Transcript Welcome ToFall 2013 E-Rate Training

Welcome
To
Fall 2013
E-Rate Training
Agenda
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Introduction to E-Rate
Understanding Eligible Services
E-Rate Update
Break
Notice of Proposed Rulemaking (NPRM)
New FCC Form 470 & 471
New FCC Form 486 & 472
Avoid the Dirty Dozen Mistakes
– Lunch on your own
• Form 470 Step-by-Step
**Thanks to USAC & SLD staff for providing training materials and program
information.
E-Rate Program
Introduction to E-Rate
Fall 2013 Applicant Trainings
General E-Rate Information
E-Rate Background
• Federal Communications Commission (FCC), an
independent U.S. government agency, established
and oversees the E-Rate Program.
• Universal Service Administrative Company (USAC), a
not-for-profit, administers the E-Rate Program along
with three other programs.
• Schools and Libraries Program (SL) is the part of
USAC with responsibility for E-Rate.
General E-Rate Information
E-Rate Rules
• Congress directed the FCC to establish the E-Rate
Program in 1996.
• The FCC sets rules and policies through orders.
• USAC develops procedures for specific actions, such
as how to process applications.
General E-Rate Information
E-Rate Timeline
• Commitments for E-Rate are made by funding
year (FY), which runs from July 1 through the
following June 30.
• USAC refers to the funding year as the year in
which most services will begin, e.g., FY2013 is
July 1, 2013 to June 30, 2014.
General E-Rate Information
E-Rate Budget
• The FCC capped E-Rate funding at $2.25 billion per
year, until 2010 when the FCC began to adjust the
cap annually for inflation
• Once a year, the FCC is required to roll over all funds
that are collected and are unused from prior funding
years to the next full funding year
General E-Rate Information
E-Rate Eligibility
• Who is eligible for E-Rate funding?
– Elementary and Secondary schools and
school districts
• Non-traditional facilities
• Non-Instructional facilities
– Libraries and library systems
– Consortia – groups of eligible entities that
band together to aggregate demand and
negotiate lower prices
General E-Rate Information
E-Rate Discounts
• How large are the discounts on eligible products and
services?
– Discounts are 20-90 percent of eligible costs.
– Discount level for a school or library depends on:
• Percentage of students who are eligible for National
School Lunch Program (NSLP) in
– (for a library) the school district in which the
library is located.
• Urban or rural location of the school or library.
General E-Rate Information
Discount Matrix
INCOME
URBAN LOCATION
Discount
RURAL LOCATION
Discount
...and you’re in an URBAN area,
your discount will be...
...and you’re in a RURAL area,
your discount will be...
Less than 1%
20%
25%
1% to 19%
40%
50%
20% to 34%
50%
60%
35% to 49%
60%
70%
50% to 74%
80%
80%
75% to 100%
90%
90%
% of students eligible for NSLP
If the % eligible is...
General E-Rate Information
E-Rate Categories of Service
• Priority 1 (P1): funded first
– Telecommunications Services
– Internet Access
– Telecommunications
• Priority 2 (P2): funded second and starts with
neediest applicants
– Internal Connections
– Basic Maintenance of Internal Connections
General E-Rate Information
E-Rate Forms
• How do I file a program form?
– Three options:
• File online, certify on paper
• File online, certify online
• File on paper, certify on paper
– USAC encourages you to file online, because
online filing speeds processing and reduces errors.
General E-Rate Information
E-Rate Letters
Each time applicants file a program form, USAC sends you a
notification or acknowledgement letter.
• Letters are color-coded by funding year
– 2013
– 2014
– 2015
Pink
Blue
Canary
• Note: When storing documents, USAC encourages you to
separate your program forms and letters by funding year to
better organize them.
Introduction to E-Rate
Technology Planning
Technology Planning
Technology Plans (P2 Services Only)
• A technology plan must contain the following 4
elements:
– Goals and strategies for using technology to improve
education or library services
– Needs assessment
– Staff training
– Evaluation plan
• Technology plans must be approved by a USAC-certified
Technology Plan Approver (TPA). In this case:
– State Library of Ohio
Introduction to E-Rate
Requesting Services
(FCC Form 470)
Requesting Services
FCC Form 470 Purpose
• Opens your competitive bidding process.
