Transcript PowerPoint Template

E-rate Program
Updates for the FY2011
Application Process
E-Rate Program
Revised FCC Forms 470 and 471
Form 471 Submissions – FY2009
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Form 471 Submissions – FY2010
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General Format Changes
Formatting changes to paper forms
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Grey boxes (one character per box) removed
Extra lines separating most fields removed
Larger font where possible
Checkboxes outlined
More easily read
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General Format Changes
Online formats remain the same
• Apply Online page
• Form filing options
– Interview or expert
– Continue incomplete
– Item 21 (Form 471)
• Certification options
– Certify online or on paper
NOTE: Training site will be updated after Apply Online page
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Apply Online Page
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Apply Online Page - Detail
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Interview Example (Form 470)
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Expert Example (Form 470)
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Revised FCC Forms 470 and 471
Changes Common to
Both Forms
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Changes Common to Both Forms
Eligible Entities/Type of Application (Additions in red)
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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
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Changes Common to Both Forms
Recipient(s) of Services (check all that apply)
– Public
– Private
– Charter
– Tribal
– Head Start
– State Agency
• You must check at least one option
• You may check multiple options
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Changes Common to Both Forms
Consultant Information
• 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 the authorized person
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Changes Common to Both Forms
Consultant Information Fields
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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
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Changes Common to Both Forms
Technology plan certification
• 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 SLD-certified technology plan approver, prior
to the commencement of service OR
• I certify that no technology plan is required by
Commission rules.
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Changes Common to Both Forms
Educational purposes certification
• 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.
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Changes Common to Both Forms
Email addresses
• 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
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Revised FCC Forms 470 and 471
Form 470
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Form 470 - Overview
Changes to Form 470
• Block 1: Applicant Address and Information
– Eligible entities that will receive services / Recipient(s)
of services added (slides 12 and 13)
– Number of eligible entities moved from Block 4
– Consultant information added (slide 15)
• Block 2: Summary Description of Needs or Services
– Tariffed/month-to-month, contracted services (multiyear, voluntary extensions), contracts signed before
July 19, 1997 deleted
– SPI/BEAR/no preference checkboxes deleted
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Form 470 - Overview
Changes to Form 470
• 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
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Form 470 - Overview
Changes to Form 470 (continued)
• Block 5: Certifications and Signature
– Some certification language changed
– Consultant as authorized person checkbox added
(slide 14)
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Form 470 – Certifications
Block 4 - Changes to certification pages
• Item 17 – Technology plan certification (slide 16)
• 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 17)
• Item 21 – The following sentence has been added:
– I certify that I have considered what financial resources
should be available to cover these costs.
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Form 470 – Certifications
Block 4 - Changes to certification pages
• 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
(slide 14)
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Revised Forms 470 and 471
Form 471
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Form 471 - Overview
Changes to Form 471
• Block 1: Billed Entity Address and Information
– FCC Registration Number added
– Type of application and Recipient(s) of services added
(slides 12 and 13)
– Consultant information added (slides 14 and 15)
• Block 2: Impact of Services Ordered
– Collection of broadband services data added
• Block 3: [reserved]
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Form 471 - Overview
Changes to Form 471 (continued)
• 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 14)
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Form 471
Changes to Form 471
• Block 1: Billed Entity Address and Identifications
– Item 3b – FCC Registration Number (FCC RN) added
• Persons and entities doing business with the FCC must
obtain an FCC RN and supply it when doing business with
the FCC (Form 471 Block 1 entities only)
• If you do not already have an FCC RN, you can visit
https://fjallfoss.fcc.gov/coresWeb/publicHome.do
– Items 5a and 5b – Type of application/Recipient(s) of
service added (slides 12 and 13)
– Item 6g – Consultant information added (slide 15)
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Form 471
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
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Form 471
Block 2: Impact of Services Ordered – Items 7a through 7g
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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)
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Form 471
Block 2: Impact of Services Ordered – Item 7g
• Direct broadband services: Number of buildings served at
the following speeds:
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< 200 kbps
200 kbps – 1.5 mbps
1.5 – 3 mbps
3 – 10 mbps
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10 – 25 mbps
25 – 50 mbps
50 – 100 mbps
> 100 mbps
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Form 471
Block 3: [Reserved]
• Block 3 is marked “reserved” to maintain the numbering
of subsequent blocks
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Form 471
Block 4: Discount Calculation Worksheet
• 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
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Form 471
Block 4: Discount Calculation Worksheet (continued)
• 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
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Form 471
Block 4: Discount Calculation Worksheet (continued)
• 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 request
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Form 471
Block 5: Discount Funding Request(s)
No changes
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Form 471 – Certifications
Block 6: Certifications and Signature
• Item 26 – Technology plan certification (slide 16)
• 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 (slide 17)
Signature page
• Checkbox for consultant as authorized person (slide 14)
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Questions?
