Presentation on theme: "Presented by Julie Tritt Schell PA E-rate Coordinator Fall 2011 1 E-RATE TRAINING WORKSHOP FOR BEGINNERS FUNDING YEAR 2012 Happy 15 th Birthday, E-rate!"— Presentation transcript:
Presented by Julie Tritt Schell PA E-rate Coordinator Fall 2011 1 E-RATE TRAINING WORKSHOP FOR BEGINNERS FUNDING YEAR 2012 Happy 15 th Birthday, E-rate!
History and Program Administration Applicant and Services Eligibility Step-by-Step Program Requirements and Forms Additional Rules Morning break, if needed Questions at end of each section Lunch from 12 -12:30 * What does this mean? 2 AGENDA
School Districts IUs Charter Schools AVTSs Non-public Schools Libraries Superintendents/Asst Supt Business Managers Technology Directors Vendors Consultants 3 WHO IS HERE? Who is brand new to E-rate? Who NOT on PA E-rate listserve?
Telecommunications Act of 1996 established “Universal Service Discount Program for Schools and Libraries” Annual $2.25 billion program, adjusted for inflation Funding years named for the year in which they begin FY 2012 = July 1, 2012 – June 30, 2013 Provides 20-90% discounts on eligible services Fund made up from charges on your phone bills Not a typical grant program 4 WHAT IS E-RATE?
FCC Federal Communications Commission Created program and sets rules and policy USAC Universal Services Administrative Company Created by FCC to run E-rate and other universal service programs Pays invoices SLD Schools and Libraries Division Entity within USAC that runs E-rate Makes no policy decisions 5 WHO ADMINISTERS E-RATE?
Under contract with PDE to serve as PA E-rate Coordinator Provide outreach and training to schools and libraries in PA Represent PA before federal policymakers Maintain PA E-rate website and listserve Act as resource when E-rate administrator can’t help 6 WHAT IS JULIE’S ROLE?
Public libraries eligible for LSTA funding Public and private K-12 schools For-profit schools not eligible Pre-k eligible in PA (age 3+) Head Start entities eligible in PA but only if operated by a public school entity Cannot have endowment exceeding $50 million 7 WHO IS ELIGIBLE?
Residential locations within schools serving (beginning with FY 2011): tribal students children with physical, cognitive, or behavioral disabilities juvenile justice students, or residential schools where 35% or more of their students are eligible for NSLP Schools can be public or private and both Priority 1 and Priority 2 services are eligible Residential locations of cyber school students or employees are not eligible 8 ELIGIBLE RESIDENTIAL LOCATIONS
E-rate is not a short, easy process Read listserve messages Read form certifications Be prepared for an audit Stay organized! – USE THE BOX or BINDER! 10 FAIR WARNING!
Eligible Services List in Binder* 11 WHAT SERVICES ARE ELIGIBLE AND INELIGIBLE?
FCC established funding priorities because demand always exceeds cap of $2.29 billion Priority 1: Telecommunications and Internet Access All ‘services’ that are leased, and nothing that is purchased All approved-inside the window-likely to be funded, regardless of discount level Priority 2: Internal Connections and Basic Maintenance of IC Funds go first to neediest applicants (90% discount level), then to others in order of discount until funds are exhausted 12 FUNDING PRIORITIES
MUST be provided by an Eligible Telecommunications Provider (ETP) Local, long distance, voice mail, cell, paging, Centrex, T-1, PRI, frame relay, ISDN, etc. Installation of eligible telecom services (if included on your application) Including most taxes and surcharges and custom calling features Hosted VOIP* (also eligible under Internet) Lit fiber service (also eligible under Internet Access)* 13 P1: ELIGIBLE TELECOM SERVICES
Sharing of bandwidth to ineligible entities 900 calls Payphone service Cost of not-publishing phone numbers Cost of additional directory listings End user equipment (phones, beepers, cell phones, fax machines, etc.) Late fees or finance charges Paper statement fees Cost recovery fees Property tax fees 14 P1: INELIGIBLE TELECOM SERVICES
Eligible: Basic conduit access Hosted E-mail service Laptop aircard access Basic webhosting, including: discussion boards, blogging, instant messaging and chat Firewall fees – if part of standard vendor service Blackberry/data services (be sure to post separately from telecom on 470) Lit fiber service Dark fiber service Ineligible: Filtering Any remote access outside school property to Internet Broadcast messaging services AntiVirus/AntiSpam Ineligible webhosting features: content, website development costs, searchable databases or content, student attendance reporting, and grade books 15 P1: INTERNET ACCESS
Called On-Premise, Priority 1 Equipment Permitted if bundled with service from Telco or ISP Must tell SLD make/model of equipment Must certify to TN Test: No applicant ownership – ever No exclusive use LAN functions without use of equipment Service provider maintains equipment Not applicant (Answers on PA E-rate website) 16 EQUIPMENT ELIGIBLE TO BE BUNDLED*
Can be leased from telecommunications provider (such as Verizon, Comcast, Sunesys, Sting, etc) OR Beginning in FY 2011, can be leased from any other provider (such as electric company, cable company, regional network, etc) Post in both telecom and internet category on Form 470 17 LIT FIBER ELIGIBILITY
Beginning in FY 2011, applicants may lease dark fiber from any provider, with conditions: E-rate will not pay for new fiber networks off school property Installation (non-recurring) charges eligible from school building to edge of school property Modulating electronics must be provided by the applicant and cannot be bundled with the cost of the service This equipment is eligible for Priority 2 funding 18 DARK FIBER ELIGIBILITY
Fiber must be lit immediately Excess fiber that is not lit is not eligible Network maintenance costs are eligible Service should be posted in both telecom and internet access categories Apples-to-apples comparison should be done to ensure that leasing dark fiber is most cost effective method of delivering service 19 DARK FIBER ELIGIBILITY, CONT.
