E-rate - Get those dollars back to Arizona! Process overview

E-rate - Get those dollars back to Arizona! Process overview
Brett Hinton AZ Dept. of Education Mala Muralidharan AZ State Library Archives and Public Records Modified from Train-the-Trainer Workshops Video Tutorials at

Overview General information about E-rate Technology planning
Request services (Form 470) Competitive bidding Choose/contract for services (Form 471) Application review & funding commitments Start services (Form 486) Invoice USAC (Form 472 or Form 474)

General information Federal Communications Commission (FCC), an independent U.S. government agency, oversees the E-rate program Universal Service Administrative Company (USAC), a not-for-profit, administers E-rate along with three other programs Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-rate

General information FCC sets rules and policies through orders
Rules are compiled in the Code of Federal Regulations (CFR) Policies are defined in the text of orders USAC/SLD sets procedures for specific actions, such as how to process applications USAC sends its procedures to the FCC for approval each year

E-rate? What is it? E-rate Program provides reimbursements to eligible schools and libraries for Telecommunications Services Internet Access, Internal Connections Basic Maintenance Applicants must apply each year Reimbursements are based on the poverty level and the maximum one can get back is 90% of your billed amount Funding cap each year is $2.25 billion 5

FCC USAC Schools Vendors Library $2.25 Billion Funding Waves
Telecomm Internet Internal connections IC Maintenance FCC $2.25 Billion USAC Funding Waves Submitted each Quarter Schools Library Vendors

Timetable Form 470: File from April before the Window to 28 days before the Window closes Form 471: Must be filed during the Window, generally mid-November to early February before the start of the funding year Funding waves: Groups of funding decisions issued after USAC review – waves generally start in April before the start of the funding year Invoices: Can file after services are received for the funding year. Examples Recurring services – monthly telephone or internet bill Non-recurring services – installations, equipment, wiring (things that happen once) July 1 – Sept 30 – good time for installation b/c schools are closed during the summer

General information Who can apply? Schools and school districts
Libraries and library systems Consortia – groups of eligible entities that band together to aggregate demand and negotiate lower prices

General information How large are the discounts on eligible products and services? Discounts: 20% to 90% of eligible costs Discount for a school or library depends on: Percentage of eligibility of students for National School Lunch Program (NSLP) in: (for a school) the school (for a library) the school district in which the library is located Urban or rural location of the school or library

General information What services are eligible?
Priority 1 (funded first) Telecommunications Services Internet Access Priority 2 (funded beginning with neediest applicants first) Internal Connections Basic Maintenance of Internal Connections We’ll talk about a few examples of what P1 and P2’s are in the next slide But we fund all P1’s first and then move to P2’s starting w/the S&L that qualify for a 90% discount and we go down by 1%, so to 89% and so on until we run out of money – for example in FY 2007 we funded P2’s from 81% and above, and have denied at 80% and below

General information How do I file a program form?
In general, you have three options: File online, certify online File online, certify on paper File and certify on paper USAC encourages you to file online Online filing speeds processing and reduces errors

What is sent ……and received
Applicant to USAC -> Letters received from USAC Technology plan created but not sent Form 470 Form 471 Form 486 Form 472 Receipt Notification Letter (RNL) Receipt Acknowledgment Letter (RAL) Funding Commitment Decision Letter (FCDL) Form 486 Notification Letter (486NL) BEAR Notification Letter — Form 472 only 12

1. Technology planning You must write a technology plan that contains the following elements: Goals and strategies for using technology to improve education or library services Staff training/ Professional Development Needs assessment Budget Evaluation plan Note: if you are only requesting basic telephone service, a technology plan is not required

Necessary Resources Does the applicant have the resources needed to provide the service Are there end user computers? Must have reasonable plans to fully utilize all internal connections for which you are requesting discounts Do you have software to run on the computers? Staff trained on how to use the technology? Electrical capacity? Can you maintain the eligible and ineligible equipment?