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E-rate Program
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Report and Order
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Overview
What’s Included?
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Leased dark fiber now eligible
Makes permanent community use
Services to certain residential schools are eligible
Indexes funding cap to inflation
Pilot program for schools providing offsite wireless access
Technology plans only for P2
More on competitive bidding, including gifts
Disposal of equipment and SPIN changes
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6th Report and Order
Improving Broadband
Access for All
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Access to Broadband
Dark Fiber
• 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 local networks;
or private networks
• Cannot purchase excess capacity for future growth
• Maintenance of leased dark fiber is eligible
• Installation costs within the property line are eligible
• Modulating electronics for leased dark fiber are not
eligible
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Access to Broadband
Dark Fiber Construction
• Up-front construction costs:
– Construction on school or library property is eligible
– Construction beyond the property line is ineligible
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Access to Broadband
Who can provide fiber?
• Any provider can provide telecommunications over fiber
– Includes voice phone service, distance learning, etc.
– Includes providers such as state and regional
networks, utility companies, and private companies
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Access to Broadband
Applying for fiber
• On Form 470, post for fiber and fiber-based services in
both Internet Access and Telecom Services to maximize
your pool of providers
• On Form 471, file in Telecom Services if the provider is a
telecommunications carrier or Internet Access for all
other providers
• CIPA reminder:
– CIPA compliance is required if selecting services in
Telecom Services when used to obtain Internet service
or access to the Internet
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Access to Broadband
Selecting Broadband
• Applicants can access broadband through a variety of
means
• When comparing competing bids with different
solutions, you should do an “apples to apples”
comparison
• Total cost for leased dark fiber involves a number of
additional costs beyond the lease payments for fiber
connectivity, and those costs should be factored into a
total-cost comparison across bids.
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Improving Broadband Access
Community Use of Schools’ E-rated Services
• Waiver for FY 2010 is now permanent
• When schools are not in session, schools may open their
facilities to the general public to use E-rate supported
services on the school’s campus.
• 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
– Use must be incidental and not increase E-rate costs
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Improving Broadband Access
Community Use of Schools’ E-rated Services
• Community use is limited to non-operating hours and
only on campus
– School personnel and students must have priority
• 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.)
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Improving Broadband Access
Funding for Certain Residential Facilities
• Residential schools that service populations facing
unique challenges can receive support for service in
residential areas (dormitories) of their schools.
• Eligible populations include:
– Schools on Tribal lands
– Children with physical, cognitive and behavioral
disabilities, and those with medical needs
– Juvenile Justice schools, where eligible
– Schools with 35% or more students eligible for NSLP
• Schools can be public or private
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Improving Broadband Access
Indexing the Funding Cap to Inflation
• Funding has been capped at $2.25B since 1999
• Starting with FY 2010, the cap will be increased based on
the Dept of Commerce Gross Domestic Product numbers.
• 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: $2,270,250,000
• This increase is in addition to any rollover funds
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Improving Broadband Access
E-rate Deployed Ubiquitously (EDU) 2011 Pilot Program
• Pilot allows up to $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 to determine whether such
services should permanently be eligible for E-rate
support.
• FCC will require data reporting by those selected
• Strong preference given to those who have implemented
or in the process of implementing such programs
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Improving Broadband Access
EDU 2011 – How to Apply
• Rules:
– Competitive bidding rules for applicants who already
have legally binding agreements with existing
providers for these services are waived.
– Other rules may be waived to the extent necessary to
run the program
– CIPA continues to apply
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6th Report and Order
Streamlining and
Simplifying
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Streamlining & Simplifying
Technology Plans
• 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)
• Beware of potential bucket switches
– P1 on-premise equipment moved to Internal
Connections
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Streamlining & Simplifying
Technology Plan Timing
• Who needs a written plan prior to the Form 470 posting?