Network and phone wiring Routers Switches, hubs Certain network servers e-mail, DHCP, firewall, DNS Video codecs VOIP equipment GBICs and modulating electronics to light fiber Wireless access points Private branch exchange (PBXs) Firewalls Installation of eligible internal connections System operating software For eligible equipment only 20 P2: ELIGIBLE INTERNAL CONNECTIONS
Personal computers FAX machines Asbestos removal Cameras Electrical wiring Teacher training Security wiring Servers for storage Network management s/w Curriculum software Phones, beepers, aircards Salaries of school or library staff Filtering software 21 P2: INELIGIBLE INTERNAL CONNECTIONS
Beginning in FY 2011, maintenance severely curtailed Eligible: Bundled manufacturer warranties up to 3 years Cannot have a separate price Software, patches, online tech support Actual labor and break-fix cost Ineligible: Unbundled warranties, insurance-type warranties, including Smartnet (portion of Smartnet eligible) 22 P2: BASIC MAINTENANCE
Contract: Must separately identify cost of maintaining E-rate eligible equipment from E-rate ineligible equipment May not mix E-rate eligible maintenance services with other ineligible services (such as help desk or monitoring services) Calculation of funding request: Must be based on an estimated number of maintenance hours per year for eligible equipment, based on current life of equipment and history of needed repairs Reimbursement amount Break/fix - USAC will only pay for cost of actual work performed (which includes labor, equipment fix, or if it is beyond repair, equipment replacement) Software patches/Online tech support – 100%, no documentation needed 23 P2: BASIC MAINTENANCE
An entity may only receive discounts 2 out of every 5 years for internal connections Doesn’t include basic maintenance Applies at the building level, not district level If central equipment is purchased for NOC, each building receiving benefit of that equipment receives a strike Plan accordingly to maximize discounts “Strikes” related to FCDL, not 471 or invoices Can cancel FRN to get strike (year) back, but not after funding has been disbursed Hint: Don’t use a strike (year) for a $500 piece of equipment 24 2/5 RULE*
E-rate-funded equipment must remain at approved site for 3 full years after installation After which it may be moved to another eligible location Documentation must be retained describing transfer If school or library closes, equipment may be moved to another entity, regardless of discount Must send letter to SLD outlining closing of school and transfer of equipment Must keep documentation regarding transfer for 5 years After 5 years, equipment may be disposed of or sold Disposal does not need to be reported to USAC Proceeds from sale do not need to be returned to USAC 25 TRANSFER OF EQUIPMENT*
SHOULD I APPLY FOR P2 FUNDING? Year 1 -- funded to 70% Year 2 – all funded Year 3 – down to 82% Year 4 – down to 87% Year 5 – down to 81% Year 6 – down to 70% - significant rollover funds Year 7 – down to 81% Year 8 – down to 80% Year 9 – down to 86% Year 10 – down to 81% - $650M rollover Year 11 – down to 87% - $600M rollover FY 2009 – down to 77% - $900M rollover FY 2010 -- all funded - $1.15B rollover + inflation 26
