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Form 471 to Funding Commitment

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Presentation on theme: "Form 471 to Funding Commitment"— Presentation transcript:

1 Form 471 to Funding Commitment
E-rate Modernization Form 471 to Funding Commitment Finishing The Process E-rate Modernization 2015

2 Agenda General Information & Updates December 2014 Order
Discount Calculations Urban/Rural Look-up Tool Bidding Process Category 2 Budget The NEW Form 471 Form 471 – Getting Prepared Program Integrity Assurance CIPA Compliance Document Retention Program Compliance E-rate Modernization 2015

3 General Information & Updates
What is the role of CDE, K-12 HSN and State Library? Have no statutory authority to administer the federal E- rate program May only offer general information about the E-rate/CTF program including: training and outreach, reference materials, and other publicly available SLD/USAC resources The following information is provided to assist applicants with their applications. It remains each applicant’s responsibility to ensure FCC/USAC, State, and local agency rules and practices are followed. All liability and risk rests upon each applicant for E-rate approval

4 General Information & Updates
Form 471 filing window: Opens at noon EST on Wednesday, January 14, 2015 Closes at 11:59 PM EDT on Thursday, March 26, 2015 The filing window will be open for 72 days Last possible day to file the Form 470: Thursday, February 26, 2015 E-rate Modernization 2015

5 E-rate Modernization December 2014 Order E-rate Modernization 2015

6 December 2014 Order Increase the funding cap from $2.4 Billion to $3.9 Billion Special Construction – Category 1–Data Networks Beginning 2015: Allows applicants to invoice for special construction in excess of $500,000 in a single funding year Beginning 2016: Allows applicants to pay their non- discounted share over multiple years (interest or fees incurred are the sole responsibility of the applicant) E-rate Modernization 2015

7 December 2014 Order Dark and Lit Leased Fiber - 2016
Modulating equipment for leased dark fiber eligible under Category 1 (C1) Leased dark fiber special construction charges eligible for C1 support IF fiber is lit within the same funding year Allows C1 special construction charges to be incurred prior to the commencement of the funding year under certain circumstances Requires applicants to consider both dark and lit fiber during competitive bidding when seeking fiber-based solutions E-rate Modernization 2015

8 December 2014 Order Self construction of fiber networks - 2016
Permitted under limited circumstances when it is the most cost-effective solution Beginning in Funding Year 2016 E-rate Modernization 2015

9 December 2014 Order Additional funds for last-mile construction costs FCC will match, dollar-for-dollar, up to 10% of the funds supplied by the State toward the applicant’s matching funds Ensure access in high-cost areas Service providers that receive Universal Service Fund High-Cost support must charge schools in high-cost locations rates that are “reasonably comparable” to schools in urban areas E-rate Modernization 2015

10 December 2014 Order Urban/Rural definition revised - 2015
In response to Petitions for Reconsideration the FCC has adjusted its use of the Urban Cluster definition as it is used in the 2010 Census Formerly, Urban Clusters population parameters were between 1,500 and 50,000 REVISION – for the purposes of E-rate, Urban Clusters will now include only those areas between 25,000 and 50,000 E-rate Modernization 2015

11 December 2014 Order Urban/Rural definition revised - 2015
Effect in California: Of the 150 Urban Clusters only 26 of them will be classified as Urban 124 of them will remain Rural, thus getting 10% increase in E-rate discount for those applicants at 49% NSLP and lower See slides 21 for detailed discussion of Urban/Rural Look-up tool E-rate Modernization 2015

12 Discount Calculations
E-Rate Modernization Discount Calculations E-rate Modernization 2015

13 Discount Calculations
Discount Calculations based on NSLP eligibility Calculated for the organization as a whole There is no longer a discount for individual sites Libraries – use NSLP eligibility of district where main branch is located Consortia – continue to use simple average of members Urban/Rural status Determined by the majority of sites in the organization Must have more than 50% of sites considered Rural for the organization to be determined to be a Rural District/Library E-rate Modernization 2015