– Applicants citing their own Form 470:
• If P2 services are all included in current tech plan, and
the plan covers at least part of the upcoming funding
year, then a new tech plan not needed prior to posting
• If new P2 services requested are not in tech plan, then
must have a written plan prior to posting
– Applicants citing a State-filed Form 470:
• Not needed prior to posting of state-filed Form 470
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Streamlining & Simplifying
Technology Plan Timing
• Technology Plan Approval – no change
– All applicants requesting Priority 2 services, must have
an approved plan that covers at least part of the
upcoming funding year prior to the start of service, or
the filing of the Form 486, whichever comes first.
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Streamlining & Simplifying
Technology Plan
• Four Required Elements
– Applicants no longer have to include a section on
budget
– This information is covered by certification on
necessary resources (“I certify that the entities I
represent or the entities listed on this application
have secured access to all of the resources to pay the
discounted charges …”)
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Streamlining & Simplifying
Disposal of Equipment
• 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
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• 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
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• 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
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• Rule violations include (but are not limited to):
– Service Provider prepares applicants’ Form 470 or
participates in the bid evaluation or vendor selection
process in any way
– Applicant turns over the competitive bidding process
to a service provider
– Applicant employee with a role in the selection
process has an ownership interest in a vendor seeking
to provide the services
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• Rule violations include (but are not limited to):
– Applicant does not describe the desired products and
services with sufficient specificity to enable interested
parties to bid.
– List is not exhaustive and are meant as examples
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• Gifts
– Receipt of gifts by applicants from service providers
and potential service providers is a competitive
bidding violation.
– Must follow the stricter of state/local or FCC rules
– Applies per funding year
– Exceptions mirror Federal Government regulations
• Modest refreshments not offered as part of a meal (eg
coffee and donuts at a meeting) are OK
• Items with little or no intrinsic value such as certificates
and plaques are OK
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• Gifts
– Exceptions:
• Items worth $20 or less (meals, pencils, pens, hats, tshirts etc) as long as those items do not exceed $50 per
funding 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.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• 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
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Streamlining & Simplifying
Fair and Open Competitive Bidding Rule
• Gifts
– Gifts to family and friends when those gifts are made
using personal funds of the donor (without
reimbursement from the employer) and are not
related to a business transaction or business
relationship are also exempt.
– 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 E-rate related procurement.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Simplifying and Streamlining
Gift Examples
Gifts OK
Gifts NOT OK
Coffee and donuts at a presentation
Meal at presentation over $20
Door Prize: Ball cap worth $20 or less
Door Prize: $30 gift card
Certificate or plaque presented at
conference
Gold watch given as thank you gift
Travel, food or lodging at conference,
even if you are speaking on behalf of the
provider
Pens handed out a conference worth $20
or less
Conference giveaways: any item
exceeding $20 in value (eg briefcase)
Holiday present to sibling, not reimbursed Customer Appreciation meal/gift
by company, paid with own funds
exceeding $20
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Simplifying and Streamlining
Gift Examples
Gifts OK
Gifts NOT OK
Joe Applicant get $18 lunch from Larry,
the Cable Guy. No other meals or gifts
during the funding year from anyone
employed by, or representing, the Cable
Company.
No Rule Violation = Total gift below $20
and $50 threshold.
Joe Applicant get $12 lunch from Larry,
the Cable Guy three times during the
funding year. (Total: $36 total). Larry’s
boss, takes Joe to lunch for $18. (Total
from Cable Company: $54).
Rule violation = exceeded $50 threshold
Jane Applicant wins mousepad at a
conference from Internet R Us. (Value =
$8)
Jane Applicant also receives $15 box of
chocolates from Internet R Us.
No Rule Violation = Both below $20 and
did not exceed $50 threshold.
Jane Applicant wins a wireless mouse and
mousepad at a conference from Internet
R Us. (Value = $24 +$8)
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
Rule violation: One gift exceeded $20
threshold.
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Simplifying and Streamlining
Gift Examples
Gifts OK
Gifts NOT OK
Joe Applicant attends a conference and
picks up a free ballpoint pen and stress
ball from a company he’s never heard of.
No further gifts are given.
No Rule Violation = Total gift below $20
and $50 threshold.
Joe Applicant is invited to a customer
appreciation lunch at a seminar. Meal
value = $22
Jane Applicant received a bag of peaches
in the summer from a provider.