27 QUESTIONS ABOUT APPLICANT OR SERVICE ELIGIBILITY ISSUES?
29 GENERAL FRAMEWORK Plan Bid ApplyApproval! Receive Services Pay Full Invoices USAC Pays Applicant Pay Discounted Invoices USAC Pays Vendor
Required if applying for P2 funding Must include four SLD technology plan criteria Goals and Strategies for using technology Needs Assessment Professional Development Evaluation Must align with funding requests and bidding documents Must be “written” before 470 is filed Must cover full 12 months of NEXT funding year (include dates!) 3 year max 30 STEP 1: TECHNOLOGY PLAN (MAYBE?)*
Must be approved by SLD “Certified” approver Public schools – PDE approves PDE requires submission by Sept. 30 for plans expiring June 30, 2012 Status of LEAs’ tech plans in binder Nonpublic schools – Various entities approve List in binder and on SLD website CAIU will approve if no organization on the SLD list represents your entity Libraries: Approved by Commonwealth Libraries 31 TECHNOLOGY PLAN APPROVALS*
All E-rate services must be competitively bid Before any contract is signed If multi-year contract is signed, then there is no requirement to bid the remaining years of the contract Every year for all month-to-month services Even if no competition in your area or if bidding under state law Bidding via E-rate does not exempt you from bidding under state law Can be done simultaneously Only exception is if someone bid it for you (consortium application, PEPPM contract) 33 STEP 2: COMPETITIVE BIDDING
File online to begin procurement process All 470’s posted on SLD web site Cannot select vendor until 29 th day after 470 is posted But must have Form posted on web at least 29 days before the Form 471 window close (example: March 15 close = Feb 16 deadline) Don’t wait this long File 470 by Thanksgiving, if possible eCertify! (or mail certification page to SLD if you don’t have PIN) 34 HOW? MUST USE FORM 470* Read the Instructions!
Must be fair and open process Provide as much detail as possible so bidders can respond Be sure to post in proper category If unsure, post in multiple categories File single or multiple 470s (up to you) Review Checklist before submitting your 470* 35 COMPETITIVE BIDDING: FORM 470
New 470 removes many of the unused features and questions MTM/contract/multi-year contract checkboxes BEAR/SPI preference question Ineligible entities section Necessary resources checkboxes Area codes and phone pre-fixes section Added item for consultant registration number 36 NEW FORM 470
Have a relationship with service providers that would unfairly influence the outcome of the competition Furnish service providers with inside competitive information Provide information or grant meetings to only some bidders Have ownership interest in a service provider’s company competing for services Violate applicant’s own regulations or policies Violate gifts rules 37 APPLICANTS CANNOT...
Have pre-bidding discussions with potential bidders as long as that doesn’t lead to one bidder having “inside” information Attend product demonstrations Encourage and seek vendors to bid Do research to determine what cost-effective solutions are available 38 APPLICANTS CAN...
Offer neutral technical assistance on development of technology plan Cannot exert undue influence on applicant's ability to conduct a fair and open competitive bidding Answer general questions about the products and services they sell in response to applicant inquiries Assist with Form 471 Item 21 attachment Provide information to applicants to assist with responding to PIA questions but applicant must respond to PIA Provide assistance with service substitutions and other post-commitment activities but applicant must certify 39 SERVICE PROVIDERS CAN...
Help prepare Form 470 Help write or provide RFP to applicant Be a contact person on Form 470 Sign any applicant forms Be involved with bid evaluation in any way Provide funding for the applicant's non-discount portion or waive the applicant's non-discount portion Coerce or pressure the applicant to use a specific Service Provider Provide gifts to applicants that violate the gift restrictions 40 SERVICE PROVIDERS CANNOT...
All gifts from service providers to applicants are prohibited except for: (1) Modest refreshments that are not offered as part of meal (e.g., coffee and donuts provided at a meeting) and items with little intrinsic value intended for presentation (e.g., certificates and plaques); and (2) Items that are worth $20 or less (e.g., pencils, pens, hats, t-shirts, and other items worth less than $20, including meals), as long as those items do not exceed $50 per employee from any one source per funding year 41 GIFT RESTRICTIONS
Exception for charitable contributions Service providers can continue making charitable donations to E-rate eligible entities in the support of schools – including, for example, literacy programs, scholarships, and capital improvements – as long as such contributions are not directly or indirectly related to E-rate procurement activities or decisions Exception for personal gifts There is an exception for gifts to family and personal friends when those gifts are made using personal funds of the donor (without reimbursement from an employer) and are not related to a business transaction or business relationship 42 EXCEPTIONS TO GIFT RESTRICTIONS
Service providers All service providers with current or possible future E-rate relationship to applicant All individuals who are on the governing boards of such an entity (such as members of the board of directors); and All employees, officers, representatives, agents, or independent contractors of such entities 43 WHO IS SUBJECT TO GIFT RESTRICTIONS?
