Transcript WHY ME? THE E-RATE APPLICATION PROCESS

NAVIGATING THE E-RATE
APPLICATION PROCESS: WHY
ME?
Presented by:
Mary Mehsikomer
Network Coordinator
NW-LINKS /Region 1
November 2009
WARNING
• Presentation not to be undertaken by the
those allergic to Power Point
• Contains use of at least 10,000 acronyms
• Liberally abuses cute clip art in a futile
attempt to make content interesting
• High octane caffeine is recommended
throughout the presentation
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WHAT THE HECK IS E-RATE?
• Funded by Universal Service Fund through
fees on phone bills
• Provides discounts of 20-90 percent on
telecommunications services
• For schools and libraries
• Created by Telecommunications Act of 1996
• 12 years old in 2009
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E-RATE: WHY NOT? YOU CAN DO
IT!
• Eligibility
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Schools
Definition of Educational Purpose
Libraries
Eligible Products and Services
• The Application
• Audits and Documentation
• SLD Website Features
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ELIGIBILITY
• Schools
– Statutory definition of elementary or secondary
school found in the No Child Left Behind Act of
2001
– Non-profit institutional day or residential school,
including a public charter school, that provides
elementary or secondary education, as
determined under state law
– Not operating as a for-profit business
– No endowment exceeding $50 million
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ELIGIBILTY
• Schools (continued)
– Must be providing elementary or secondary
education as defined in state law
– Minnesota allows juvenile justice and
prekindergarten eligibility
– Head starts eligible as prekindergarten
– All head start students 100% free & reduced
– No child under three years is ever eligible and
must be left behind (at least as far as E-rate is
concerned)
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ELIGIBILITY
• Public Libraries
– Must be eligible for funding under Library
Services and Technology Act
– Must have budget separate from any other
entity
– Must be operating as a nonprofit
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EDUCATIONAL PURPOSE
– Activities that occur on school property are
presumed to be integral, immediate, and
proximate to the education of students or the
provision of library services to library patrons and
therefore qualify as educational purposes
– Customary work activities of employees of a
school or library are presumed to fall under the
definition of education purposes
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MORE ON ELIGIBILITY
• Noninstructional Facilities (NIFs)
• Eligible for Priority 1 Services
(telecommunications and Internet access)
• Sometimes for Priority 2 (Internal
connections)
• Meet definition of educational purpose
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ELIGIBILITY
• Some NIF(TY) Examples
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Administrative buildings
School bus barns and garages
Cafeteria offices
Facilities for athletic activities
Technology centers
Bookmobile garages
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ELIGIBILITY
• Products and Services
– ALWAYS refer to the Eligible Services List
– Make sure you use the correct year
• Service Categories
– Priority 1
• Telecommunications
• Internet Access
– Priority 2
• Internal Connections
• Basic Maintenance on Internal Connections
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ELIGIBILITY
• Priority 1
– Telecommunications Services
• Basic telephone service — wireline or wireless
phone service (local, cellular/PCS, and/or long
distance)
• Voice mail
• Transmission services (T-1, DSL)
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ELIGIBILITY
• Priority 1 (continued)
– Internet Access
• Basic conduit access to the Internet
– Broadband over Power Lines (BPL)
– Cable Modem
– Digital Subscriber Line (DSL)
– Satellite
– T-x, DS-x, OC-x
• Priority 2
– Internal Connections (switches, hubs, routers, wiring)
– Basic Maintenance on Internal Connections
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ELIGIBILITY
• Priority 2 (continued)
– Usually only funded at the highest level of
discount (most economically disadvantaged)
– Entity may only receive funding twice in five years
– Check guidance and tip sheets for conditions and
anomalies
– SLD diagrams for lines of demarcation for
eligibility
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Internal Connections Ex. 1
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ELIGIBILITY
• Organization of Eligible Services List (ESL)
• Five sections
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Telecommunications Services
Internet Access
Internal Connections
Basic Maintenance of Internal Connections
Miscellaneous
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ELIGIBILITY
• Organization of Eligible Services List
(continued)
 Three special areas with additional
information
– Special Eligibility Conditions
– Glossary
– Index
• READ CAREFULLY
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QUESTIONS
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Any questions so far?
Are we still awake?
Has anyone expired from sheer despair?
Has anyone started looking on Craig’s List for a
new job?
• Now we’re ready to move on to THE
APPLICATION PROCESS
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THE APPLICATION PROCESS
• WE CAN DO IT!!!!
• WE ARE NOT AFRAID!
• WE WILL NOT BE DEFEATED BY FORMS AND
PROCEDURES!
• WE ARE MINNESOTANS!
• WE’RE TOUGH!
• WE CAN MAKE GAS OUT OF
CORN!