Value of peaches = $10
No other gifts are given by anyone from
that company for the rest of the funding
year.
No Rule Violation = Below $20 and did not
exceed $50 threshold.
Jane Applicant is invited to speak at a
conference regarding services she gets
from a provider. The provider offers to
pick up travel costs.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
Rule violation = exceeded $20 threshold
Rule violation: Total gift exceeded $20
threshold.
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Streamlining & Simplifying
SPIN Changes
• Pre-commitment SPIN changes
– Corrective SPIN changes only (ie. 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
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Eligible Services List
Eligible Services
• Order adopts the FY 2011 Eligible Services List
• Priority 1
– Leased dark fiber is eligible as described above
– Telecommunications now two categories on ESL
• “Telecommunications Services” can only be provided by
an eligible telecommunications carrier
• “Telecommunications” can be provided by a nontelecommunications carrier via fiber in whole or in part
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Eligible Services List
Eligible Services
• Web hosting
– Remains eligible
– Allows additional functionality of discussion boards,
instant messaging and chat
– Content remains ineligible, including searching of
databases such as gradebooks, encyclopedias etc.
– Support for applications necessary to run online
classes or collaborative meetings is also ineligible
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Eligible Services List
Ineligible Services
• Wireless Internet Access Applications
– Remain ineligible
– Wireless Internet Access service and data charges for
a service that is solely dedicated to access an ineligible
functionality is also ineligible
• For example, cellular data circuits used to support GPSs
on busses or student attendance are fully ineligible
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Eligible Services List
Ineligible Services
• Enhanced Firewalls, Intrusion Detection and Prevention
Devices and Anti-Virus and Anti-Spam software
– All fully ineligible
– Basic firewalls that are bundled with Internet access
remain eligible
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
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Eligible Services List
Ineligible Services
• Unbundled Warranties
– Separately priced warranties allows for broken
equipment to be fixed or replaced are ineligible.
– This is a type of retainer and not actual maintenance
service performed.
– Funding requests for routine maintenance will
continue to be funded.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
75
Eligible Services List
Ineligible Services
• Unbundled Warranties
– Applicants that can estimate number of maintenance
hours per year for their equipment, based on current
life of equipment and history of needed repairs, can
seek funding for upfront costs on service contract
designed to cover this estimate and upkeep.
– Reimbursement will be paid on actual worked
performed and hours used only.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
76
Eligible Services List
Ineligible Services
• Unbundled Warranties
– For example, school determines they need 30 hours of
maintenance for a router but only use 20
• USAC will reimburse for 20 hours only
– Manufacturers warranties of no more than three
years and included in the equipment purchase are
eligible.
• Scheduling services are ineligible
• Online backup solutions are ineligible
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
77
Eligible Services List
Administrative Changes for the ESL
• The complete list of services and products eligible for Erate support will only be listed in the ESL from now on,
and not elsewhere in the rules.
• USAC will submit the ESL to the Commission by March 30
of each year
• ESL can be released through Public Notice or Order
– Stakeholders will continue to be able to provide
comment on future ESLs.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
78
Questions?