Applicants All individuals who are on the governing boards of such entities (such as members of a school committee) All employees, officers, representatives, agents, consultants or independent contractors of such entities involved on behalf of such school, library, or consortium with E-rate Individuals whose work in any way relates to E-rate forms and technology plans; Individuals who prepare bids, communicate or work with E-rate service providers, E-rate consultants, or with USAC; and Any staff of such entities responsible for monitoring compliance with the E-rate Program 44 WHO IS SUBJECT TO GIFT RESTRICTIONS?
Aggregate value of all gifts to an E-rate applicant, from any employees, officers, representatives, agents, independent contractors, or directors of the service providers, are considered when computing the $50 annual limit Rules are always applicable, not just during the time period when the competitive bidding process is taking place State and local restrictions regarding gifts also still apply If more stringent than federal requirements, violation of state or local provision constitutes a violation of the FCC rule 45 OTHER IMPORTANT DETAILS RE GIFTS
You are allowed to change your mind and not purchase a service that is listed on Form 470 You are not required to meet with any vendor before, during or after the 470 bidding period If you meet with a vendor during the bidding period, fairness requires that you meet with any other vendor that contacts you. Smartphone service should be posted under both the Telecom and Internet service categories When contacted by a vendor, you must indicate your willingness to receive a proposal for services listed on Form 470 46 COMMON QUESTIONS ABOUT 470
47 LET’S LOOK AT THE FORM 470 http://www.sl.universalservice.org/menu.asp
GET 470 INFORMATION IMMEDIATELY! Posted 470 available immediately on SLD web site to view Online 470 shows: Posting date of application Earliest date that your contract can be signed and thus 471 submitted Date that certification page was received at the SLD SLD also sends this info in Receipt Notification Letter* 48
After 470 is posted for at least 28 days, review all bids received for all services Create bid evaluation matrix Price of eligible services/components MUST be the most heavily weighted factor* Keep documentation of criteria used to select vendor Keep all winning and losing bids Keep bid evaluation matrix Retain all correspondence between applicant and all vendors (winning and losing) 49 STEP 3: BID EVALUATION*
Can consider other criteria in bid evaluation. Examples: History with vendor Cost of ineligible items New vendors’ cell phones Quality of proposed solution MBE/WBE preference Cost to switch vendors Staff time References Cannot consider “free services” 50 WHAT CAN BE CONSIDERED?
What should you do if you receive no bids? Document via an email or file memo that no bids were received Existing Services: can continue to receive services from existing service provider New Services/Procurement: Solicit bid from willing vendor (who is not your brother-in-law) Make sure price is cost-effective Check marketplace options from other vendors in your area or nearby areas Save research and information to justify buying service from this vendor 51 STEP 3: BID EVALUATION*
Vendor selection must be done before you submit 471 Be careful not to make any decisions, sign anything or file any forms during 28 day waiting period. Contracts must be signed and dated by applicant Must sign contract unless receiving services on month-to-month basis List extensions and expiration date in contract (cannot be open-ended) Be careful to list prices in extension terms! Include out-clauses if you can’t pay without E-rate Try to have contracts begin July 1 and end June 30, 20XX to coincide with E-rate funding year 52 STEP 4: SIGNING E-RATE CONTRACTS*
These are Priority 1 services that have NO contract Local, long distance phone service Cellular Service Some Internet Access Must competitively bid every year, regardless of competition in your area for those services E-rate does not recognize multi-year tariffs… these must be contracts 53 TARIFFED SERVICES/MTM*