Budget This is an important part of the Tech plan and the purpose is to show USAC that the applicant can fund their share Operating budget (or draft) has dates that cover the funding year (July – June) Budget documentation should have clear expense line items not all bundled together If budgets are not passed at that time, can provide letter for reasonable expectation that funds will be secured by 7/1

Non-Discounted portion
Obligation to Pay Non-discount Share Applicants are required to pay their share of the cost (the “non-discount” portion or share) — this share cannot be donated, forgiven or ignored. Service providers cannot waive or credit the applicant’s share. Service provider must bill the applicant for non-discount share of services. If applicant can’t show proof of payment during invoice review; invoice may be denied. Deferred payment plans that allow the applicant to pay after USAC has paid will jeopardize a funding request. 16

Free Goods and Services
Applicants and service providers are prohibited from using E-rate to subsidize the procurement of ineligible or unrequested products and services E-rate cannot be used to get free stuff or kick-backs. The value of ineligible products that are needed to run the service have to be backed out in your vendor selection process. Cost of eligible goods and services cannot be inflated to cover the“free” ineligible stuff

Technology plan approval
Technology Plan Approver (TPA) – the agency certified by USAC that approves your technology plan It has to be written (drafted) before the filing of the Form 470, finalized and approved before the start of services. Can be multi-year but major changes have to be re-approved

Tech Plan Validity Year 1 Year 2 Year 3 Approved
Tech plan submitted for approval Approved Must submit another plan No longer valid for E-Rate Major change occurs between approved years 1 & 2 Tech plan drafted

Technology Planning: Do’s and Don’ts
draft your technology plan before Form 470. verify that it contains all five required elements. make sure your technology plan covers at least 12 months make sure that your technology plan approver is certified by USAC. verify that plan is approved before services begin and before your Form 486 is filed. PRINT A COPY of your Tech Plan for your records. PRINT A COPY of your approval for your records. DO NOT ask the service provider direct advice on technology planning. 20

Questions? 21

2. Request services (470) You post a Form 470 to:
Open a competitive bidding process Notify potential bidders (service providers) of the types and quantities of services that you need Define the scope of your needs (e.g., a school building, a library system, a state network)

2. Request services (470) Acronyms and terms
Billed Entity Number (BEN) – an identification number assigned by USAC to each school or library building Personal Identification Number (PIN) – a code assigned by USAC to applicants for use in certifying program forms online USAC issues a PIN to every new authorized person filing a paper Form 470, 471, or 486 Request for Proposals (RFP) – a bidding document (not required by E-rate) that provides detailed information about your services, locations, bid submission requirements, etc. Allowable vendor selection/contract date (ACD) – the date 28 days after the Form 470 is posted to the USAC website

3. Competitive bidding When you open a competitive bidding process for your services: Potential bidders have the information from your Form 470 and RFP and can respond to your requests You must ensure that the competitive bidding process is open and fair You must be prepared to evaluate bids

3. Competitive bidding After you close the competitive bidding process for your services (on or after the ACD): You can evaluate the bids received You can choose your service provider(s) You can sign a contract You can post a Form 471 Price as the primary factor – In evaluating bids, the price of the eligible products and services must be the most heavily-weighted factor in your evaluation of bids

Calculate the discounts
Reimbursements are based on Discounts calculated using Percentage of students eligible for National School Lunch Program (NSLP) Urban or rural status of county in which school or library is located (see USAC web site) These two pieces of information are carried into the Discount Matrix

4. Choose services (471) You post a Form 471 to:
Report information on the service providers and services you have chosen Provide a list of the schools and libraries that will receive services Include discount calculation information including student NSLP counts Certify your compliance with program rules

4. Choose services (471) Acronyms and terms
Funding Request Number (FRN) – the identification number assigned to a Form 471 Block 5 funding request Service Provider Identification Number (SPIN) – the identification number assigned by USAC to a service provider Service providers may have more than one SPIN in order to identify separate business units, different states in which they operate, etc. Non-instructional facility (NIF) – a school building with no classrooms or a library building with no public areas NIFs are eligible for Priority 1 services NIFs are eligible for Priority 2 services only if necessary to provide effective transport of information to classrooms or public areas of libraries

4. Choose services (471) Item 21 Attachment (Item 21) – the description of services associated with a funding request (Item 21 on Form 471) Item 21 attachments can be submitted online or on paper USAC encourages online filing, especially for simpler applications Form 471 Receipt Acknowledgment Letter (RAL) – a letter issued by USAC to the applicant and the service provider that summarizes the information provided in the Form 471 Many of the entries on the form can be corrected after submission by using the RAL

5. Application review USAC reviews your Form(s) 471 to:
Check the eligibility of the schools and libraries and their discount levels Verify that the services you requested are eligible for discounts Give you an opportunity to make allowable corrections to your form In some cases, ask for additional verification of your compliance with program rules Program Integrity Assurance (PIA) – the USAC group that reviews and makes funding decisions on program applications Funding Commitment Decision Letter (FCDL) – a letter issued by USAC to the applicant and the service provider that contains commitment decisions on funding requests