• Notifies potential bidders of the types and quantities of
services that you need.
• Must be posted on the USAC website at least 28 days
before filing the FCC Form 471.
Note: Request for Proposals (RFPs) or other supplemental
documents may be issued in addition to describe specific needs
and circumstances. If you issue an RFP (or provide supplemental
documents), the RFP, supplemental documents, and FCC Form
470 must be available during the same 28-day period.
Requesting Services
Response Letter
• FCC Form 470 Receipt Notification Letter (RNL): a
letter issued by USAC to the applicant that
summarizes the information provided in the FCC
Form 470.
• If you notice mistakes, use the RNL to make
allowable corrections immediately.
Introduction to E-Rate
Competitive Bidding
Competitive Bidding
Competitive Bidding Requirements
• No one other than the applicant or an authorized
representative of the applicant should prepare, sign or
submit the FCC Form 470 or certification.
• The FCC Form 470 must describe the desired products
and services with sufficient detail to enable interested
parties to submit bid responses.
• All potential bidders must have access to your FCC Form
470, RFP (or other supplemental documents describing
the procurement, if you have them).
• You must evaluate the incoming bids fairly and equally.
Competitive Bidding
Sample Matrix
• The price of the eligible products and services must be the
most heavily weighted factor in your evaluation of bids
Factor
Points Available Vendor 1
Vendor 2 Vendor 3
Price of the ELIGIBLE
products and services
30
15
30
25
Prior experience w/ vendor
20
20
0
20
Prices for ineligible services,
products and fees
25
20
15
25
Flexible Invoicing: 472 or 474
15
0
15
15
Local or in-state vendor
10
10
8
7
Total
100
65
68
92
Competitive Bidding
Competitive Bidding Process
• After the 28-day waiting period closes, on the 29th
day, you can:
1.
2.
3.
4.
Evaluate bids received
Choose your service provider(s)
Sign a contract (if applicable)
Submit an FCC Form 471.
*Be sure to check for the Allowable Contract Date (ACD)
shown on the Form 470
Introduction to E-Rate
Ordering Services
(FCC Form 471)
Ordering Services
FCC Form 471 Purpose
• Identifies the service providers and eligible services
you have chosen on funding requests.
• Identifies the eligible schools and libraries that will
receive services.
• Calculates how much support you seek for the
funding year using your discount calculation
information.
Ordering Services
Acronyms and Terms
• Funding Request Number (FRN): The identification
number assigned to each FCC Form 471 Block 5 funding
request.
• Service Provider Identification Number (SPIN): The
identification number assigned by USAC to a service
provider.
• Item 21 Attachment (Item 21): A description of services
and prices associated with each funding request.
– Item 21 attachment(s) are part of the FCC Form 471
and are a window filing requirement.
Ordering Services
Response Letter
• Receipt Acknowledgment Letter (RAL): a letter issued
by USAC to the applicant and the service provider that
summarizes the information provided in the FCC Form
471, which you should carefully review.
• If you notice mistakes, use the RAL to make allowable
corrections immediately.
Introduction to E-Rate
Application Review and
Funding Commitments
Application
Review/Commitments
PIA and USAC Reviews, FCC Form(s) 471
• Program Integrity Assurance (PIA) is the USAC group
that reviews and makes funding decisions on
program applications:
– Verifies eligibility of the schools and libraries entities,
entity discount levels, and the services requested.
– Gives you an opportunity to make allowable corrections
to your form.
– In some cases, asks for additional verification of your
compliance with program rules.
Application
Review/Commitments
Decision Letter
• Funding Commitment Decision Letter (FCDL):
Following application review, USAC issues this letter
to both the applicant and the service provider. It
contains decisions on approved or denied funding
requests and next steps.