14 Discount Calculations
Discount calculations – Non-Instructional Facilities (NIFs) Receive the discount of the school district or library system, regardless of the entities they serve. Do NOT receive an urban/rural status E-rate Modernization 2015

15 Discount Calculations
Revised Discount Matrix E-rate Modernization 2015

16 Discount Calculations
Alternative Discount Mechanism - Surveys You can no longer extrapolate the survey data Beginning in FY2015, you can use the NSLP applications as your survey instrument. District qualifies for 80% discount School Enrolled Surveys Returned No Qualified for NSLP % of total enrolled that qualify Red Elementary 300 125 100 Blue High 900 600 550 Total 1200 650 54% E-rate Modernization 2015

17 Discount Calculations
Community Eligibility Program (CEP) At least 40% of students are directly certified Eligibility determined by the Identified Student Percentage (ISP) Multiply the ISP by the national multiplier (1.6) to determine NSLP eligibility for E-rate E-rate Modernization 2015

18 Discount Calculations
Provisions 1, 2 and 3 Allow for socio-economic survey to be used to establish the NSLP reimbursement rate and reduce paperwork for schools Applicant uses approved NSLP eligibility percentage to calculate E-rate discount rate Schools submit base-year documentation to support E-rate discount rate If extension is granted, applicants can submit extension approval letter to support E-rate discount rate E-rate Modernization 2015

19 Discount Calculations
Head Start All Head Start students qualify for NSLP program Early Head Start (EHS) students do not qualify for E-rate program If facility is shared with Head Start students and Early Head Start students a cost allocation must be done to account for the ineligible students. E-rate Modernization 2015

20 Discount Calculations
Best Practices: Schools in CA are encouraged to use “auditable” data to establish discount Monthly Claim for Reimbursement report from Food Services - CNIPS CalPads section 1.17 E-rate Modernization 2015

21 Discount Calculations
Questions? E-rate Modernization 2015

22 Urban/Rural Look-up Tool E-rate Modernization

23 Urban/Rural Look-up Tool
Left side of screen click “Search Tools” Scroll down and click “Search Urban/Rural Status” Direct link to tool: external/urbanRuralLookup/ E-rate Modernization 2015

24 Urban/Rural Look-up Tool
Sample – Invalid Address, single site E-rate Modernization 2015

25 Urban/Rural Look-up Tool
Sample – Invalid Address, District E-rate Modernization 2015

26 Urban/Rural Look-up Tool
Issues: Check the address listed under the billed entity to ensure it is correct in its entirety, including ZIP code Check if address has any punctuation that is not “postal” standardized, for example Ave. versus AVE To make corrections to address, call Client Service Bureau at USAC refreshes database periodically so run a check on the Urban/Rural Look-Up Tool the following day to see if address corrections updated status When all else fails call your State E-rate Coordinator for help. E-rate Modernization 2015

27 Urban/Rural Look-Up Tool
Questions? E-rate Modernization 2015

28 E-rate Modernization Bidding process E-rate Modernization 2015

29 Bidding Process Form 470 – starts the bidding process
Identifies number of eligible entities receiving services Identifies products/services that applicant is seeking bids for May include information on RFP, if one is being used Includes required certifications of program compliance E-rate Modernization 2015

30 Bidding Process BIDDING Reminders
Post Form 470 (and RFP if using one) for minimum of 28 days Ensure bidding process is fair and competitive Respond equally to all legitimate inquiries Do not provide “insider” information to any potential bidder Clearly define disqualifying factors or special requirements Ensure Form 470 has been certified E-rate Modernization 2015

Requirement: must select the most cost effective solution Price must be the heaviest weighted factor. Must be able to demonstrate why a solution with higher than average pricing is cost-effective. Service providers may work with applicants to help them understand the technical needs for a more expensive solution. Service Provider must provide the Lowest Corresponding Price. (see next slide) E-rate Modernization 2015

LCP relates to Category 1 services Proposed pricing must be the lowest price that a service provider charges to a non-residential customer similarly situated for similar services Responsibility rests with Service Provider to provide pricing that is LCP compliant Applicants encouraged to compare prices, especially if only one bid response is received E-rate Modernization 2015