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THE APPLICATION PROCESS – THE
TWELVE, NO SEVEN, STEPS
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Write a technology plan
File Form 470
File Form 471
Receive Funding Commitment Decision Letter
Obtain technology plan approval
File Form 486
File Form 472 (BEAR)
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THE TIMELINE
• Funding Year – July 1 through June 30
• Competitive Bidding Process – Form 470
Anytime after July 1 – 28 days before end of 471 window
• Services Selected – Form 471
November – February (check website for exact dates)
(Opens 60 days after release of Eligible Services List from FCC)
• Receipt of Services Confirmation – Form 486
120 days after USAC response from 471 letter or
120 days after the service start date
• Billing Entity Reimbursement Form – Form 472 or Form 474
120 days after date of the Form 486 Notification Letter or
120 days after the last date to receive service
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STEP ONE: THE TECHNOLOGY PLAN
• Allow ample time for pacing the office prior to
writing technology plan
• Develop a technology plan
• Must be WRITTEN prior to filing Form 470 (the
first form to be filed)
• Make sure plan has a date of creation on it
that predates the Form 470
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STEP ONE: THE TECHNOLOGY PLAN
• Make sure the technology plan includes all
services to be requested for E-rate discount
• Technology plan must cover the full program
year
• Plan cannot be more than three years in
length
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STEP ONE: THE TECHNOLOGY PLAN
Technology Plans
– Not required for basic telephone service
– Must be approved by a certified approver
before the Form 486 is filed or discounted
services start, whichever is earlier (MDE)
– Must cover five specific elements (needs
assessment, goals and strategies, budget,
staff development, and evaluation)
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STEP TWO: FORM 470
• Form 470 – Services Requested
• Filed by applicants to define desired services
and open the competitive bidding process
• Choose the correct category of service
(Telecommunications Services, Internet
Access, Internal Connections, or Basic
Maintenance of Internal Connections) for each
set of services
• Observe appropriate roles
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STEP TWO: FORM 470
• Filing Form 470 opens a competitive
bidding process
• Applicants are responsible for ensuring
an open and fair process and selecting
the most cost-effective provider of the
desired services
• Be clear and complete
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STEP TWO: FORM 470
• Posted on the USAC website for at least 28
days before selection of service provider
and/or signing a contract
• Form 470 request must be based on the
technology plan
• Applicants may issue a Request For Proposal
(RFP), which must also be available for at least
28 days before making a vendor selection
• Receipt Notification Letter (RNL)
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STEP TWO: FORM 470
• Multi-year or renewable agreements are allowed
if stated on Form 470
• Tariff or month-to-month services REQUIRE
posting Form 470 annually
• Service providers are prohibited from completing
and signing Form 470 or for being involved in the
bidding evaluation process
• Choose the correct category of service
(Telecommunications Services, Internet Access,
Internal Connections, or Basic Maintenance of
Internal Connections) for each set of services
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BIDDING
• Applicants must conduct a fair and open
competitive bidding process
– All bidders are treated the same
– All bidders have equal access to information
– All bidders know what is required of them
– All bidders know any reasons for
disqualification
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BIDDING (continued)
• Bid Evaluation
– Applicants must choose the most costeffective offering with price the primary
factor
– Can include other important factors for
evaluating bids but these must weigh less
than price
– Set up a chart, evaluate the bids and keep
your documentation of the process
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BIDDING (continued)
• What if I receive only one or no bids?
– Once you have waited 28 days, you can
solicit more bids
– If you receive one bid and select this bid,
document this fact by sending yourself an
email indicating this was the only bid
received
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QUESTIONS?