Introduction to E-Rate
Begin Receiving
Services (FCC Form 486)
Begin Receiving Services
FCC Form 486 Purpose
• Notifies USAC that your eligible services have started or
been delivered and invoices for those services can be
processed and paid.
• Provides the name of the TPA that approved your
technology plan (if applicable).
• Reports your status of compliance with Children’s Internet
Protection Act (CIPA)—a law with specific requirements on
Internet safety policies.
Begin Receiving Services
Response Letter
• FCC Form 486 Notification Letter: a letter issued
by USAC to the applicant and service provider
after an FCC Form 486 has been processed.
Introduction to E-Rate
Invoicing USAC
(FCC Forms 472, 474)
Invoicing USAC
Requirements Before Invoicing USAC
• Applicants and service providers receive an FCDL
from USAC for the services being invoiced.
• Applicants must file an FCC Form 486 and receive an
FCC 486 Notification Letter.
• Service providers must file an Service Provider
Annual Certification (SPAC) FCC Form 473 each
funding year.
Invoicing USAC
Two Methods of Invoicing
1) Billed Entity Applicant Reimbursement (BEAR) FCC
Form 472: filed by applicant after services have been
paid in full
OR
2) Service Provider Invoice (SPI) FCC Form 474: filed by
service provider after the applicant has been billed for
the non-discount portion of eligible services.
Note: Applicants can choose their method of invoicing;
service providers cannot force applicants to use a particular
method.
Invoicing USAC
Response Letters
• BEAR Notification Letter: a letter issued by USAC to
the applicant with a copy to the service provider after a
BEAR is processed.
• Quarterly Disbursement Report: a letter issued to the
applicant detailing all invoicing activity (BEARs and
SPIs) during the previous quarter.
Introduction to E-Rate
Deadlines
Deadlines
Application Deadlines
• Tech Plan - drafted before the competitive bidding
process and approved on or before the date when you
begin receiving services or at the time you file the FCC
Form 486, whichever date is earlier.
• FCC Form 470 - Posted at least 28 days before the filing
of the FCC Form 471, keeping in mind the FCC Form 471
application filing window opening and closing dates.
• FCC Form 471 and Item 21 Attachment - Received or
postmarked no later than 11:59 PM ET on the day of the
close of the FCC Form 471 application filing window
(exact window dates will be posted on our website).
Deadlines
More Deadlines
• FCC Form 486 - Received or postmarked no later than
120 days after the date of the FCDL or the service start
date, whichever is later.
• FCC Form 472/ FCC Form 474 - Received or postmarked
no later than 120 days after the date of the FCC Form 486
Notification Letter or the last date that the applicant can
receive service from the provider in the funding year at
issue, whichever is later.
• Appeals - Received or postmarked no later than 60 days
after the date of USAC's decision letter.
E-Rate Program
Understanding Eligible Services
Overview
Overview
•
•
•
•
Priority One (P1)
Priority Two (P2)
Miscellaneous
Interconnected Voice over Internet Protocol (VoIP)
Priority One
Telecommunications Services
• Digital Transmission Services
– Digital Subscriber Line (DSL)
– Primary Rate Interface (PRI)
– T-1, T-3
– Satellite service
Priority One
Not Eligible as Telecom Services
• Broadcast “Blast” messaging
• Monitoring services for 911, E911 or alarm telephone
lines
• Services to ineligible locations
• End-user devices
– Cell phones, tablet devices, netbooks and computers
Priority One
Internet Access (IA)
• Support for IA includes charges to access the Internet
and costs for the conduit to the Internet
• Other eligible Internet Access services include:
– Email service
– Wireless Internet access
– Interconnected VoIP
– Web hosting
Priority One
Not Eligible as Internet Access
•
•
•
•
•
Costs for Internet content
– Subscription services such as monthly charges for
on-line magazine subscriptions
Internet2 membership dues
Website creation fees
Web-based curriculum software
Software, services or systems used to create or edit
Internet content
Priority Two
Internal Connections
•
Support for equipment and cabling onsite that
transport info to classrooms or public rooms of a
library
• Subject to the Two-in-Five Rule
– Entities can only receive funding two out of every
five years
Priority Two
Not Eligible as Internal Connections