6. Start services (486) You post a Form 486 to:
Notify USAC that services have started and invoices for those services can be processed and paid Provide the name of the TPA that approved your technology plan Report your status of compliance with CIPA Acronyms and terms Form 486 Notification Letter – a letter issued by USAC to the applicant and service provider after a Form 486 has been processed Children’s Internet Protection Act (CIPA) – a law with specific requirements on Internet safety policies and filtering TPA Tech plan approver

7. Invoicing USAC (472/474) Applicants have a choice of two invoicing methods to receive discounts on eligible services: Billed Entity Applicant Reimbursement (BEAR) Form 472 Service Provider Invoice (SPI) Form 474 BEAR Form is filed by the applicant and approved by the service provider after the applicant has paid for the services in full SPI Form is filed by the service provider after the applicant has been billed for the non-discount portion of the cost of eligible services Acronyms and terms BEAR Notification Letter – a letter issued by USAC to the applicant and service provider after a BEAR has been processed Quarterly Disbursement Report – a report issued to the applicant detailing all invoicing activity (BEARs and SPIs) during the previous quarter

Questions? Break- Time!

Eligibility and Eligible Services List

Eligibility - Schools Must meet the statutory definition of elementary or secondary school found in the No Child Left Behind Act of 2001. Must be a non-profit institutional day or residential school, including a public charter school, that provides elementary or secondary education, as determined under state law eg Pre-kindergarten( Sp Ed. Only), Adult Education, Juvenile Justice students facilities may be eligible. Must not have an endowment exceeding $50 million. USAC requests updated eligibility information from state departments of education every two years. 35

Eligibility - Libraries
Must meet the statutory definition of library or library consortium in the Library Services and Technology Act (LSTA) of 1996. Must be eligible for assistance from a state library administrative agency under LSTA. If they are a joint use facility (school + public library) each can apply separately for their portions provided budgets are completely separate. Must not operate as for-profit business. 36

Eligibility - Consortia
Eligible schools and/or libraries may form consortia with Other eligible schools and/or libraries Certain health care providers Public sector (governmental) entities Helps bring the prices down May even help bring higher band-width or better service May bring more competition to your area BUT – Only eligible entities can receive discounts Be careful about consortial applications – not easy to administer there are consequences and responsibilities. 37

Eligible Services - Priority 1
Priority 1 – funded first Telecommunications Services Basic telephone service — wireline or wireless phone service (local, cellular/PCS, and/or long distance); Voice over IP- PBX and Centrex; Radio loop Internet Access Basic conduit access to the Internet including but not limited to: Broadband over Power Lines (BPL), Cable Modem, Digital Subscriber Line (DSL), Satellite T-x, DS-x, OC-x . service, and web hosting 38

Eligible Services – Priority 2
Internal Connections (switches, hubs, routers, wiring, cabling) Basic Maintenance on Internal Connections NOTE: End user equipment - such as computers, monitors, or phone sets - is NOT eligible Priority 1 funded first, then Priority 2 begins with neediest applicants (90% first, then 89%, 88%, etc.). Internal Connections funded in only two out of five funding years. 39

Special Eligibility Conditions

Internal Connections Example 1

Internal Connections Example 2

Classroom Internal Connections

Classroom Internal Connections Ex. 2

On-Premise Equipment 1 This leased router may be eligible for P1 funding if all conditions are met. Single demarcation – If the router is removed, the LAN would continue to function.

On-Premise Equipment 2 This leased router is NOT eligible for P1 funding. Multiple demarcations – If the router is removed, the LAN would cease to function which violates program rules for Priority One eligibility. Router may be eligible in IC.

Internal Connections Maintenance
Ensures the necessary and continued operation of eligible internal connection components at eligible locations. Ex: Repair and upkeep of eligible hardware, wire and cable maintenance, and configuration changes. Basic technical support of eligible hardware is Eligible but end-user support such as a student calling a help desk for technical assistance is NOT Eligible. BMIC is a Recurring service - Delivery must be within July 1st – June 30th BMIC is exempt from the Two-in-Five rule

Must be for Educational Purpose only
Activities that occur on library or school property are presumed to be integral, immediate, and proximate to the education of students or the provision of library services to library patrons and therefore qualify as educational purposes. Customary work activities of employees of a school or library are presumed to fall under the definition of education purposes. 48