54 QUESTIONS ABOUT BIDDING / FORM 470 / BIDDING BEHAVIOR/GIFT RESTRICTIONS/BID EVALUATION / SIGNING CONTRACTS?
Form that requests discounts (funding) Filed by entity that actually pays the bills Shows discount calculations Lists which 470 was used to bid services, provides contract signing dates, contract amounts File single 471 (multiple OK) for all requests eCertify!! Or submit signed certification page ASAP if you don’t have a PIN Must be filed by close of 471 filing window (likely will be mid March) Don’t miss this deadline! 55 STEP 5: FILING THE 471
Discount level for a school or library depends on: 1) Percentage of students who are eligible for National School Lunch Program (NSLP) in: → (for a school) the school → (for a library) the school district in which the library is located Doesn’t matter if school serves lunch or participates in NSLP AVTS and nonpublic schools use their own students’ data, not sending schools’ data October NSLP data on PA E-rate website by mid January USAC wants you to use this data for FY 2012 2) Urban or rural location of the school or library List in binder and on pa e-rate website under ‘discount calculations’ 56 WHAT IS MY E-RATE DISCOUNT?*
57 DISCOUNT MATRIX FOR SINGLE SCHOOL INCOME Measured by % of students eligible for NSLP URBAN LOCATION Discount RURAL LOCATION Discount If the % of students in your school that qualifies for the NSLP......and you are in an URBAN area, your discount will be......and you are in a RURAL area, your discount will be... Less than 1%20%25% 1% to 19%40%50% 20% to 34%50%60% 35% to 49%60%70% 50% to 74%80% 75% to 100%90%
Schools Use straight matrix discount Districts Use weighted average of schools’ individual discounts Library Use the total number of students eligible for NSLP in the school district in which the library is located divided by the total number of students in that school district, then use straight matrix discount Library System Use simple average of member libraries’ discounts Consortium Use simple average of members’ discounts 58 DISCOUNT CALCULATIONS BY ENTITY*
59 SCHOOL BUILDING DISCOUNTS Individual School uses Discount from Matrix
60 SCHOOL DISTRICT DISCOUNTS Weighted Average of Individual School Discounts
61 LIBRARY BRANCHES Use discount information for school district in which library is located
62 CONSORTIUM DISCOUNTS Simple Average of All Entity Members
Participation in these programs also qualifies: TANF Medicaid Food Stamps Supplementary Security Income (based on income) Federal public housing assistance (section 8) Low Income Home Energy Assistance (LIHEAP) Not acceptable - Title 1, feeder schools method, principal’s estimate 63 ALTERNATIVE MEASURES TO NSLP*
Can conduct family survey even if you participate in NSLP Must survey all families in the school Can do single buildings If 50% of surveys are returned, survey is considered valid and results may be extrapolated for entire school Keep careful documentation Beneficial for both public and nonpublic schools seeking P2 funding Don’t let consultants talk you into conducting surveys 64 ALTERNATIVE MEASURES TO NSLP*
Non-instructional school and library buildings are eligible for Priority 1 funding NIFs that house the network hub are eligible for Priority 2 services and equipment NIFs that contain classrooms 65 NON-INSTRUCTIONAL FACILITIES (NIFS)
Method of calculating discounts depends on what purpose the services are being used School: Use NSLP data of students attending classroom IU Admin Services: Weighted average of discounts in all buildings within IU territory (act as large admin building) Consortium Lead: Simple average of consortium members’ discounts 66 IU DISCOUNT CALCULATIONS
Provide information related to your funding requests in Block 5 of Form 471 Vendor/SPIN Category of Service Form 470 Number T/MTM or Contracted Service Signing dates/expiration dates for contracted service Pre-discount amount must be based on bill, contract, quote, etc. Which entities receiving service 68 FUNDING REQUESTS – FRNS
New FRN (block 5) for each contract or SPIN FRNs will be reviewed and funded individually Don’t include Priority 1 and Priority 2 on the same Form 471 This is called a ‘polluted 471’ and can’t be funded until all FRNs can be funded 69 FUNDING REQUESTS – FRNS
File and certify online! Multiple forms OK No one-to-one correlation with 470 required Meaning, you can have (1) 471, but (3) 470’s. All services listed on 471 must have been listed on a 470 Checklist* 70 FORM 471 FILING TIPS
AFTER YOU HIT ‘SUBMIT’ ON THE 471, THEN WHAT? 71
Item 21 attachments provide descriptions of actual services Because no space to do so on the 471 Must have separate description for each FRN (funding request/Block 5) Detailed list of products with associated prices that add up to funding request List # of lines, speed, and description of service File online or on paper (online preferred) 72 STEP 6: ITEM 21 ATTACHMENTS*
Don’t need to submit bills or contracts But must have available and may be asked to submit during application review Keep 471 Security Code to access Online Item 21 Attachment system Item 21 attachments are required to be submitted within 471 window Can increase request on Item 21 attachment if you made clerical error on 471 73 ITEM 21 ATTACHMENTS - ONLINE
74 LET’S LOOK AT THE FORM 471 http://www.sl.universalservice.org/menu.asp
