • Auditors will spend more time on planning and review of materials and less time on site 124 Other Levels of Scrutiny • H.A.T.S Visits JACK O’CONNELL State Superintendent of Public Instruction •Helping Applicants To Succeed • Primarily for applicants that have had funding issues in the past • Welcome the help…do not be afraid • Special Compliance Reviews • Typically during PIA • Item 25 Selective Review • Cost Effectiveness Review • CIPA Compliance and Competitive Bidding Selective Reviews 125 Reminders JACK O’CONNELL State Superintendent of Public Instruction •Create YOUR OWN timeline of E-Rate deadlines –Opening and closing of the Form 471 –Form 486 deadline based on FCDL •Be aware of timelines and adhere to them •Share this information with others at your site (keep administration informed) •Have a backup person (succession planning) •Keep E-Rate files organized •Print and retain copies of everything –USAC Link to Document Retention: http://www.usac.org/sl/about/audits/e-rate-binder.aspx. •Additional 2009 USAC Training Audit Information: http://www.usac.org/sl/about/training-presentations/trainingpresentations-archive/training-2009/fall/materials.aspx •Get on the CDE E-rate list Serv Today !! http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp 126 Contact Information JACK O’CONNELL State Superintendent of Public Instruction • State Library: Rushton Brandis, (916) 653-5471, [email protected] • CDE/E-rate: John Vardanega, (916) 323-2241, [email protected] • CDE/EETT: Tech Plans: Doris Stephen, 916-324-9943 [email protected] • K-12 HSN/Butte COE: Russ Selken, 530-532-5678 [email protected] 127 Overview of E-Rate Process Step Description Determine Needs Review new E-rate eligible services, determine budget, calculate E-rate discounts, update Technology Plan Go out to Bid/ E-Rate Form 470 Prepare and post RFP/RFB, post E-Rate Form 470, Conduct job walks, answer vendor questions Select Services Estimate Costs File E-Rate Application Form 471 Review proposals, develop decision matrix, select services and sign contracts Timing Sept – Dec Sept - Dec Sept - Dec Review existing recurring services, estimate eligible costs, and determine Sept - Dec growth Complete application and file with USAC to request E-rate discounts on eligible services. Prepare Item 21 Attachments to support funding request January Feb – Dec Program Integrity Review (PIA) Item 25 Selective Review Respond to USAC’s questions regarding application for standard PIA review. If necessary, provide extensive documentation for Selective Review. Funding Decision/ E-Rate Form 486 Upon funding approval, file Form 486 to inform USAC of intention to use funds July-Jun Service Provider DGF Forms File required DGF forms with service providers to start discounts (local phone and data services) Jan-June Analyze actual costs and file BEAR form to release discounts as refund check (long distance and cellular services) August-Oct E-Rate BEAR Form 472 File Service Certification Form if requested by USAC (internal connections) If selected for an audit or site visit, collect and prepare documentation and answer questions If necessary, file appeals regarding denied funding requests with USAC and/or the FCC Varies Service Certification Form E-Rate Audit E-Rate Site Visit USAC and FCC Appeals Varies Varies 128