Non-instructional Facilities
Non-instructional facilities are school buildings with (few or) no classrooms or library buildings with no public areas Non-instructional Facilities Eligible for Priority 1 services Telecommunications Internet Access Eligible for Priority 2 services only if the services are essential for the effective transport of data to classrooms or public areas of a library School examples: Administration buildings Bus barns Athletic stadiums Library examples: Administration buildings Bookmobile garages Technology centers

Non-instructional Facilities (NIFs)
NIFs can receive Priority 1 services. Examples are SCHOOLS: Administrative buildings School bus barns and garages Cafeteria offices Facilities associated with athletic activities Teachers accompanying students on a field trip LIBRARIES: Administrative buildings Bookmobile garages Interlibrary loan facilities Library technology centers NIFs – Priority 2 NOT eligible unless it is essential for the effective transport of information to an instructional building of a school or to the patrons of a library. 50

Eligibility- Service Provider
What should you know about your Service Providers Must be an authorized Telecom Carrier and supply on a common carriage basis. Must file form 498 (Service Provider Information Form) Must have a Service Provider Identification Number (SPIN) Must file Form 473, Service Provider Annual Certification (SPAC) Form Must contribute to the Universal Service Fund. 51

Website and Links Questions? Eligible Services List
Questions? 52

What are we? Telephone Handsets Switch
What are the following services? P1, P2, or Not Eligible Telephone Handsets Switch Internet Access Router Cabling VOIP Not Eligible P2 P1 P1 / P2 P2 P1 / P2 53

Calculating Discounts
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Overview Basic discount calculations Alternative discount mechanisms
Non-instructional facilities Snapshots New construction

Basic Calculations E-rate discounts depend on:
The percentage of students eligible for the National School Lunch Program (NSLP) or an equivalent measure of poverty The urban or rural status of the county or census tract in which the school or library building is located USAC may request third-party verification of student counts submitted by applicants

Discount Matrix Percent of Eligible Students Urban Rural Less than 1%
20% 25% 1% - 19% 40% 50% 20% - 34% 60% 35% - 49% 70% 50% -74% 80% 75% -100% 90%

Basic Calculations Individual school calculation:
Calculate the percentage of students eligible for NSLP in that school Use the urban or rural status of the county or census tract in which the school is located School district calculation: Calculate the E-rate discount for each individual school in the school district Calculate the weighted average discount For each school, multiply the E-rate discount by the total student population of the school (the weighted product) Add all weighted products and divide by the total number of students in the school district

Basic Calculations Library outlet/branch calculation:
Calculate the total percentage of students eligible for NSLP in the school district in which the library building is located Use the urban or rural status of the county or census tract in which the library outlet/branch is located Library system calculation: Calculate the E-rate discount for each library outlet/branch in the library system Calculate the simple average discount Add together the discounts for the outlet/branches and divide by the total number of outlets/branches Consortium calculation: Calculate the E-rate discount for each individual member of the consortium Calculate the simple average of all the member discounts

Alternative Mechanisms
Head Start (NSLP) Head Start is a federal program that provides comprehensive developmental services for low-income children ages three to five Head Start students meet free lunch guidelines under NSLP, so Head Start entities automatically qualify for 90% discount Children under age three are never considered eligible and must be cost-allocated out Home based Head Start is not eligible Direct certification (NSLP) State social services agency works with local educational authority to directly certify students for NSLP based on household participation in other poverty-based programs USAC will accept the student counts determined using this method if the school can demonstrate participation in direct certification

Alternative Mechanisms
Other alternative discount mechanisms measure a level of poverty in a household equivalent to that required by NSLP Income Eligibility Guidelines (IEGs) are published each year by the U.S. Department of Agriculture (USDA) Students from households whose income is at or below 185% of the federal poverty guideline are eligible for the NSLP Examples Medicaid, Food stamps Supplementary Security Income (SSI) Section 8 (federal public housing assistance) Low Income Home Energy Assistance Program (LIHEAP) Other programs can be used as mechanisms ONLY IF their requirements are at least as stringent as IEGs Examples of programs that do not automatically qualify Temporary Aid to Needy Families (TANF) Title 1 eligibility, Scholarship programs

Alternative Mechanisms- Survey
Applicants can conduct surveys to establish eligibility (see sample survey on USAC website) Survey requirements: Must be sent to all families whose children attend the school Must contain names of family and students Must contain size of family Must contain income level of family Data must not be more than two years old Surveys can request information on household income level or participation in eligible alternative mechanisms or both With one exception, applicants must be able to provide data on an individual student basis Exception: if a school sends a survey to the households of all of its students and at least 50% of the surveys are returned, the school may project a percentage of eligibility based on the percentage of eligibility in the returned surveys Retain copies of all surveys for your records