• Summary so far…
• Write technology plan
• Ensure technology plan has a date of creation
prior to Form 470 submission
• Complete Form 470 to define services sought
• Use a fair and competitive bidding process
• Keep all documentation
• Document receipt of no bids or one bid
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STEP THREE: FORM 471
• Form 471 – Products and Services
Ordered
• Actual E-rate application
• Provides USAC with all information
needed to make decisions on funding
• Filed EACH year WITHIN the filing window
• No vacation from Form 471
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STEP THREE: FORM 471
• Contains specifics on services ordered,
quantities, from whom, at what price
• Calculates discount rate and lists entities
receiving services
• Certifies compliance with rules and verifies
that applicant has the resources to make
effective use of the services
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STEP THREE: FORM 471
• FCC Registration Numbers
– Recommend one for each billed entity
– http://www.fcc.gov – CASE link
– Need federal tax ID number
• NCES Numbers
– Needed for each site
– http://www.nces.ed.gov
• FSCS Code – Libraries
– http://www.nces.ed.gov
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STEP THREE: FORM 471
• Calculating Discounts – The Matrix
FREE & REDUCED
DISCOUNT –
URBAN
DISCOUNT –
RURAL
Less than 1%
20%
25%
1 to 19%
40%
50%
20% to 34%
50%
60%
35% to 49%
60%
70%
50% to 74%
80%
90%
75% to 100%
90%
90%
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STEP THREE: FORM 471
• Discount Calculations
• Individual schools use percentage of students eligible
for NSLP in the school
• Library outlets/branches use the percentage of
students eligible for NSLP in the school district
• Shared Discounts
– School districts use the weighted average of the
discounts of individual schools in the school district
– Library systems use the simple average discount of the
school district in which they are located
– Consortia use the simple average of the consortium
members
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STEP THREE: FORM 471
• Block 5: Funding Request Number (FRN)
must include the following:
– Contract information (signed)
– Service start and end dates
– Service Provider Identification Number
(SPIN)
– Eligible and ineligible amounts for each FRN
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STEP THREE: FORM 471
• Item 21 Attachment
– Narrative overview or description of the products
and services
– Line item detail and cost associated with eligible
and ineligible products and services requested
– Additional details - equipment location, make,
model and bandwidth for all products or services
to support the request
– Service providers can assist applicants to complete
– Receipt Acknowledgement Letter (RAL)
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STEP FOUR: THE PIA
• PIA is Program Integrity Assurance
• They work in New Jersey
• Checking for
– Eligible entities
– Eligible services
– Competitive bidding process and contracts
– Cost effectiveness
– Correct discount calculations
– Ability to pay for non-discount share
– Proper posting of Form 470
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STEP FIVE: THE FUNDING COMMITMENT
DECISION LETTER
• OH HAPPY DAY – NOW YOU CAN GO TO DISNEY WORLD
• Much anticipated response from SLD to Form 471
• Possible Funding status by Funding Request Number (FRN):
– Funded (includes modifications)
– Not funded
– As yet unfunded (applicant FCDL only)
– Canceled
– Under Review (part of application still under PIA review)
• Funds approved for specific services from identified service
providers at approved discount rate
• Check this to make sure all info is ACCURATE
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STEP 6: FORM 486
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Form 486 – Services Confirmed
Congratulations
You’ve made it this far
Don’t mess this part up
Acknowledgement of discount approval and
start of services
• DON’T FORGET TO FILE IT OR YOU WILL WISH
YOU HAD NEVER BEEN BORN
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STEP SIX: FORM 486
• Notifies USAC that invoices can be paid
• Provides the name(s) of the USACcertified Technology Plan Approver(s) that
approved the appropriate technology plans
• Certifies compliance status under the
Children's Internet Protection Act (CIPA)
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STEP SIX: FORM 486
• Filed online or postmarked no later than
– 120 days after the Service Start Date or 120
days after the date of the FCDL, whichever
is later or
– The deadline specified in the “Urgent
Reminder: Your Form 486 May be Late”
letter
• Service Start Date
– Cannot be before July 1 of the funding year
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STEP SEVEN: FORM 472 OR DIRECT
DISCOUNTS
• Work with service provider
• Form 472 – Billed Entity Applied Reimbursement
• Used when entity pays bills in full and claims
discount from SLD
• Some providers will apply discounts directly to bills
(Applicant should make sure discounts are correct)
• Make sure you know which one you are doing
• Discount or BEAR method must be consistent for
program year
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STEP SEVEN: FORM 472 OR DIRECT
DISCOUNTS
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Don’t neglect the BEARS
Do Form 472 (BEARS) quarterly
Online
Service provider must certify
Filed online or postmarked no later than
– 120 days after the last date to receive service or
– 120 days after the date of the Form 486
Notification Letter, whichever is later
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DOCUMENTATION
• Maintain copies of EVERYTHING
• See SLD recommended list
• Retain at least five years after the last date of
service for that program year
• Try to be organized
• Set up a system
• Make sure equipment is tagged and tracked
• If selected for an audit DON’T PANIC
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APPEALS
• Decisions of the SLD can be appealed to the
SLD or to the FCC
• Appeal to SLD first
• Can be filed electronically or on paper
• Must be received or postmarked within 60
days of the SLD decision
• Requests for waivers of rules must be filed
with the FCC
• When in doubt appeal it
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COMADS AND RIDFS
• Commitment Adjustment (COMAD) / Recovery of
Improperly Disbursed Funds (RIDF) occur when USAC
has to recover funds after the fact
• Result of a COMAD/RIDF is a reduction in
commitment and potentially a cash recovery
– If you do not pay your debt on time, the FCC Red Light
Rule will take effect, meaning you risk losing all of
your funding
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IT’S NOT REALLY SO BAD, IS IT?
• Questions???
• Resources
– Universal Service Administrative Company (USAC)
http://www.universalservice.org/sl
– Your telecommunications region coordinator
– USAC/SLD Client Service Bureau
• 888-203-8100
– Your Higher Power of choice
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