Transcript PRESENTATION NAME - E-rate in Pennsylvania

E-RATE UPDATE
FOR
PENNSYLVANIA
APPLICANTS
Presented by:
J u l i e Tr i t t S c h e l l
Pe n n s y l v a ni a E - r a te C o o r d i n ato r
O c to b e r 2 01 1
Happy 15th
Birthday,
E-rate!
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WEBINAR QUESTIONS
Ask questions 2 ways:
 Text questions using tool on left side of the window.
 Raise hand using the tool next to your name and I will call on you to
use the mic.
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AGENDA
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FY 2010, 2011 , 2012
New CIPA Requirement
Maintenance
SPIN Changes
Applicant/Vendor Rules
Gift Rules
470 Disqualifications
Contract Extensions
Bid Evaluations
M/C Errors
Filtering
PEPPM Requirement
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ETC
 If you’re not a member of the PA E -rate Listserve, e-mail Julie
at [email protected]
 If you need beginners’ training, register at:
http://www.e-ratepa.org/training_outreach.htm
Nov 1 – Allentown Area (IU 21)
Nov 4 – Harrisburg Area (IU 15)
 If you’d like to download a copy of the full 2012 E -rate
Training Manual, it’s posted on www.e-ratepa.org website
under Helpful Documents (at the top of the page)
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FY 2010 (YEAR 13)
 Funding Year ended June 30, 2011 for recurring services
 Deadline for submitting BEARs (Form 472s) is Friday,
October 28, 2011
 List of affected entities sent to listserve
 Deadline for submitting invoices for non-recurring services is January
28, 2012 (unless an extension has been granted)
 File for extension if you haven’t submitted your BEAR!
 Example sent to listserve on Oct 26
 File Form 500 if you don’t need the funding
 All Priority 2 requests will be funded for FY 2010
 All 80% and below requests being reviewed and being funded now
 Because they’re being funded after March 1, you will have until
September 30, 2012 use funding
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REMINDER ABOUT ONLINE BEARS
 After you submit an online BEAR, you will receive 2 e -mails:
1) Immediately after you submit
2) After the vendor certifies the BEAR
 If you haven’t received the second e -mail, contact your vendor to
remind them to certify by deadline
 To track your BEARs (paper or online) using the Online System,
go back to the Online BEAR page and click on Track Form
 After submitted by applicant to vendor: Pending Validation
 After certified by vendor: Passed Validation
 After paid by USAC: Completed
 If you don’t have your paper BEAR postmarked by Friday, or if
your vendor doesn’t certify your online BEAR by Friday, Occt 28,
you must request an extension
 If you’re on my list and you already submitted your BEAR, it’s
because either they haven’t yet mailed your BEAR check, or they
are going to $0-fund it.
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REMINDER ABOUT $0.00-FUNDED BEARS
 When you receive the white BEAR notification letter,
be sure to open ASAP
 If the amount on the first page says $0.00 -funded, it
does not mean ‘denial’
 Create a new BEAR, correct the mistake and
resubmit
 If resubmitting after October 28, file for an invoice
deadline extension, and then resubmit after
extension is approved
 Most common reason for $0.00-funded BEARs is
listing that the service started 7/1/2011, instead of
7/1/2010
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INELIGIBLE CHARGES ON BILLS
 When determining the amount to list on a BEAR, create a quick
spreadsheet showing each month’s total charges, and total ineligible
charges
 What are the ineligible charges?
 Varies by vendor, but these are known to be ineligible:
 Property Tax Fees
 Universal Service Administrative Fee
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USF fees themselves ARE eligible
Late payment or finance charges
USF Cost Recovery Fees
Paper statement fees
Equipment charges (on P1 bills), such as cell phones
Equipment insurance fees
Directory listing fees
Non-published phone number fees
Payphone service
Personal usage
 Here’s an example of what your spreadsheet may look like:
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Verizon Account:
215-235-1232
Ineligible Charges
Total Eligible Charges
non-published #
July
$
200.10
$
2.75
$
197.35
Aug
$
200.20
$
2.75
$
197.45
Sept
$
200.30
$
2.75
$
197.55
Oct
$
200.20
$
2.75
$
197.45
Nov
$
201.30
$
2.75
$
198.55
Dec
$
203.30
$
2.75
$
200.55
Jan
$
202.20
$
2.75
$
199.45
Feb
$
201.30
$
2.75
$
198.55
Mar
$
200.30
$
2.75
$
197.55
Apr
$
203.20
$
2.75
$
200.45
May
$
200.10
$
2.75
$
197.35
June
$
203.50
$
2.75
$
200.75
$
2,416.00
$
33.00
$
2,383.00
Total Charges
$
2,416.00
Ineligible Charges
$
33.00
Eligible Charges
$
2,383.00
E-rate Discount
E-rate Reimb.