SLD mails to applicants Confirms receipt of Form 471 Verifies Block 5 information Service provider receives similar letter when they are listed as SPIN on 471 Can use to make corrections for ministerial and clerical errors 77 471 RECEIPT ACKNOWLEDGMENT LETTER (RAL)*
“The applicant can amend its forms to correct clerical and ministerial errors on their FCC Forms 470, FCC Form 471 applications, or associated documentation until an FCDL is issued. Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error.”(FCC 11-60) 78 MINISTERIAL AND CLERICAL ERRORS
Examples include but are not limited to: Not timely notifying USAC to correct a USAC clerical error Using wrong FCC Form 470 number, wrong billed entity number, or wrong billed entity number/worksheet number on Form 471 Using wrong name or service provider identification number (SPIN) Using wrong expiration date for a contract Requesting recurring service when the service is one time Requesting one time service when the service is recurring Inaccurately reporting the prediscount amount on Block 5 Leaving off a building from Block 4 Referring to wrong Block 4 worksheet for a funding request Listing wrong service category in Block 5 79 MINISTERIAL AND CLERICAL ERRORS
Spelling errors Simple addition, subtraction, multiplication or division errors Transposed letters and/or numbers Misplaced decimal points Other punctuation marks (hyphens, periods, commas, etc.) included, or not included or misplaced Failing to enter an item from the source list (e.g., NSLP data, uploading Block 4 data, FRN, etc.) 80 MORE M&C ERRORS
PIA will ask if this is a ministerial or clerical error Explain how the error occurred Provide a reasonable explanation Provide documentation that was in existence as of the date of submission of Form 470 or Form 471 Explain that the error occurred when consulting “source list” PIA must approve the explanation before the change will be made 81 REQUESTING A M&C CORRECTION
Contract, Service Agreement Vendor quote, bill, invoice, etc. RFP, Newspaper listing NSLP documentation or student enrollment data Board Minutes, Resolutions Budget Any other documentation in existence as of date of submission of Form 470 or Form 471 to prove error was ministerial/clerical 82 EXAMPLES OF SOURCE DOCUMENTATION
83 QUESTIONS ON FORM 471, ITEM 21 ATTACHMENTS, M/C ERRORS?
Program Integrity Assurance (PIA) Review Checks for rule compliance eligible services eligible entities appropriate discount Almost everyone receives a PIA call (document contacts with PIA) If they are going to deny an FRN, they will tell you so and give you 1 more chance to submit new information 84 STEP 7: PIA REVIEW
THEN WHAT? Wait Return PIA calls/e-mails Ask for extension if absolutely necessary E-mail Julie if you’re unsure of answers Check status of 471 on SLD website 85
FCDL = Funding Commitment Decision Letter Tells you which funding requests (block 5’s) of Form 471 are approved or denied Provides information for Form 486 Can appeal if you don’t agree with your decision* Must do so within 60 days Appeal first to the SLD. If SLD denies, appeal to the FCC within 60 days Always appeal! 86 NEXT: SLD MAILS FCDL*
Signifies that it’s OK for SLD to pay any invoices for that FRN Lists who approved tech plan Certifies CIPA compliance Must be postmarked no later than: 120 calendar days after the Service Start Date featured on the Form 486 or 120 calendar days after the date of the Funding Commitment Decision Letter whichever is later. Submit online using info from FCDL Use 07/01/2012 as service start date for FY 2012 (Yr 15) Form 486 Approval Letter Mailed* 87 STEP 8: APPLICANT FILES FORM 486*
Filtering and Internet Safety Policies ISP must have been adopted after public hearing Required for any school or library receiving: either Internal connections or Internet access Recipients of only Telecommunications services are exempt from E-rate CIPA compliance Consortium members submit Form 479 to consortium leader certifying compliance in order for leader to submit Form 486 88 CIPA: ORIGINAL REQUIREMENTS*
New CIPA requirements becomes effective 7/1/2012 Requires schools’ (not libraries) Internet Safety Policies include "... educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response." This means that schools are required to teach online safety to students as a prerequisite to receiving E-rate funding Local boards decide frequency and delivery of online safety/cyberbullying education Can’t be once every 4 years Establish policy, follow policy and document implementation 89 NEW CIPA REQUIREMENTS
Notice of public hearing or public meeting (such as school board meeting) where CIPA policy was considered and voted upon Agenda for meeting – show opportunity for public input/comment before adoption of CIPA policy Other documentation for opportunity for public comment Filtering records, purchase order Documentation of cyberbullying/appropriate online behavior education for all minors 90 CIPA DOCUMENTATION
91 LET’S LOOK AT THE FORM 486 http://www.sl.universalservice.org/menu.asp
92 QUESTIONS ON PIA REVIEW, FCDLS, FORM 486, CIPA?
Two choices Discounts on bills (vendor invoices USAC) OR Reimbursement process (applicant pays bills in full, then invoices USAC) Must select one or the other for entire year If you want discounted bills, call provider as soon as you are funded Many have additional forms to complete 93 HOW DO YOU GET E-RATE $?