33 Bidding Process NO BIDS RECEIVED? Keep a written record of this fact
During an audit this may be the only evidence you are able to produce that no bids were received You can: contact service providers to solicit bids review and evaluate any bids received as a result However, if you post a new RFP or Form 470 you must wait another 28 days before reviewing bids E-rate Modernization 2015

34 Bidding Process ONLY ONE BID RECEIVED? Document this fact
Provides evidence during audit that you did not simply keep the winning bid E.g.: Send an to yourself documenting that only one bid was received as of a certain date FCC expects applicant to demonstrate cost effectiveness, even if only one bid is received E-rate Modernization 2015

35 Bidding Process BID EVALUATION
Cost of eligible services MUST BE the heaviest weighted factor (see next slide for example) Other factors may be considered by applicant, e.g.: Prior experience Personnel qualifications Cost of ineligible components/services E-rate Modernization 2015

36 Bidding Process Sample Bid Evaluation Matrix Factor Points Available
Vendor 1 Vendor 2 Vendor 3 Price of the ELIGIBLE goods and services 30 15 25 Prior experience w/ vendor 20 Prices for ineligible services, products & Fees Flexible Invoicing: 472 or 474 Environmental objectives 5 3 2 Local or in state vendor Total 100 65 68 92 E-rate Modernization 2015

37 Bidding Process BID AWARD Follow local, state, federal policies
A purchase order may be considered a contract ONLY if the State considers it to be a contract Obtain Board approval if required A contract must be signed and dated by the applicant after the Allowable Contract Date (ACD) and prior to the date the FCC Form 471 is submitted The ACD is 28 days after the posting of the Form 470 or RFP, which ever is later Voluntary contract extensions must be clearly identified in the original contract language Note: Evergreen contracts (ones that automatically extend unless cancelled) are not eligible within the E-rate program. E-rate Modernization 2015

38 Bidding Process DOCUMENT THE PROCESS Keep copies of:
RFP, if one was used All communications with services providers and consultants All bids received, winning and losing Completed bid evaluation matrix Copy of signed contract Retain ALL documents for at least 10 years from the last date that services are received (see Document Retention section of this presentation) E-rate Modernization 2015

39 Bidding Process Questions? E-rate Modernization 2015

40 E-rate Modernization Category 2 Budget E-rate Modernization 2015

41 Category 2 Budget What are Category 2 budgets?
A five year budget for each school or library Category 2 products and services include Internal Connections, Managed Internal Broadband Service and Basic Maintenance of Internal Connections. Products and services ordered in excess of an entity’s Category 2 budget will not receive E-rate discounts. There is no budget for Category 1 services E-rate Modernization 2015

42 Category 2 Budget New approach to the former Priority 2
Schools: Pre-discount of $150/student Libraries serving less than 250,000 population Pre-discount of $2.30/square foot Libraries serving 250,000+ population: Pre-discount of $5.00/square foot All qualify for a floor of $9,200 pre-discount E-rate Modernization 2015

43 Category 2 Budget New approach to the former Priority 2
Budgets are set per individual school site or library Budgets may not be shared or averaged between sites Non-instructional facilities (including NIFs with classrooms) DO NOT qualify for Category 2 funding, therefore, no budget is allowed Core equipment that serves multiple sites and is located at NIF can receive E-rate discounts. (see next slide) E-rate Modernization 2015

44 Category 2 Budget How do I allocate costs for shared services?
On the FCC Form 471, you indicate how funding should be allocated among entities sharing services. Your allocation can be: Straight-line (all entities share the cost equally) Proportional (based on student count/square footage of each entity) Specific (you specify each entity’s share) Cost allocate expense for any product/services delivered to Non-Instructional Facilities (see next slide for example) E-rate Modernization 2015

45 Category 2 Budget Example of cost allocating for shared services
Switch costs $10,000. Shared between 5 sites. Straight-line method = each site pays $2,000. 2 sites ineligible for C2 = $4,000 ineligible 3 sites eligible for C2 = $6,000 eligible Core Switch - DO Maint Dept Blue High Yellow Elem Green Middle E-rate Modernization 2015