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
79
E-rate Program
Program Compliance
Overview
•
•
•
•
•
•
•
•
•
Know Your Roles
Technology Plans
Competitive Bidding Do’s & Don’ts
Forms 470 and RFPs
Vendor Selection
Pre- Commitment “Must Knows”
CIPA Compliance
Post Commitment “Must Knows”
Document Retention
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
81
Know Your Role
• Applicants
– Write tech plan(Priority 2 services only), file Form 470 and write RFP,
evaluate bids, select provider, document the process, file Form 471,
get tech plan approved, file Form 486, select invoice method, file
BEARs, retain docs
• Service Providers
– Respond to 470/RFPs, assist with preparing Item 21 attachments,
provide technical answers on questions regarding specific goods and
services requested, but NOT on competitive bidding; file SPIs and/or
approve BEARs; file SPAC, retain docs
• Consultants
– Follow the role of their client – either applicant or service provider,
obtain a consultant registration number, retain docs
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
82
Know Your Role
When you don’t follow your role
• FRNs are denied
Program Compliance Denials
Form 470
$
Competitive bidding
$ 36,227,592.00
Contracts
$
Insufficient Documentation
$ 22,632,050.00
Necessary Resources, Tech Plan, Cost
Effectives
$
Total $ Denied
$ 78,053,203.00
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
4,573,327.00
6,714,749.00
7,905,485.00
83
Technology Plan
Tech Plans prior to FY 2011
•
•
•
Required for all categories of service (excluding basic
telecom and VOIP)
Creation must precede Form 470/RFP
– Month and year that the plan is “written”
Five elements
– Goals/strategy for using technology
– Professional development strategy
– Needs assessment
– Sufficient budget
– Evaluation process
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
84
Technology Plan
New Tech Plan Requirements
•
•
New requirements apply to FY 2011 and beyond
IC and BMIC ONLY require a tech plan
–
•
•
Be aware of potential bucket switches from P1 to P2
(e.g., P1 on premise equipment moved to IC)
Budget is no longer tech plan element
A written tech plan is
–
–
not needed prior to posting Form 470 when you are
using a state Form 470
needed prior to posting Form 470 , if P2 services are not
addressed in the existing tech plan (e.g., requesting
servers, routers)
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
85
Technology Plan
New Tech Plan Requirements
•
A revised tech plan is not needed prior to posting Form
470 , if an existing approved tech plan is in place which
covers a portion of the upcoming funding year
– Must have approved tech plan prior to the start of
service or when the Form 486 is submitted whichever
is earlier
Example:
– Posted Form 470 – December 15, 2010
– Current approved tech plan expires December 1, 2011
– A written tech plan is not required at the time Form
470 is posted
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
86
Technology Plan
Tech Plan Requirements for Everyone
•
•
•
•
•
Created by schools or libraries ONLY (no service providers
involvement)
Sufficient detail to support and validate the services
requested
Should cover the funding year
Approved by a USAC-certified Tech Plan Approver (TPA)
before Form 486 is filed or services start, whichever is
sooner
Must follow FCC rules and your DOE state or local
technology plan requirements
•
Your DOE may require a tech plan for P1 services
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
87
Competitive Bidding
The Competitive Bidding Process
• Must be fair and open process
• Avoid conflicts of interest
– Applicant consultant Service Provider
– Applicant  Service Provider
• Open competition and bid evaluation
• Follow all rules – FCC and state/local
• Read the Form 470/RFP responses and contract fine
print
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
88
Competitive Bidding
Vendor Involvement
• Service providers cannot:
– Determine the types of service the applicant will seek on a
Form 470
– Prepare, assist applicants with the filling out of the FCC
Form 470
– Sign, certify and/or submit Form 470
– Negotiate with prospective bidders
– Assist or run the competitive bidding process for the
applicant
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
89
Competitive Bidding
Vendor Involvement
• Service providers cannot:
– Be privy to information about the bid not shared with
other potential bidders
– Provide charitable donations that have a relationship to
the competitive bid and would circumvent FCC competitive
bidding rules
– Offer or provide any gifts or other things of value to those
personnel of eligible entities involved with E-rate program
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
90
Competitive Bidding
Applicants Involvement
•
Applicants can:
– Have pre-bidding discussions
o Discuss their product offering with SPs
o Learn about new technologies from SPs
– Have product demonstrations
– Encourage and seek vendors to bid
– Receive de minimis gifts
• Modest refreshments, not offered as a part of a meal
• Items with little intrinsic value intended solely for
presentations
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
91
Competitive Bidding
Applicant Involvement
• Applicants cannot:
– Have a relationship with service providers that would
unfairly influence the outcome of the competition
– Furnish service providers with inside competitive
information
– Have ownership interest in a service provider’s company
competing for services
– Violate applicant’s own ethical regulations policy
– Solicit or accept any gift or
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
92
Competitive Bidding
Applicant Involvement
• Applicants cannot:
– Solicit or receive gifts worth $20 or more or
exceed $50 per school or library employee from
any single service provider participating in or
seeking to participate in the E-rate program per
year.