65%
$
1,548.95
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FY 2011 (YEAR 14)
 For services rendered 7/1/2011 - 6/30/2012
 74% of PA Priority 1 FRNs funded as of 10/26/2011
 P2 funding at 90%
 Likely to go lower
 File the 486 after FCDL arrives
 List of near 486 due dates sent to listserve last week
 Many due by October 28
 If you don’t file, USAC will send you a 486 Late
Notice, and give you a few additional days to file
 Request discounted bills from vendors, if desired
 FY2011 cap increased to $2.29 billion due to
inflation
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FY2011 IF YOU HAVEN’T BEEN FUNDED
 For the 26% of applicants have haven’t yet been funded, it’s
likely due to one of these four causes:
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Polluted Form 471 (mixing P1/P2 on same 471)
Certain vendor listed on your 471
PIA reviewer left USAC
Funding increase requested and caught in USAC limbo (more later)
 What should you do?
1.
2.
3.
4.
Consider possibly cancelling P2 FRN(s)
Be patient, issues being resolved
contact PIA Regional Manager – Ruchi Patel at
[email protected] – and ask if she will have your 471
assigned to another reviewer
If you don’t care about the funding increase, contact your reviewer
and ask that they process application as it was submitted
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FY 2012 (YEAR 15)
 For services rendered 7/1/2012 - 6/30/2013
 471 application window will likely open first week in January
and close mid/late March (my guess 1/5 – 3/15)
 Reason? Trying to wrap up FYP1 FCDLs before FY 2012 begins
 Form 470’s being accepted now!
 Don’t wait until Jan/Feb to file, especially if you need to take contracts
to your board
 New 470 removes many of the unused features and questions
 MTM/contract/multi-year contract checkboxes
 BEAR/SPI preference question
 Ineligible entities section
 Necessary resources checkboxes
 Area codes and phone pre-fixes section
 Must list disqualification reasons on 470 in Item 13
or in RFP
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Don’t forget:
 You must post a 470 for every service, every
year, unless.....
You are in a multi-year contract that was
originally competitively bid using a Form
470
OR
 If you are purchasing P2 equipment from
the PEPPM contract
(PEPPM was already competitively bid on behalf of all schools
and libraries)
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ELIGIBLE SERVICES LIST 2012
 ESL approved by FCC; No meaningful changes, just wordsmithing
 Reminders from FY 2011
 Lit and Dark Fiber
 Can be provided by a non-telco
 Dark fiber installation only eligible from school building to property line
 Dark fiber must be leased, and lit by the applicant
 VOIP
 Handsets never eligible, even if leased
 Gateway can be bundled with MRC
 Basic Maintenance – Eligible
 No-cost bundled manufacturer warranties up to 3 years
 Software, patches, online tech support (such as Ciscobase)
 Reimbursements for actual labor and break-fix cost
 Basic Maintenance – Not Eligible
 Unbundled warranties, insurance-type warranties, including Smartnet
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NEW CIPA REQUIREMENTS
 New CIPA requirements become effective 7/1/2012
 Requires schools’ (not libraries) Internet Safety
Policies include "... educating minors about appropriate
online behavior, including interacting with other individuals on
social networking websites and in chat rooms and cyberbullying
awareness and response."
 This means that schools are required to teach online safety to
students as a prerequisite to receiving E-rate funding
 Local boards decide frequency and delivery of online
safety/cyberbullying education
 Can’t be once every 4 years
 Establish policy, follow policy and document
implementation
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CIPA DOCUMENTATION
 Notice of public hearing or public meeting (such as
school board meeting) where CIPA policy was
considered and voted upon
 Agenda for meeting – show opportunity for public input/comment
before adoption of CIPA policy
 Other documentation for opportunity for public comment
 Filtering records, purchase order
 Documentation of cyberbullying/appropriate online
behavior education for all minors
 Curriculum, when taught, to whom, etc...