46 Category 2 Budget 5 year budget
You can spend the entire amount in one year OR You can spread it over any combination of years, up to 5. The budget may increase within the 5 years if enrollment increases (schools) or square footage increases (libraries) E-rate Modernization 2015

47 Category 2 Budget New schools
Estimate your enrollment to establish the Category 2 budget This number will be trued up once the school opens Funds received in excess will be returned to USAC If actual enrollment ends up being greater than estimated enrollment the site will qualify for the larger budget. E-rate Modernization 2015

48 Category 2 Budget How are services counted against my budget?
Any funding commitments that include your entity as a recipient of service in FY2015 count against your pre-discount budget for that entity. Any un-used funds on an FRN may be returned to USAC by means of the Form 500 to credit your budget. If entities are sharing the service, specific information will be required so USAC will know how to apply the returned funds to the specific entities. E-rate Modernization 2015

49 Category 2 Budget How low will USAC fund in Category 2?
There is no way to know for certain but the FCC has stated several times that they are very optimistic to be able to fund all requests. What does this mean for you? Have a PLAN We encourage you to apply for Category 2 funding if you have an eligible project/service. Even if funding isn’t available for every request it is the only way the FCC will have an idea of the true demand. E-rate Modernization 2015

50 Category 2 Budget Questions? E-rate Modernization 2015

51 E-rate Modernization The NEW Form 471 E-rate Modernization 2015

52 Details of Services and Costs
The NEW Form 471 New and IMPROVED look and feel Re-designed to be a clean and simple interface Fields on the left for help Fields on the right for error messages Buttons to exit, save, or continue at the bottom of each page, consistently labeled Basic flow unchanged Billed Entity Info Recipients of Service Details of Services and Costs Item 21 EMBEDDED in form E-rate Modernization 2015

53 The NEW Form 471 More applicant friendly and feature-rich
Progressive disclosure – showing only the screens pertinent to the application type and other information provided earlier in the form. Information is entered only once, then presented to the applicant as needed E-rate Modernization 2015

54 The NEW Form 471 More applicant friendly and feature rich
Form navigation arrows at the top of the screen to show progress and pages completed. Timeout feature warns the applicant after 25 minutes of no activity, i.e., no keystrokes or mouse clicks. If no activity occurs after five additional minutes, applicant is timed out AFTER work to that point is saved E-rate Modernization 2015

55 The NEW Form 471 NEW Templates :
Allows applicant to prepare information ahead of time and upload Designed to save time HOWEVER – do not wait until the last minute. The Form 471 will be more time consuming this year than in prior years. E-rate Modernization 2015

56 The NEW Form 471 Online submission only
Paper certifications will still be accepted. The paper certification can be only obtained only after submitting the Form 471 online. E-rate Modernization 2015

57 The NEW Form 471 Questions? E-rate Modernization 2015

58 Form 471 Getting Prepared E-rate Modernization

59 Form 471 – Getting Prepared
Have available: Entity Numbers: Billed Entity Number – agency that represents schools/libraries Entity Number for all recipients of services, include NIFs Confirm address/phone/fax numbers are correct in SLD database Other Identifying Numbers - Schools NCES code for each instructional facility: CDS code for each instructional facility: Other Identifying Numbers - Libraries FSCS Code for each library site E-rate Modernization 2015

60 Form 471 – Getting Prepared
Have available: Schools District-wide NSLP data for discount calculations Enrollment for each site for Category 2 budget Urban/Rural status for each instructional facility Libraries District NSLP for school district where main branch is located Square footage for each site for Category 2 budget If doing only C1 application, square footage is not required Urban/Rural status for each library Budget information to demonstrate sufficient resources to effectively use program funds E-rate Modernization 2015

61 Form 471 – Getting Prepared
NEW: Network survey information - Schools: To be filled out once per applications E-rate Modernization 2015