Other Sources Applicants can match siblings or collect data from other existing sources Example: if a elementary school student from a household participates in NSLP, an older sibling in that household can be counted as eligible Multiple entities Discount is based on the total enrollment for the entity and NSLP data and each location receives the same discount Obtain an entity number for each facility if the facility has a different address or a public right-of-way crosses the campus Maintain adequate documentation

Non-instructional Facilities
Discounts for NIFs without classrooms In general, the discount for a NIF on the same campus as a school or library is the same as the discount of the school or library A NIF shared by more than one school in a school district or library in a library system is eligible for the shared discount for that school district or library system

Non-instructional Facilities- snapshot
Separate NIFs (not a part of the campus) that are used by a class should use the snapshot method Choose a specific day Determine the percentage of students eligible for NSLP for the student population that attends class on that day Use that percentage and the urban/rural status to find the discount in the Discount Matrix Save your documentation

New Schools and Libraries
Is it really a new school or library? Does the State consider this a replacement facility for the same school or library? If yes, use current discount information Does the State consider this a new school or library? If yes, the may use New School Construction guidance

New Constructions If a school is under construction –
If the student population is known, use the percentage of NSLP eligibility of those students to calculate the discount If not, do a pre-enrolment survey If a library is under construction – Use the discount for the school district in which the library building is going to be located Charter and Private Schools If population is unknown use 20% discount . You cannot use school district average If population is known - Must be able to provide supporting documentation. Use that data to calculate discount rate

Questions?

Form 470 & Competitive Bidding
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Competitive Bidding / 470 Filing Form 470 opens a competitive bidding process, which is fair and open. The Goal is to have a healthy competition to promote better service and lower prices Avoid conflicts of interest Independent consultant Service Provider Applicant  Service Provider 70

Competitive Bidding / 470 Fair and open process
All bidders treated the same No advance knowledge of RFP information No secrets in the process All bidders know what is required of them including the selection criteria. Follow all rules – FCC and state/local 71

Pre-bidding Discussions
Applicants may: Discuss their product offering with SPs Learn about new technologies from SPs Applicants may NOT accept/use the following from service providers: Vendor-specific language for RFP or the 470 Template RFPs or Forms 470 Assistance with tech plan Assistance with RFP

Vendor Involvement Service providers cannot:
Determine the types of service the applicant will seek on a Form 470 Assist applicants with the filling out of the FCC Form 470 which requires an applicant’s certification Influence or run the competitive bidding process for the applicant Be privy to information about the bid not shared with other potential bidders

Competitive Bidding / 470 Request for Proposal (RFP)
Not required under FCC rules, but a good practice Must comply with local and state procurement laws (check for limits on sealed bid requirements etc.) Describes your project scope, location, other requirements in detail Even if you have an RFP, you must describe the services you desire on your Form 470. 74

Competitive Bidding / 470 Form 470
Must indicate a multi-year contract or contract with extensions if appropriate. Must list services sought in the correct category of service. If you are not sure put it in both categories (Telecom and Internet). You can decide when doing Form 471 Must indicate if it is for a single entity or multiple entities and if there are likely to be changes in the middle of the contract period 75

The 28 day rule RFP handed out at walk through
WAIT 28 DAYS after your Form 470 is posted and your RFP is issued before you evaluate the bids No hard deadline for filing Form 470 but is based on Form 471 window closing RFP handed out at walk through 28 day clock starts after last of the RFP issued Clock for 28 days restarts when If you issue a new RFP, then your 28 days starts again (do not have to post a new 470) Changed services sought Make other cardinal changes to RFP Post new Form 470 76

Qualifying factors Qualification Factors Disqualification Factors
Can require that potential bidders meet minimum number of qualification factors Disqualification Factors Can require that potential bidders that meet any disqualification factors are not considered Ensure that all potential bidders have adequate notice of these items If no bids received after 28 days, you may contact vendors to seek bids

Sham bid process “I want to stay with my incumbent”
Avoid appearances of a “done deal” Must respond to all legitimate inquiries. Need not respond to spams Cost to transfer to another provider alone is not by itself a good enough reason to stay with incumbent, but can be one of the bid evaluation criteria 78

Competitive Bidding Retain your documentation
If you wait until the last date to file a Form 470, the following must all occur on the last day of the window for Form 471: Bid Evaluation Selecting a service provider Signing and dating a contract Submitting Form 471 online or mailing the manual paper copy Certifying, signing and dating Retain your documentation Retain, retain, lessen your pain 79