Discounts appear on applicant’s bill Service provider submits Form 474 to USAC the Service Provider Invoice Form (SPIF) Provider should get reimbursed by SLD within 30 – 60 days from date of submission Applicants do nothing except make sure they are getting discounts they deserve on bills Do the math! 94 DISCOUNTED BILLING METHOD
Applicant pays bill in full Applicant submits Form 472 – BEAR Form for reimbursement* Quarterly, semi-annually, or at end of year Complete one BEAR for each SPIN Must contain SPIN signature on last page Send or fax to SPIN SPIN will mail or fax back Calculated based on eligible charges on actual bills Not AP register or amount committed Subtract ineligible charges 95 REIMBURSEMENT METHOD
Deadlines: October 28 (following close of funding year) for recurring services; January 28 for non-recurring services Can request extension if good cause exists SLD approves BEAR and sends approval letter to vendor and copy of letter to applicant SLD then sends check to vendor Vendor must send check to applicant within 20 business days Call SLD if you don’t get a check in a timely manner after receiving approval letter 96 REIMBURSEMENT METHOD
Applicant and Vendor must have PINs to file online BEARs Applicants completes BEAR Online Electronically sent to vendor Vendor certifies or denies If approved, applicant receives e-mail and BEAR is automatically sent to USAC for payment If denied, applicant receives e-mail and must refile the BEAR from scratch 97 ONLINE BEAR PROCESS*
When determining the amount to list on a BEAR, create a quick spreadsheet showing each month’s total charges, and total ineligible charges What are the ineligible charges? Varies by vendor, but these are known to be ineligible: Property Tax Fees Universal Service Administrative Fee USF fees themselves ARE eligible Late payment or finance charges USF Cost Recovery Fees Paper statement fees Equipment charges (on P1 bills) Equipment insurance fees Directory listing fees Non-published phone number fees Payphone service Here’s an example of what your spreadsheet may look like: 98 INELIGIBLE CHARGES ON BILLS
100 LET’S LOOK AT THE FORM 472 BEAR http://www.sl.universalservice.org/menu.asp
Sent only to applicants Authorized person Billed Entity (BEN) address Contains all invoice (Form 472 and Form 474) payment authorization amounts for the Billed Entity approved during that quarter for all funding years Review to ensure you agree with disbursements 101 QUARTERLY DISBURSEMENT REPORTS
File Form 500 to either: Change a service start date or a contract expiration date Cancel or reduce a funding commitment Warning: reductions or cancellations of funding commitments are irreversible Not required, but strongly suggested to file Form 500 if FRN not needed, or large amount of commitment is not used 102 OPTIONAL FORM 500*
103 QUESTIONS ON FORM 472 REIMBURSEMENTS, DISCOUNTED BILLING, FORM 500?
FY 2012 is YELLOW! For services rendered 7/1/2012 - 6/30/2013 471 application window slated to open early January 2012 Window is expected to close mid March 2012 Form 470’s being accepted now! 104 FY 2012 (YEAR 15) COMING SOON! Happy 15 th Birthday, E-rate!
For services rendered 7/1/2011 - 6/30/2012 FY 2011 is BLUE 72% of PA Priority 1 FRNs funded as of 10/12/2011 File the 486 after FCDL arrives Request discounted bills from vendors, if desired Watch PA E-rate Listserve closely 105 FY 2011 (YEAR 14) DETAILS
Funding Year ended June 30, 2011 for recurring services FY 2010 was PINK Deadline for submitting BEARs (Form 472s) is October 28, 2011 Deadline for submitting invoices for non-recurring services is January 28, 2012 (unless an extension has been granted) List available at training and watch PA E-rate listserve for “list” of affected entities List available at training File for extension if you haven’t submitted your BEAR! 106 FY 2010 (YEAR 13) NOT OVER YET!