• End-user components
– Computers, laptops, tablets, speakers, white boards
• Most software
– Anti-virus, anti-spam, curriculum or productivity
software
• Spare parts
• Intercom or public address (PA) systems
Priority Two
Basic Maintenance of Internal Connections (BMIC)
•
Support for basic maintenance of eligible internal
connections
• Such as:
– Repair and upkeep of hardware
– Wire and cable maintenance
– Basic tech support
– Configuration changes
Priority Two
Basic Maintenance of Internal Connections
• Agreements or contracts must state the eligible
components covered, make, model, and location
• Services must be delivered between the July 1 to June
30 Funding Year
• Two-in-Five Rule does not apply to BMIC
Priority Two
Basic Maintenance of Internal Connections
• Standard manufacturer warranties of no more than three years
remain eligible
– If there is a cost associated with the warranty, then the
warranty is not eligible
• Support for BMIC is limited to actual work performed under the
contract
• Exceptions that will not require demonstration that work was
performed are:
– Software upgrades and patches
– Bug fixes and security patches and
– Online and telephone based technical support
Miscellaneous
Miscellaneous Charges
•
Miscellaneous charges can apply to all service categories
and are funded in the same category of the service they
are supporting
• Training is eligible when included as part of the contract
and performed coincidently with the installation of the
new service/product or in a reasonable time thereafter
– Training for end-users or professional development is
not eligible
Miscellaneous
Miscellaneous Charges
•
Other charges that are not eligible include but are
not limited to:
– Universal service administration fee
– Interest or finance charges
– Late payment fees and
– Termination fees
Interconnected VoIP
• Interconnected VoIP service is eligible as a Priority
One service
• Interconnected VoIP is defined as a service that
– Enables real time, two-way voice communications
– Requires a broadband connection from the user’s
location
– Requires Internet protocol-compatible customer
premises equipment (CPE)
– Permits users generally to receive calls that originate on
the public switched telephone network and to terminate
calls to the public switched telephone network
Interconnected VoIP
• Leased VoIP system or PBX equipment are not
eligible for Priority One funding
• VoIP or PBX equipment are eligible as Internal
Connections
• A VoIP gateway may be leased with an eligible Priority
One VoIP Service
• A VoIP gateway is considered a single basic
terminating device
Interconnected VoIP
• Example of a common configuration containing a
leased gateway
E-Rate Update
E-Rate Update
E-Rate Update
FY2013 at a Glance
• FY2013 demand for funds
• Priority 1 - $2.7 bil
• Priority 2 - $2.2 bil
• Application review
• Processing positive funding for P1 only
• P2 funding still to be determined
• Target 90% of all FY2013 applications completed by
12/31/2013
E-Rate Update
FY2013 at a Glance, cont.
• FCC issues NPRM
• New FCC Form 474 (SPI) online
• New FCC Form 472 (BEAR) online
7/23/2013
8/7/2013
8/28/2013
E-Rate Update
E-Rate 2.0 NPRM:
Preview of Proposed
Changes
E-Rate 2.0 NPRM General
• This presentation tries to outline the major
issues/topics being considered.
• None of the proposals/topics are final.
 FCC is seeking feedback from the applicant/vendor
community whether they are on the right track and
why/why not.
• Some of the topics are actual proposals; others
are issues for which they are seeking comments.
Make Broadband Priority 1
 FCC survey data indicates that 80% of the
applicants surveyed stated they did not have
sufficient bandwidth.
 FCC proposes to update E-Rate priorities so that
high-capacity broadband and the associated
equipment needed to disseminate that broadband to
and within those buildings becomes Priority 1.
 All other services would become Priority 2 or phased
out altogether (¶ 65)

What different or additional services should be
considered eligible such as filtering, caching and
network security services, etc?
Treat Lit and Dark Fiber Equally
The FCC proposes to treat lit and dark fiber more consistently by making
modulating electronics and special construction charges eligible as part
of dark fiber (as it now does for lit fiber). (¶ 71)
 Asks many questions related to fiber deployment:
 What are barriers to fiber deployment?