• Gifts include meals, travel and entertainment (e.g.,
sporting events, trips)
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
93
Forms 470 and RFPs
Forms 470
•
•
•
•
•
•
•
Indicates the services and categories of service
which entities are seeking
Must be based on tech plan (if applicable)
Must be posted for 28 days
Indicates if they are planning/have issued RFP
Indicates any special requirements and/or
disqualification factors
Indicates who will be receiving the services
Posting a new Form 470 not required, if Form 470
is for multi-year contract and signed multi-year
contract, until the contract expires
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
94
Forms 470 and RFPs
Requests for Proposal
• FCC rules refer to RFPs generically but they may have a
variety of names (Request for Quotes, Scope, or Work)
• FCC rules do not require RFP but state and local
procurement rules may
• Must be based on entities’ tech plan (if applicable)
• Must be available to bidders for at least 28 days
– Count 28 calendar days from the later of the two
posted (470 and RFP)
• Example: RFP posted on December 1, Form 470 posted
on December 15,
• December 15 starts the 28 days count
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
95
Forms 470 and RFPs
Form 470 and RFP Issues
• Applicants must ensure that they post for the correct
category of service
– PIA can switch the category of services if applicants make a
mistake on their Form 471
• Sufficient detail in Form 470
– Cannot provide generic descriptions (e.g., All eligible
telecom services, Digital Transmission Services)
– Cannot provide laundry lists of products and services
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
96
Forms 470 and RFPs
Form 470 and RFP Issues
• Third party entities
– Non-state agencies that conduct the competitive
bidding and contract negotiations on behalf
schools or libraries
• (e.g., Joint Power Authorities)
– Must have a Letter of Agency (LOA) to act on
behalf of applicants
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
97
Forms 470 and RFPs
Form 470 and RFP Issues
• Third party entities cont’d
– If multiple vendors are selected, applicants must
conduct a mini-bid to award contract
• Make sure to memorialize your decision
• Document retention rules apply
– Generally, applicant completes the Form 471
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
98
Forms 470 and RFPs
Imposing Restrictions
• Set some eligible services requirements
– Applicants may require service providers to provide
services that are compatible with one kind of system
over another (e.g. Cisco compatible).
– Applicants cannot state make and model on Form 470
or RPF, may state equivalent make and model
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
99
Forms 470 and RFPs
Imposing Restrictions
• Disqualifying Bidders
– Qualifications/disqualification factors must be spelled
out to all interested parties prior to the bid evaluation
begins
– Available to all in Form 470 and/or RFP
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
100
Forms 470 and RFPs
Imposing Restrictions
• Disqualifying Bidders cont’d
– Disqualification factors should have yes/no responses
and cannot be scored on a range
• Yes/No Examples
– Was the bid submitted by the response date?
– Was the bid certified?
– Did the vendor attend the pre-bid walk through?
• Range Score Examples
– Using on a scale to rank the vendors (e.g., Very high, high,
poor)
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
101
Vendor Selection
Bid Evaluation
• Retain all vendor selection documentation (remember
document retention rule)
– Winning and losing bids, correspondences, memos,
bid evaluation documents, etc.
• Price of the eligible goods and services must be primary
factor in all rounds
– USAC sample evaluation matrix available
• Vendor evaluation begins after 28 day waiting period
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
102
Vendor Selection
Most Cost Effective
• Selecting the winning bidder
– Price of the ELIGIBLE goods and services must be the
primary factor.
– Other factors, including other price factors, can be
considered as well but they cannot be weighted
equally or higher than cost of the eligible goods and
services
– See Step 4: Construct An Evaluation for weighting
samples
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
103
Vendor Selection
Cost Effectiveness
• Solution must be cost-effective (not just the most
cost-effective)
• Ysleta Order, para. 54: Routers priced at two or three times greater
than the prices available from commercial vendors would not be
cost-effective, absent extenuating circumstances.
• Receiving only one bid does not automatically make it costeffective
• Applicants must be able to explain why a solution with higher than
average pricing is cost-effective.
• Provide as specific an answer with as much objective information
as possible.
• Service Providers may work with the applicant to help them
understand the technical needs for this expensive solution.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
104
Vendor Selection
Free Services
• Can’t use E-rate to get free stuff (ineligible or eligible)
• Must deduct the value of the “free stuff”, discounts,
trade-in etc, from the pre-discount amount in order
get equal comparison between offerings
Example: Discount rebate
–Cost for product = $100 pre-discount
–Rebate of 20% is available
–Can ONLY apply for $80 ($100*80%) prediscount
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
105
Vendor Selection
Free Services
• A proportionate cost allocation is required between
eligible and ineligible components.