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NEW SPIN CHANGE RULES
 Can no longer switch vendors because of lower price
 Some vendors were abusing lax SPIN change rules and not
bothering to participate in 470 bidding process
 Legitimate reasons include:
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breach of contract
service provider is unable to provide quality service
bankruptcy
delayed provision of service
 Must select vendor that received the next highest point
value in the original bid evaluation, assuming there was
more than one bidder
 If no other bidders, then you may select any cost effective
vendor
 Tell your business office!
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SHOULD I APPLY FOR P2 FUNDING?
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Year 1 -- funded to 70%
Year 2 – all funded
Year 3 – down to 82%
Year 4 – down to 87%
Year 5 – down to 81%
Year 6 – down to 70% - significant rollover
funds
Year 7 – down to 81%
Year 8 – down to 80%
Year 9 – down to 86%
Year 10 – down to 81% - $650M rollover
Year 11 – down to 87% - $600M rollover
FY 2009 – down to 77% - $900M rollover
FY 2010 -- all funded - $1.15B rollover +
inflation
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APPLICANTS CANNOT...
 Have a relationship with service providers that would
unfairly influence the outcome of the competition
 Furnish service providers with inside competitive
information
 Provide information or grant meetings to only some
bidders
 Violate new gifts rules
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APPLICANTS CAN...
 Have pre-bidding discussions with potential bidders
as long as that doesn’t lead to one bidder having
“inside” information
 Attend product demonstrations
 Encourage and seek vendors to bid
 Do research to determine what cost-effective
solutions are available
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SERVICE PROVIDERS CAN...
 Of fer neutral technical assistance on development of
technology plan
 Cannot exert undue influence on applicant's ability to conduct a fair and
open competitive bidding
 Answer general questions about the products and services
they sell in response to applicant inquiries
 Assist with Form 471 Item 21 attachment
 Provide information to applicants to assist with responding to
PIA questions but applicant must respond to PIA
 Provide assistance with service substitutions and other post commitment activities but applicant must certify
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SERVICE PROVIDERS CANNOT...
Help prepare Form 470
Help write or provide RFP to applicant
Be a contact person on Form 470
Sign any applicant forms
Be involved with bid evaluation in any way
Provide funding for the applicant's non -discount portion or
waive the applicant's non -discount portion
 Coerce or pressure the applicant to use a specific service
provider
 Note to vendors on this webinar....
 Provide gifts to applicants that violate the gift restrictions
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GIFT RESTRICTIONS
All gifts from service providers to applicants are prohibited
except for:
 Modest refreshments that are not offered as part of meal (e.g., coffee
and donuts provided at a meeting) and items with little intrinsic value
intended for presentation (e.g., certificates and plaques);
 Items that are worth $20 or less (e.g., pencils, pens, hats, t-shirts, and
other items worth less than $20, including meals), as long as those
items do not exceed $50 per employee from any one source per funding
year
 Charitable contributions in support of schools, including, for example,
literacy programs, scholarships, as long as such contributions are not
directly or indirectly related to E-rate procurement activities or decisions
 Personal gifts to family and personal friends when those gifts are made
using personal funds of the donor (without reimbursement from an
employer) and are not related to a business transaction or business
relationship
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WHO IS SUBJECT TO GIFT RESTRICTIONS?
Service providers
 All service providers with current or possible future
E-rate relationship to applicant
 Includes:
 All employees, officers, representatives, agents, or
independent contractors of service providers; and
 All individuals who are on the governing boards of such a
service provider (such as members of the board of directors)
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WHO IS SUBJECT TO GIFT RESTRICTIONS?
Applicants
 All individuals who are on the governing boards of
such entities (such as members of a school
committee)
 All employees, officers, representatives, agents,
consultants or independent contractors of such
entities involved on behalf of such school, library, or
consortium with E-rate
 Individuals whose work in any way relates to E-rate forms and
technology plans;
 Individuals who prepare bids, communicate or work with E-rate
service providers, E-rate consultants, or with USAC; and
 Any staff of such entities responsible for monitoring
compliance with the E-rate Program
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OTHER IMPORTANT DETAILS RE GIFTS
 Aggregate value of all gifts to a single applicant
employee, from a vendor (company) is considered
when computing the $50 annual limit
 Example: Comcast as a company can’t give more than $50/year to a
single school employee, in no larger than $20 increments
 Rules are always applicable, not just during the time
period when the competitive bidding process is taking
place
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OTHER THINGS TO REMEMBER
 Contract extensions:
 If you sign a contract with optional extensions, be sure the contract
lists what the price will be during those extensions.