 Should E-Rate support the purchase of WANs if it’s more cost
effective than leasing? (¶ 80)
 Should the one-time installation costs receive a higher discount?
 Can the FCC do anything to reduce recurring costs over time by
altering any of its policies
 Should the Eligible Services List be amended to include additional
equipment that is needed for broadband connectivity within
buildings?
Revise Eligible Services List
The FCC proposes to phase out support for a number of
specific services including:
◦
◦
◦
◦
◦
◦
◦
paging
wireless text messaging
directory assistance
custom calling features
inside wiring maintenance plans
call blocking
800 number services. (¶ 90)
 When should such changes be made? FY 2014?
Revise Eligible Services List
The FCC also seeks comment on whether support for the
following services should be phased out, de-prioritized or
eliminated:
◦ All voice services (presumably basic telephone service, local and
long distance
◦ If so, should VOIP continue to be eligible? (¶ 105)
◦ Internet access provided via cellular data plans, including aircards.
(¶ 102)
◦ Web hosting and hosted e-mail services. (¶ 97)
◦ Basic maintenance of internal connections. (¶ 101)
 Should other items on the Eligible Services List that are not directly
related to high-capacity broadband be ineligible? (¶103)
Streamline E-Rate
The FCC proposes several options for streamlining the administration of
the E-Rate program, including:
 Requiring all forms and USAC correspondence to be submitted/sent
electronically (¶ 227);
 Providing more detailed and comprehensive funding statuses
throughout the application process (¶ 232);
 Speeding review of applications and issuance of commitment decisions
(they seek specific comments on problems they have had during the
PIA review process) (¶ 233);
 Removing the distinction between telecommunications services and
Internet access (¶ 258);
 More effectively identifying and capturing unused funds (why do funds
go unused and how can USAC identify and de-obligate those funds
more quickly?) (¶ 254); and
 Streamlining the E-Rate appeals review process (¶ 266).
Change Funding
Distribution Model
The FCC seeks comment on 4 major options for revising the
structure for distributing E-Rate funds as follows:
1) Revising the discount matrix to increase certain applicants’
matching requirements through a phase-in process. (¶117)
 What should the maximum E-Rate discount be? 70%? 75%?
 Should all of the discount bands be adjusted downward by a certain
percentage?
 Should the discount matrix be abandoned in lieu of a discount calculated
as NSLP percentage plus 20% (urban) or 25% (rural)?
2) Incorporating a per-student or per-building cap on
funding into the discount matrix. (¶ 135)





What would those caps be?
Should they apply to both Priority 1 and Priority 2 funding?
Should installation fees be excluded from the calculation?
Should there be a di minimus amount funding available?
How would consortia apply using a per-student cap?
Change Funding
Distribution, cont.
3) Providing more equitable access to Priority 2 funding (¶
133)




How can the FCC ensure more applicants have access to P2 funding
Should the 2/5 rule be replaced with another rule, such as a 1/5 rule?
Should P2 be funded on a rolling-funding cycle?
Should there be different priorities established, such as a
broadband/Internet P1 category and other service (such as voice) become
Priority 2 (or some other priority)?
4) Allocating funds through a fixed dollar amount before the
funding year begins (¶ 149)




How would this amount be calculated for libraries?
How would it be calculated for schools?
How would this work with consortia?
What would the reporting requirements be?
Change Discount Calculations
The FCC proposes 2 major revisions to E-Rate discount
calculations:
 Changing the E-Rate discount calculations to be based on a simple average of
the District’s NSLP enrollment whereby a district would receive a straight matrix
discount.
 The current formula is a weighted average approach that uses each school
building’s discount as part of the calculation) (¶ 126)
 Districts would apply for all services (P2/P2) using district-wide discount; no
building discounts would apply.)
 Changing the definition of rural to ensure greater funding to truly rural areas by
using NCES codes.