• Cost of eligible goods and services cannot be inflated
to cover the “free” ineligible stuff
Example: “Free products” included in a bid
– Vendor A: $10,000 products includes $1,000 of free
ineligible products (Deduct $1,000 free products)
– Vendor B: $8,000 for eligible products – no free products
– Must compare:
• Vendor A: $9,000 ($10,000 -$1,000) to Vendor B: $8,000
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
106
Vendor Selection
Pre-Commitment SPIN Changes
• Corrective SPIN change is same service provider corrections to
the SPIN
– Data entry errors
– Service provider mergers, or been acquired by another
vendor
Post-Commitment SPIN Changes
• Operational SPIN change is to different service provider
– Breach of contract or service provider is unable to perform
– Newly selected service provider must receive the next
highest points value in the original bid evaluation (if there
was more than one bidder)
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
107
Contracts
Contracts Overview
• A contract must be signed and dated by the applicant
prior to the Form 471 certification postmark date
– Applicant must not sign a contract before the Allowable
Contract Award Date (CAD)
– Service providers may sign before the CAD
– When state and/or local contract law doesn’t require
signature and/or date, the applicant will be given the
opportunity to complete a certification statement.
• A purchase order may be considered a contract ONLY
if your state considers it a contract
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
108
Contracts
Contracts Overview
• Voluntary Contract Extensions
– Are allowable when the option for contract
extensions is stated in the original provision of the
contract
– Applicant must rebid the services (i.e., file a new
Form 470) if contract extensions are not stated in
the contract or RFP
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
109
Contracts
Contracts Overview
• Service Delivery Extension
– Deadline for implementation of nonrecurring
services is September 30 following the close of the
funding year
– Applicants may request a service delivery
extension from USAC for non-recurring services
– File a Form 500 to adjust the contract expiration
date
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
110
Contracts
State Master Contracts
• A state master contract (SMC) is competitively bid
and put in place by a state government for use by
multiple entities in that state
• Single winner
– Single vendor wins the bid
• Multiple winners
– State awards contract to several bidders
• Multiple Award Schedule (MAS)
– State awards contract for same goods and services to
multiple vendors that can serve the same population
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
111
Contracts
State Master Contracts
• Only applies to state agencies, state procurement
• Multiple winners always require vendor selection justification
• If multiple vendors can provide the services to you, then you
must conduct a mini-bid based on FCC rules.
– Do not need to file another Form 470
– But comply with all FCC Rules regarding vendor
selection (i.e., most cost effective, price must be
primary, cost-effectiveness)
• Contract Award Date = Date you decided to purchase off State
Contract.
– Memorialize your decision to purchase off a State Contract
in an email to yourself or the file.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
112
Contracts
State Master Contracts
• If a State Master Contract expires either before the
funding year starts or during a funding year, you may
be able cite a State Replacement Contract (SRC) on
your FRNs.
• Form 470/Contract requirements:
– Existing State Master Contract posted on a State Form 470
– Replacement State Master Contract posted on a State
Form 470
• USAC can make commitments using the SRC SPIN,
but cannot pay invoices until a SPIN change to “real”
provider has been processed.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
113
Pre-Commitment
Paying Non-Discount Share
• There is still no free lunch
• Applicants will always have to pay at least 10% or more
depending on their discount
• Service providers cannot give the money (directly or
indirectly) to pay for the non-discounted share
– Funds cannot come from the service provider or an entity
controlled by the service provider where funding is
contingent upon selecting that provider.
– Service provider bills can’t be ignored or waived.
– If applicant can’t show proof of payment during invoice
review; invoice may be denied.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
114
Pre-Commitment
Budget Review
• Purpose is for applicant to show us they can fund their
share
• Operating budget (or draft) has dates that cover the
funding year (July – June)
• Budget documentation should clearly identify applicant’s
share (e.g., expense line item)
• Can provide letter for reasonable expectation that funds
secured by 7/1
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
115
Pre-Commitment
Necessary Resources
• Check applicant’s certification that they have them.
– Are there end user computers?
• Must have reasonable plans to fully utilize all
internal connections for which you are requesting
discounts (e.g., 2-year plan to get computers for all
network drops)
– Do they have software to run on the computers?
– Staff trained on how to use the technology?
– Electrical capacity?
– Can they maintain the eligible and ineligible
equipment?