107 QUESTIONS ABOUT FUNDING YEARS AND WHAT’S DUE WHEN?
Two types of SPIN changes: Corrective: Mostly for data-entry errors Can be done pre-and post-commitment Operational: When actually switching vendors Can only be done post commitment and for legitimate reason Must submit request to the SLD requesting change Can do so using Submit a Question feature* Can request to split an FRN* Allocate $ to 2 providers in same funding year Don’t forget to file 486 for new FRN 109 CHANGING SERVICE PROVIDERS*
Can no longer switch vendors because of lower price Some vendors were abusing lax SPIN change rules and not bothering to participate in 470 bidding process Legitimate reasons include: breach of contract service provider is unable to perform bankruptcy Must select vendor that received the next highest point value in the original bid evaluation, assuming there was more than one bidder 110 CHANGING SERVICE PROVIDERS
E-rate PINs can be used to file E-rate forms online PIN assigned to a person and is specific to that entity while employed at that entity Not given to an entity No way to request a PIN Must sign a paper certification of a 470, 471 or 486 SLD will mail them a PIN in a small white mailer Can still submit these forms online, but cert page must be signed and mailed to USAC PIN then may be used to 470, 471, 486, and BEAR Forms 111 E-CERTIFICATION/PINS*
Applicants required to pay non- discounted portion of cost Cannot be waived by the vendor Vendor cannot provide a “grant” Funding must be in budget or draft budget Must keep all invoices and copies of cancelled checks for 5 years after last day to receive service 112 PAYING YOUR SHARE
SS required when a change is made to any service on your approved 471, Item 21 attachments After FCDL issued Applicant must seek SLD approval which meets certain conditions Good idea to seek approval PRIOR to doing substitution in case it’s not approved by SLD. 113 SERVICE SUBSTITUTIONS*
Depends on the form and requirement Form 470 – no Form 471 – no Form 486 – no but they will send a reminder letter and you can then file if you missed the original deadline Form 472 BEAR – yes. Must be submitted by original deadline Service delivery – recurring services – no Services must be delivered between July 1 – June 30 Service delivery – non-recurring services – yes Installations and equipment purchases have until Sept 30 If applicant needs more time, they must request extension prior to Sept 30 PIA inquiries – yes. If you cannot provide the info by the deadline, you may request extension, but it may not be granted 114 CAN YOU REQUEST EXTENSIONS?
Consortium Name of consortium leader, consortium member name, type of service, signature, date and title of people signing document Sample LOA available on SLD website Must be signed/dated before filing of Form 471 Consultant Must be signed by applicant before the consultant does ANY work on behalf of the applicant 115 LETTERS OF AGENCY*
Most data on SLD website, using DRT Download by state, by SPIN, by entity, etc Updated nightly Shows: Entity info / 471# / FRN # / 470 # / SPIN if FRN funded whether 486 was submitted last date to invoice original requested amount & committed amount discount invoice paid and by what mode etc. E-rate Central Database Tool* 116 DATA RETRIEVAL TOOL*
PEPPM is contract administered by IU 16 for PDE State posts Form 470 when contract is bid Schools and libraries may skip 470 process and purchase directly from PEPPM for P2 equipment and services Obtain quote from PEPPM vendor(s) for products needed Be sure quote is dated before Form 471 is submitted Use quote for funding request on Form 471 E-mail with details of which 470 number to use is sent to PA E-rate listserve in January Co-Stars is not an E-rate eligible contract 117 USING PEPPM FOR P2 PURCHASES
COMMUNITY USE OF SERVICES Schools may now permit general public to use the schools’ Internet access during non-operating hours – at the school Until February 2010, such Internet access was only permitted to be used by K-12 students and staff for educational purposes only, putting many schools and most vocational technical schools in a difficult position In February 2010, the FCC permitted such usage on a temporary basis 118
3 conditions for community use of school facilities: Usage is permitted only during a school’s “non- operating” hours or summer School may not request E-rate funding for a higher level of service than would be required for educational purposes Schools may not charge for the use of the Internet access, but may charge reasonable fees to cover overhead costs from individuals that use the schools' services and facilities Organizations using a schools' services are permitted to recover related costs (e.g., “curriculum development and presentation costs”) from attendees 119 COMMUNITY USE OF SERVICES
School not required to open facilities Internet filtering rules must remain intact during use New rule in no way permits schools to share their bandwidth with other ineligible entities, such as an off-site after-school program at the YMCA or community center Also does not permit partially eligible entities, such as a Diocesan office that provides services to both schools and the church, to stop cost allocating the ineligible portion of Internet use 120
Rules require all applicants to retain ALL E-rate and related documents for 5 years from last day of service in a particular funding year If auditor visits in 4 years, and documents are missing, it could be the basis to recover all funding from that funding year Document and keep everything remotely related to E- rate Like what? 122 AUDITS AND DOCUMENT RETENTION*
Tech plan and approval letter Consultant agreements RFP and proof of publication date All vendor correspondence Winning and losing bids Professional development records Bid evaluation documentation Proof of authorization to sign E- rate forms Filtering records and payments NSLP forms AUP and proof of public meeting Signed contracts NSLP documentation Budgets Purchase orders Packing slips Asset or inventory records Installation records All Invoices Front and back of checks as proof of payment to vendor (non-discounted share) Proof of receipt of payment from vendor (BEAR checks) 123 DOCUMENTS TO RETAIN*
124 QUESTIONS ABOUT DOCUMENT RETENTION AND AUDITS?
SLD Client Service Bureau (CSB) E-rate “Help Desk” where applicant & service providers can get answers to questions Accessed via 888-203-8100 Submit a Question Available on SLD website PA E-rate Coordinator E-mail firstname.lastname@example.org www.e-ratepa.org 125 E-RATE HELP