 Should the definition be based on ‘rural’ or ‘remote-rural’ areas? (¶ 130)
 Should the rural schools and libraries receive a greater discount than they
currently receive and should the rural factor also be incorporated into the
highest discount bands? (¶ 133);
Increase Funding Cap
The FCC seeks comment on whether to
increase the $2.25 billion E-Rate cap
(temporarily or permanently) to ensure highcapacity broadband connectivity to and within
schools and libraries. (¶ 173)
Increase Transparency
The FCC proposes to increase the transparency and seeks comments
on the following:
 Transparency of E-Rate spending.
◦ How can the FCC increase transparency with respect to how ERate funds are allocated and spent?
 Transparency of prices available for E-Rate supported services.
◦ How can the FCC best increase the transparency of prices for ERate supported services?
 Transparency of prices being bid for E-Rate supported services.
◦ Should the FCC consider making bid responses public or at least
accessible to other E-Rate applicants?
 Transparency of actual purchase prices.
◦ As an alternative to requiring public disclosure of all bids to provide
E-Rate services, should the FCC make available the prices
applicants are paying for E-Rate supported services?
Direct Payments to Applicants
The FCC proposes to permit schools and libraries
to receive BEAR reimbursement checks directly
from USAC and not have to pass through the
respective service providers (¶ 259).
 Should invoicing deadlines be more rigid in order to
recapture and reuse unspent funds?
Permit Multi-year 471s
• The FCC proposes to have PIA only review the first year
of a 3-year contract allow applicants, provided there was
no changes to the contract or recipients of service in the
second and third years of the contract. *
• In the second and third years, applicants would still have
to request E-Rate funding via the Form 471, but their
contracts would not be subject to PIA review.
 Should the FCC also consider multi-year funding
commitments?
 Should applicants only be permitted to sign contracts up
to 3-years in length? (¶ 241)
New FCC Forms 470 and 471
Proposed FCC Form 470
Updates
Proposed FCC Form 470 Updates
• Consolidated the Telecommunications and Internet
access categories of service into the field Priority
One Services
 Applicants must still distinguish services between
Telecommunications and Internet access on the FCC
Form 471
Proposed FCC Form 470 Updates
• Block 2, item 8a, 10a and 11a text addition
– 8a, 10a, 11a. YES, I have released or intend to
release an RFP for one or more of these services.
It is available or will become available on the
Internet at:
Proposed FCC Form 470 Updates
• Document retention certification Block 5, Item 19
update
– “I certify that I will retain required documents for a period
of at least five years (or whatever retention period is
required by the rules in effect at the time of this
certification) after the last day of service delivered.”
New FCC Forms 470 and 471
Proposed FCC Form 471
Updates
Proposed FCC Form 471 Updates
• Block 2 has been removed and a new data gathering
section has been added to Block 5
Proposed FCC Form 471 Updates
• Additional Block 5 reporting requirements
– For Broadband and other connectivity services only
• E.g. T-1, fiber, DSL, cable, cellular wireless hotspots,
satellite
– Does not apply to non-broadband or other
connectivity services
• E.g. Cellular service, web hosting and email service
– Complete information for every applicable funding
request
Proposed FCC Form 471 Updates
• If you are not requesting broadband or other
connectivity services for the individual funding request,
check the box
Proposed FCC Form 471 Updates
• If you are requesting broadband or other connectivity
services, fill out Block 5, Item 24
• For example, if you request one T-1, six fiber
connections that average 150 Mbps and one gigabit
connection:
Proposed FCC Form 471 Updates
• Item 25 b, 1 - For applicants if the Internet service is
available to students or patrons in more than just a
single location or office
– If the access is provided by wired connections,
approximately what percentage of the school classroom
or public library rooms included in the Block 4 worksheet
for this FRN will have access to wired drops? _____?
Proposed FCC Form 471 Updates
• Item 25 b, 2 - For applicants if the Internet service is
available to students or patrons in more than just a
single location or office
– If the access is provided by Wi-Fi connections,
approximately what percentage of the school classroom
or public library rooms included in the Block 4 worksheet
for this FRN will have access to Wi-Fi drops? _____?