 Either exact price, or current contract price adjusted for current CPI
 A note to the vendors on this webinar...
 Bid evaluations must be performed, with price of eligible
services receiving the heaviest weight
 Can consider many other factors. Examples:
 History with vendor
 Cost of ineligible items
 New vendors’ cell phones
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MBE/WBE preference
Quality of proposed solution
Cost of staff time required to switch vendor
In-state preference
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MULIT-TIERED EVALUATIONS
 Multi-tiered bid evaluations (BAFOs) ok:
 If you use a multi-tiered or multi-round evaluation process, the price
of the eligible services ultimately must be the primary evaluation
factor in selecting the winning bid.
 Technical capabilities, such as scope or quality of service, may form
the basis for conducting the first round of bid evaluations. This tier
may be evaluated on a pass/fail basis or scored numerically where a
maximum score is required to advance to the next tier of the
evaluation process.
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MINISTERIAL AND CLERICAL ERRORS
 In previous year s, applicants could make almost ANY change to a 471
during the 15 -day RAL Correction Period
 This summer, the FCC issued an appeal which stated:
“The applicant can amend its forms to correct clerical and
ministerial errors on their FCC Forms 470, FCC Form 471 applications, or
associated documentation until an FCDL is issued . Such errors include
only the kinds of error s that a typist might make when entering data from
one list to another, such as mistyping a number, using the wrong name or
phone number, failing to enter an item from the source list onto the
application, or making an arithmetic error.”(FCC 11 -60)
 USAC revised their procedures to be extremely conser vative, making
nearly all corrections invalid
 States pushed back , met with the FCC, and those procedures were
pulled
 New PIA procedures being developed to better match FCC’s intent
 Af fected applications in limbo as a result
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M/C ERROR EXAMPLES
 Using wrong FCC Form 470 number, wrong billed entity
number, or wrong billed entity number/worksheet number
on Form 471
 Using wrong name or service provider identification
number (SPIN)
 Using wrong expiration date for a contract
 Inaccurately reporting the prediscount amount on Block 5
 Leaving off a building from Block 4
 Listing wrong service category in Block 5
 Simple addition, subtraction, multiplication or division
errors
 Failing to enter an item from the source list (e.g., NSLP
data, uploading Block 4 data, FRN, etc.)
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REQUESTING A M&C CORRECTION
 PIA will ask if this is a ministerial or clerical error
 Explain how the error occurred
 Provide a reasonable explanation
 Provide documentation that was in existence as of the date of
submission of Form 470 or Form 471
 Explain that the error occurred when consulting
“source list”
 PIA must approve the explanation before the change
will be made
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EXAMPLES OF SOURCE DOCUMENTATION
 Contract, Service Agreement
 Vendor quote, bill, invoice, etc.
 RFP, Newspaper listing
 NSLP documentation or student enrollment data
 Board Minutes, Resolutions
 Budget
 Any other documentation in existence as of date of
submission of Form 470 or Form 471 to prove error
was ministerial/clerical
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ARE YOU IN LIMBO DUE TO M/C?
 If you requested an increase to your funding request, or PIA
noticed that you were eligible for an increase, your
application is likely being held while new procedures are
being developed
 If you would rather have your FCDL now than wait for the
increase to be approved (denied), you can contact your
original PIA reviewer and ask them to process your application
as it was submitted and forgo the increase
 If your original reviewer has left, e-mail Ruchi Patel at
[email protected]
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PEPPM
 If using the PEPPM contract for FY 2012, you may
skip the 470 process
 But you must contact the PEPPM-awarded vendor for
a price quote before you submit your Form 471
 Quote must be on vendor letterhead with date
 PIA will ask for this during their review
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FILTERING
 FCC acknowledged that current rules may not address the
filtering requirements when personal computers and devices
are brought to school
 But they have verbally stated that any school -owned
computer/device must be filtered, whether it is used on
campus or of f
 When the FCC requests public comment, I encourage you to
participate
 As of now, no exceptions for cellular devices
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WHERE CAN I LOOK FOR INFORMATION?
 www.e-ratecentral.com/us/stateInformation.asp?state=PA
 Enter your E-rate Billed Entity Number in upper left
corner
 Website shows
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All FRNs
Every Funding Year
What Has Been Filed
What Has Been Committed and Disbursed
 Need help? E-mail Julie at [email protected]
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QUESTIONS?
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