Competitive Bidding / 470 – Tips
Retain worksheets, bid evaluation criteria, winning AND LOSING bids Prepare a memo to file if you received only one bid or no bids File online to reduces errors and speed processing Read the contract’s fine print Personal Identification Numbers (PINs) Will be automatically issued to any new authorized persons filing Forms 470, 471 and 486 after at least one wet signature. Do not use the pin that was issued to a former staff (Pins are electronic signature of the individual) 80

Competitive Bidding / 470 Form 470 Receipt Notification Letter (RNL)
Cover page of important reminders Notifies applicant that Form 470 has been posted to the USAC web site Contains Allowable Vendor Selection / Contract Date (ACD) Use the calendar tool on the website rather than calculating it yourself. Remember if you posted your RFP after posting form 470 – you will have to wait 28 after posting the RFP even if you have a ACD on your RLN. 81

Questions? Video Tutorials at 82

Vendor Selection, Contracts, & Form 471
83

Selecting a vendor Applicants must choose the most cost-effective solution to their Form 470 or RFP. Price has to be the primary factor – the one with the most weightage (next slide) See Rubric on how to do the bid evaluation(Handout) Bid evaluation process should be carefully documented and filed - winning and losing bids If only one bid or no bids are received – make a memo for your files 84

Vendor Selection Applicants must retain all vendor selection documentation This includes winning and losing bids Price of the eligible goods and services must be the primary factor in all rounds Applicants determine remaining vendor selection criteria and relative weighting USAC sample evaluation matrix available

Cost-Effectiveness Solution must be cost-effective
Routers priced at two or three times greater than the prices available from commercial vendors would not be cost-effective, in the absence of an explanation of extenuating circumstances. Receiving only one bid does not automatically make it cost-effective Service Providers may work with the applicant to help them understand the technical needs for this expensive solution.

Selecting Factors 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

USAC bid evaluation template
88

Contracts Once you have selected your vendor applicants and service providers must sign contracts for services that are not provided under tariff or month-to-month arrangements Contracts have to be signed by the applicant before filing form 471 It is a good practice for the applicants to get the vendors to sign the contracts too, to make it legally binding. Contracts can cover more than one year or contain extensions, but applicant must indicate these options in the Form 470. TIP: You may want to add some contract language that allows the contract to be extended into another program year in the event you are awarded late in the funding cycle and an opt out clause in case of funding denial 89

Funding Requests / 471 Form 471 Provides specific information on services, service providers selected, and contracts Provides discount calculation information Details itemized services – item 21 attachments Must be filed for each funding year even if you do not do a Form 470 Contains certifications of compliance Has a hard deadline date. You can do multiple form 471s (Block 5s ) by breaking it out. File Priority 1 and Priority 2 requests separately. Review of Priority 2 requests may hold up Priority 1 commitments 90

Funding Requests / 471 Form 471 Deadline Must be filed online or postmarked on or before the close of the Form 471 application filing window. (midnight Eastern on the date of the deadline). Be prepared for a logjam and software timeouts closer to deadline. Good practice to file Certifications for associated Forms online or postmarked by deadline. Certifications and Item 21 attachments are accepted even after the close of the window. 91

Funding Requests / 471 Work with your service provider
Remove ineligible costs from funding requests Document ineligible costs carefully and cost allocate it out 30% rule – if 30% or more of the dollar value of the request is for ineligible products, services, or entities you will get called during PIA review and asked to remove it. Work with your service provider to help you unbundle the services and products to break out eligible and ineligible costs to create your Item 21 attachment(s) 92

Funding Requests / 471 Enter recurring and non-recurring costs carefully in the cost summary of each Funding Request Recurring costs ALWAYS must be received by June 30 of the Funding Year. Non-recurring costs must be received by September 30 following the Funding Year, and this deadline can be extended under certain circumstances 93

Funding Requests / 471 Form 471 Receipt Acknowledgment Letter (RAL)
Cover page of important reminders Provides confirmation of certain information entered from Form 471 Data entry errors may be corrected within three weeks by using the RAL (including Block 4 worksheets) Applicants can request funding changes 94

Questions? Video Tutorials at 95

PIA Review 96

Application Review - PIA
All Forms 471 are reviewed by Program Integrity Assurance for compliance with program rules concerning areas such as: Competitive bidding process, contracts, discount calculation, sufficient budget, establishing form 470, Technology plan, CIPA Some errors can be corrected during PIA review but not all. All certifications and attachments (esp item 21) will be scrutinized. 97