Proposed FCC Form 471 Updates
• Item 25 c - For consortia and statewide applications,
do the connections in this FRN include the last mile
connection to the school or library? Yes No
– If no, are these connections only for backbone
connections? Yes No
Proposed FCC Form 471 Updates
• Document retention certification Block 6, Item 33
update
– “I certify that I will retain required documents for a period
of at least five years (or whatever retention period is
required by the rules in effect at the time of this
certification) after the last day of service delivered.”
E-Rate Program
New FCC Forms 486
Proposed Changes
Proposed 486 Changes
• Proposed changes to FCC Form 486
– Name changed to Receipt of Service Confirmation and
Children’s Internet Protection Act and Technology Plan
Certification Form
– Item 6C, CIPA Waiver for Libraries in FY2004,
consolidated with Item 6B, the general checkbox for
CIPA waivers
– Item 8, technology plan certification, updated
– Item 10, document retention certification updated
– Minor text edits
Proposed 486 Changes
• Item 8, technology plan certification, updated to reflect
that technology plans only need to be prepared if
required by program rules.
– For example, currently technology plans do not need to
be prepared if applicants are seeking Priority One
services only.
E-Rate Program
New FCC Form 472
Overview
• Changes to FCC Form 472, Billed Entity Applicant
Reimbursement (BEAR) Form
– Reimbursement Form Number moved to top and
renamed Applicant Form Identifier
– Reimbursement Date to USAC moved to Block 3
– Discount column added to Block 2
– Some form items renumbered due to the above
changes
– Extraneous or confusing text removed
– Certification language added
FCC Form 472 Login
FCC Form 472 Login
FCC Form 472 Block 1
BEAR Form Block 1
BEAR Form Block 2
Note: The total of each line from Block 2 should display up in
Item 6. If the system continues to show $ 0.00, click on “Save”
located at the bottom of the screen.
Example:
BEAR Form Block 3
Item 27 is new. Enter the Name,
Title, and the Address of the person
who should receive the check. If it’s
the same as the person listed in
Block 1, you must re-enter the
information.
Block 3 Certifications
E-Rate Program
Avoid the Dirty Dozen Mistakes
Fall 2013 Applicant Trainings
Avoid the Dirty Dozen Mistakes
Overview
1. Submitting paper forms
containing errors
2. Missing deadlines
3. Not following competitive
bidding rules
4. Not communicating with
service providers after the
competitive bidding process
5. Mixed bucket funding
requests
6. Incorrect discount
calculations
7. Incomplete PIA responses
8. Missing or incomplete
Item 21 attachments
9. Ignoring USAC letters
10. Poor invoicing practices
11. Inadequate document
retention
12. Not managing your E-Rate
process
Paper Forms
Unsigned, undated FCC Form 486 paper
certification
Paper Forms
FCC Form 472 –
applicant certification
page 3 signed by
applicant
FCC Form 472 –
service provider
certification page 4
signed by same applicant
Mixed Bucket Funding
Requests
Mixed bucket funding requests
Mixing Priority 1 (Telecommunications Services and Internet
Access) and Priority 2 (Internal Connections and Basic
Maintenance) on the same funding request or the same
application causes delays.
• Mixed bucket funding requests filed as Priority 1 must be
separated out by your PIA reviewer, and you will be asked
to confirm the separation.
• Mixed bucket funding requests filed as Priority 2 may not
be reviewed until Priority 2 reviews start.
Discounts
Incorrect discount calculations
Problems with applicants not using NSLP data to calculate their
discounts:
• Using NSLP forms as surveys.
• Not keeping copies of surveys or your discount calculation source
documentation (i.e. Monthly Site Claim Form or report generated by
Food Services)
• Projecting discounts from surveys with a return rate below 50%.
• Using Community Eligibility Option (CEO) data to validate the reported
discount.
– NOTE: CEO schools use NSLP data from the year before they started
participation in CEO. The FCC has not indicated whether it will provide
a waiver for FY2014 applications to use old data.