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
116
Pre-Commitment
Certifications Forms 470 & 471
• Applicants certify that:
– Have secured access to necessary resources
– Have complied with all FCC, state and local competitive bidding and
procurement regs
– Non-discount portion of the costs for eligible services will not be paid
by the service provider
– No kickbacks were paid to anyone and that false statements on this
form can be punished by fine or forfeiture
– Failure to comply with program rules could result in civil or criminal
prosecution
– Persons who have been convicted of criminal violations or held civilly
liable for certain acts arising from their participation in the program
are subject to suspension and debarment from the program
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
117
Pre-Commitment
Certifications Forms
• Service Providers certify that:
– For SPIs, services have been billed to customers on behalf of eligible
entities and for eligible services, and exclude charges already invoiced
– SPs, if asked, must provide detailed cost breakouts of services to
applicants
– They may be audited
– Prices were arrived at independently, without communicating with
other bidders regarding pricing, intent to bid and how you determined
your pricing
– Their prices won’t be disclosed to another bidder before the bid
opening
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
118
Pre-Commitment
Heightened Scrutiny
• May include review of:
–
–
–
–
Budget
Necessary Resources
Competitive Bidding and Contracts
Targeted questions based on potential violations
• Selective Review Information Request (SRIR) contains some of
the questions we may ask
• These reviews will take additional time and will hold up
commitments until they are completed
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
119
CIPA Compliance
Children Internet Protection Act requirements:
– Proof of public notice of public meeting or hearing
– Proof of public meeting or hearing
– Copy of Internet Safety Policy
– Technology protection measure
• Applicants must be CIPA compliant when receiving Internet
access in the telecom service category
Documentation Tip:
– Must maintain documentation from prior years if it
supports current funding year
– Filter documentation examples: maintenance logs, filtering
logs, proof of purchase or vendor filter description
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
120
Post-Commitment
Payment Plans
• Are NOT Allowed
• Applicants are required to pay their share at the
same time that USAC pays the discount amount
– Service Provider certifies that the invoices they submit
are for services that “have been billed to service
provider’s customers.”
– Deferred payment plans that allow the applicant to
pay after USAC has paid will jeopardize a funding
request.
– FCC Rules include a presumption that the nondiscount share will be paid within 90 days.
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
121
Post-Commitment
Service Delivery
• Service providers and applicants should work
together to facilitate delivery of service
• Monitoring receipt of service
– Both parties (SP and applicant) should monitor delivery of
service
– Don’t rely on the other party’s records
– Keep documentation of service delivery and any service
interruptions
– Applicants get Quarterly Disbursement Report
– Applicants may request Invoice Check
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
122
Post-Commitment
Invoice Review
• SP/App must review BEAR/SPI to ensure:
– Only eligible services are being billed
– Only services that were approved on the Form 471 are
being billed
– Services were delivered consistent with the FCDL and
any agreements
– Any service interruptions are accounted for
• Credits or discounts are apportioned to both USAC and
the applicant
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
123
Document Retention
• Document retention timeframes:
– 5 years from last date to receive service
• FY 2011 – this is at least June 30, 2017
– Any document from a prior year that supports current
year must be kept until 5 years from last date to
receive service as well
– E.g., Contract from 2005, used to support FY 2011
FRNs, must be kept until at least June 30, 2017
• Documents may be retained in electronic format or
paper
• Must maintain documentation from prior years if it
supports current funding year
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
124
Document Retention
Retain documents to show your compliance:
• Letters of Agency and any agreements with all
consultants
• Technology Plan (dated draft and final approved version)
and CTPA Plan Approval letter
• RFP, including evidence of publication date and any
solicitation you did
• Any and all bids (winning and losing), competitive bidding
correspondence, notes, memo, etc
• Email to yourself if you get no or one bid
• CIPA documents
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
125
Document Retention
Retain documents to show your compliance:
• Consortium Letters of Agency or contracts with the
consortium leader
• Compliance review documents (PIA, TPA, CIPA, Invoice)
• Signed and dated contracts
• Invoices, bills
• Asset registries, inventory logs
• Also, see further list on USAC website
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
126
Document Retention
Service Providers must retain:
– Copies of your bids
– Contracts signed with applicants
– Correspondence with applicants regarding bidding
process
– Proof of delivery of the service
– Documentation of any service down time
– Logs of maintenance performed
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
127
Document Retention
• Applicants must retain all documents that show
compliance with all FCC rules
• See complete lists:
– Documentation Retention Requirements
– Documentation Checklist
– E-Rate Binder Table of Contents
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
128
Questions?
Excerpted from 2010 Schools & Libraries Fall Applicant Trainings
129