PIA Reviews Initial & Final Review Applications always start in Initial Review. Reviewer contacts the applicant with questions, gives them 15 days to answer. Final Reviewer reviews the Initial Reviewer’s comments. Quality Assurance (QA) Review Some Form 471 applications are selected for QA review QA has Initial and Final review levels as well 98

Clerical Corrections Bishop Perry Order allows applicants to make corrections to Forms 470 & known as ministerial & clerical corrections. Applicants have additional time to certify Forms 470 & 471, make corrections that do not require the Form 470 to be reposted or the Form 471 to be re-filed, and do not violate FCC regulations and/or program rules. USAC, with FCC guidance, developed a list of correctable items. List of Correctable M & C Errors Subsequent FCC Orders issued identified more corrections allowable during PIA review.

Clerical Corrections Examples:
Entered the incorrect amount (i.e., data entered $100 instead of $1,000) Omitted an entity from the Block 4 Provided the incorrect Form 470 number on the Form 471 Selected the wrong category of service Submitted an unsigned contract to PIA Omitted an FRN Did not include all of the required elements in the written tech plan

PIA Review : Tips Provide information to PIA promptly
Work with your service provider to comply with information requests. Make sure your answers respond completely to the questions asked. Ask for more time to respond if you need it. However, if you ask for more time, your PIA representative will work on other applications and you may wait longer for a decision. Ask for everything in writing, respond in writing Check the 471 Application Status Tool on the web. 101

Deadlines, Deadlines 15 Day Rule
PIA corrections MUST be submitted 20 calendar days (5 days for mail receipt + 15 days) from the date of USAC’s letter Receipt Notification Letter (RNL) – 470 Receipt Acknowledgment Letter (RAL) – 471 Mail, or fax corrections to USAC RAL doesn’t contain Block 4 information, so include the corrected Block 4 worksheet with your RAL corrections 7 day reminder

RNL/RAL Corrections Corrections submitted after the deadline in the letter: Requests to increase funding will not be granted. PIA will work with applicants to make clerical error corrections until the FCDL is issued PIA will request documentation to support the correction, such as contract, invoice, bill, etc.

PIA Identified Changes
Errors may be detected during PIA review PIA may contact you and allow corrections if they find certain discrepancies: Item 21 doesn’t match Block 5 Discount for single entity doesn’t match discount reported on different application Item 21 includes entities missing from your Block 4 Tech Plan is missing one or more required element(s)

Funding Commitments After PIA review is successfully completed you get a Funding Commitment Decision Letter (FCDL) Cover page has important date-reminders Reports status of individual funding requests: Funded Not funded As yet unfunded (Priority 2 requests) May receive more than one FCDL Check all entries on the FCDL carefully to make sure there are no data entry errors. Use the information on the FCDL to prepare your Form 486. 105

Questions? 114

Start of services Form 486 and Invoicing Form 472/474

Starting Services / 486 Notifies USAC that services have started and invoices can be paid Certifies that Tech Plan (if required) meets program requirements. CIPA compliance – file proof of Internet safety policy Public notice or meeting Technology protection measure (filter) CIPA does not apply to Telecom Services Local and Long distance. But if you apply for cell phones and blackberries or any data transmission services – you must be CIPA compliant 108

Form 486 Notification Letter (486NL)
Starting Services / 486 Form 486 Deadline Form 486 must be filed no later than 120 days after the Service Start Date OR 120 days after the date of the FCDL whichever is later. If you file late your funding commitment will be adjusted to reflect the new start date corresponding to 120 days before the filing date. Form 486 Notification Letter (486NL) USAC will accept invoices once the Form 486 is certified. 109

Invoicing BEAR or SPI? Why?
Why would you choose one or the other? Form 472, Billed Entity Applicant Reimbursement (BEAR) Form Applicant pays for services in full and then requests reimbursement from USAC The form is submitted through the SP and they have to certify the invoices Form 474, Service Provider Invoice (SPI) Form Service provider discounts customer (applicant) bills and then requests discount amount from USAC The applicant pays only the non-discounted share 110

How do reimbursements or BEARs work?

How do discounted bills or SPIs work?