Responses to PIA
Incomplete responses to PIA
Program Integrity Assurance (PIA) reviews applications for
compliance with program rules. If PIA emails or faxes
questions but receives incomplete responses, or no
response, the funding decision is based on the information at
hand. Incomplete responses include:
• A response that does not directly address the PIA questions.
• A response that addresses some but not all of the PIA
questions.
• A response that does not include documentation when
documentation was specifically requested.
Responses to PIA
Insufficient response
Responses to PIA
Insufficient response
Responses to PIA
Incomplete responses to PIA
To avoid delays and/or denials:
• If PIA emails or faxes questions to you, read them carefully.
– If you understand the questions and the documentation
requested, respond promptly.
– If you do not understand what is being requested, contact the
initial reviewer immediately for clarification and document such
contact.
• If you need more time, ask for it.
• If you feel you are not communicating successfully with your
initial reviewer, ask to speak to a manager.
Item 21 Attachments
Missing or incomplete Item 21 attachments
The Item 21 attachment is a detailed description of the
services in each funding request and an FCC Form 471 will
be considered incomplete until the Item 21 attachment is
submitted. PIA uses this information in its review. Common
problems include:
• Missing Item 21 attachments. If an Item 21 attachment is not
submitted by the deadline, the associated funding request will
be denied.
• Incomplete information. PIA will reach out for additional
information or clarification if needed. Without this information,
PIA must make its funding decision based on the information
provided.
Item 21 Attachments
Item 21 attachment missing information
USAC Letters
USAC receipt acknowledgment and notification
letters
To avoid delays and/or denials:
• Review the funding report in the Receipt Notification Letter and
Receipt Acknowledgment Letter for ministerial or clerical errors
you can correct.
• Take note of the next steps and any deadlines described in the
letter and be prepared to act on them.
• Note any changes from your original submission (e.g., an
adjusted service start date in the FCC Form 486 Notification
Letter) and take action as appropriate.
USAC Letters
Adjusted Service Start Date
Invoicing
Poor invoicing practices
USAC must be invoiced – either through the applicant FCC
Form 472 (BEAR Form) or service provider FCC Form 474
(SPI Form) – for discounts on services actually delivered and
installed. Delays or denials can occur if:
• Invoices are filed after the invoicing deadline.
• Invoice-related forms are not filed first (FCC Form 473 for
service providers, FCC Form 486 for applicants).
• Invoice entries are incomplete or inconsistent.
• If the invoice undergoes review, requested documentation
(e.g., proof of payment, copy of contract) is unavailable.
Document Retention
Inadequate document retention
To avoid delays and/or denials:
• Review the E-Rate Binder guidance for a suggested checklist
of documents to retain and how to organize them.
• Store your documents in such a way that you – or your
successor – can find them easily if needed.
• Remember that even if your local or state regulations require a
shorter time period for document retention, you must follow the
FCC program rule for documents related to E-Rate.
• Keep in mind that some documents (e.g., multi-year contracts,
notice of public hearing or meeting for CIPA) must be kept for
five years after the latest funding year they affect.
Document Retention
Response to additional selective review question
Managing the Process
Managing your E-Rate process
To avoid delays and/or denials:
• Stay informed.
– Review the guidance information on the USAC
website.
– Subscribe to the SL News Brief.
• Plan ahead.
– Create a timeline of your E-Rate activities and follow it.
– Submit required forms and requests well before the
deadline.
Managing the Process
Managing your E-Rate process
To avoid delays and/or denials (cont.):
• Track your submissions.
– Call CSB for the status of paper form data entry.
– Familiarize yourself with the tools on the Search Tools
page to verify postings and certifications, and to track
the progress of reviews and requests.
• If you need it, request an extension before the deadline.
• Ask questions.
Questions?
Contact
Information
education.oConhio.gov
E-Rate Support and Information
Lorrie Germann: 740-253-1153
E-mail: [email protected]
To subscribe to the E-Rate list, send an email with
no message to [email protected].