Review of Invoices Service providers and applicant must review BEAR/SPI to ensure: Only eligible services are being billed Only services that were approved on the application are being billed Services were delivered consistent with the FCDL and any agreements Any service interruptions are accounted for Follow through and ensure that Service providers sign off all months and all invoices

Invoicing / 472 or 474: TIPS Form 472 (BEAR Form)
DO NOT wait till the last day to file. Remember that the Service provider has to sign off on these. DO keep checking that your service provider has signed off on your 472 online DO check your calculations. Do make sure you have paid your non-discount share. Invoicing deadlines Form 472 or 474 must be filed online or postmarked no later than 120 days after the last date to receive service Can be monitored online to ensure that vendors have certified. File for invoice extension if needed You will receive a BEAR Notification Letter after your BEAR filing read it to see if you have submitted successfully 114

Questions?

Program Compliance 96

Know Your Role Applicants
Write tech plan, 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 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 Consultants Follow the role of their client – either applicant or service provider

Certifications 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 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 violations in the program are subject to suspension and debarment from the program

Selective Review and Heightened Scrutiny
These reviews will take additional time and will hold up commitments until they are completed Selective Review Information Request (SRIR) contains some of the questions that may be ask May include review of: Budget Necessary Resources Competitive Bidding and Contracts Pattern Analysis Targeted questions based on potential violations

Document Retention Document retention timeframes:
5 years from last date to receive service FY 2010 – this is at least June 30, 2016 Any document from a prior year that supports current year must be kept until 5 years from last date to receive service as well Eg. Contract from 2004, used to support FY 2010 FRNs, must be kept until at least June 30, 2016 Applicants must retain all pre-commitment documents that show compliance with all FCC rules Emphasize the importance of documentation in getting through an audit. Feed your files – constantly Your ability to get through an audit as quickly and painlessly as possible depends on being able to provide the backup documentation. Help your successors Know the rules about how long to keep something. Very important to emphasize the second point. This is often a big reason why people get CIPA findings in their audits. Generally, schools did their Public Hearings many years ago, but the proof has gotten lost. During the audit, they are then unable to prove their compliance, it becomes a finding and we have to rescind funding. Can’t fix years past but you can fix the problem going forward by having a new hearing, creating and then saving the documentation.

Document Retention and Audits
Audits are done by an external agency to ensure compliance to rules, To ensure that there is no waste, fraud and abuse To ensure that there are no improper payments made. It is easier to keep track as you go along than to scramble when auditors are knocking on your door. Appearances are important If you are listed as the contact - you need to keep all documents – don’t expect the accounts to keep documents or archives to trace them for you. Applicants have been asked to pay back what they have received, sometime years later.

Retain, retain, retain Retain documents to show your compliance:
Letters of Agency and any agreements with all consultants Technology Plan (both draft and final approved version) and TPA Plan Approval letter RFP, including evidence of publication date and any solicitation you did Any and all bids (winning and losing) to yourself if you get no or one bid

Retain, retain, retain Applicants retain documents to show compliance:
Documents describing bid evaluation criteria and weighting Any correspondence with potential bidders Documents related to the selection of the service provider(s) Signed and dated copies of contracts Also, see further list on USAC website under document retention

Appeals USAC decisions can be appealed to USAC or to the FCC.
Generally, appeal first to USAC. Can appeal to the FCC if USAC does not grant the appeal. Can be filed electronically or on paper. Must be filed electronically or postmarked within 60 days of the USAC decision. Requests for waivers of rules must be filed with the FCC. 124

125 125

SL News Briefs Emailed each week Subscribe from website
Cover topics of current interest Archive of past issues Search by topic or date

Tip Sheets One-page high-level guidance documents on major program topics Contain links to guidance documents Available on website and during site visits

Video Tutorials and presentations
Viewing Options USAC Tutorials at Blip.tv – For slower connections; can be viewed by most browsers. USAC Blog – Higher quality; requires latest Flash player. USAC Tutorials at MotionBox – Higher quality. Click "View All" to see all available tutorials. You should have latest version of your browser, and select "SD - Standard Definition" if not already selected. Video Tutorials: Presentation slides:

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E-rate resources for AZ
Arizona Department of Education (ADE) Arizona State Library Archives and Public Records Arizona State Procurement Office (AZSPO) E-rate Central E-rate resource center 130

USAC Resources USAC Homepage http://www.usac.org/sl/
USAC Reference Page USAC tools USAC Outreach and Training Use the “Submit a Question” link on the web site Fax toll-free at Telephone toll-free at Always ask in writing and insist on a written response.

Brett.Hinton@azed.gov/ Brenda Wright 602-542-4214
AZ Contact Information Brett Hinton Brenda Wright Mala Muralidharan 132

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