62 Form 471 – Getting Prepared
NEW: Network survey information - Schools: To be filled out once per applications E-rate Modernization 2015

63 Form 471 – Getting Prepared
NEW : Network survey information - Libraries: Filled out once per application E-rate Modernization 2015

64 Form 471 – Getting Prepared
NEW : Network survey information - Libraries: Filled out once per application E-rate Modernization 2015

65 Form 471 – Getting Prepared
Category 1 services Monthly recurring cost of eligible services Identify and remove ineligible charges, e.g. DID (Direct Inward dialing) 900/976 call blocking Custom calling services Paging Directory Assistance charges Text messaging Inside wire maintenance Directory listing Administrative Expense fees Some taxes and surcharges E-rate Modernization 2015

66 Form 471 – Getting Prepared
Category 1 services Non-Recurring costs, such as installation Contract information Length of contract, including any extensions Signature date Expiration date Establishing Form 470 Be prepared to justify cost Sample month bill Copy of contract E-rate Modernization 2015

67 Form 471 – Getting Prepared
Category 2 Must be on Form 471 separate from Category 1 Document the cost allocation strategy used Cost allocations must be based on tangible criteria and reach a realistic result. Contract information Award date Expiration date E-rate Modernization 2015

68 Form 471 – Getting Prepared
Category 2 What if the winning bid exceeds my budget? The amount in excess is the responsibility of the applicant. There currently is not a “best practices” since the Form 471 and Category 2 budgets are so new. E-rate Modernization 2015

69 Form 471 Going Online E-rate Modernization 2015

70 Form 471 – Getting Prepared
Practice Practice Practice Form 471 test site: https://sltools- applicant/form471/new/# Billed Entity Number FCC Registration Number, use E-rate Modernization 2015

71 The NEW Form 471 NEW Templates : templates.aspx School Template for Discount Calculations V15-1  Library Template for Discount Calculations V15-1  Item 21a  – Internet Access, Telecommunications Services, Voice Services Item 21b  – Internal Connections Item 21c  – Managed Internal Broadband Services Item 21d  – Basic Maintenance of Internal Connections Will enable applicants to upload service details directly into online Form 471. E-rate Modernization 2015

72 Form 471 – Getting Prepared
Questions? E-rate Modernization 2015

73 Program Integrity Assurance (PIA)
E-rate Modernization Program Integrity Assurance (PIA) E-rate Modernization 2015

74 Program Integrity Assurance (PIA)
What is PIA? A review process that every application goes through. Reviewers ensure that requests for funding meet program rules and requirements. Reviewer may ask questions and request documentation. The review results in a funding decision on each funding request. Specialized teams conduct additional reviews for certain groups of applications (e.g., competitive bidding & cost- effectiveness). Reviewer will always provide final chance to refute modification or denial. End result: issuance of the Funding Commitment Decision Letter. E-rate Modernization 2015

75 Program Integrity Assurance (PIA)
Common PIA requests: Provide further detail about the services delivered Provide documentation to support the discount rate Provide documentation to show the entity is eligible Provide cost-allocation information to “save” eligible part of FRN while removing costs for ineligible items Cost allocations must be based on tangible criteria and reach a realistic result. E-rate Modernization 2015

76 Program Integrity Assurance (PIA)
Common PIA questions Did the FCC Form 470 really establish the bidding for this FRN? Are the scope and details of what you are requesting funding for consistent with the originating Form 470? Provide a copy of the contract to support contract dates, service eligibility, etc. E-rate Modernization 2015

77 Program Integrity Assurance (PIA)
Discount Validation If third party validation of your discount percent is being requested Contact CDE at for instructions on completing the validation letter. Once validation letter is completed sent it, along with the USAC PIA review letter to CDE will create a validation and send it directly to the reviewer within 48 hours. E-rate Modernization 2015

78 Program Integrity Assurance (PIA)
Timing Responses to reviewer are due within 15 days of when the reviewer makes contact. Successful contact is: A sent message with no return notification of non- delivery or out-of-office response A sent fax with a confirmation of successful transmission A voic left at the contact person's telephone number if the recorded greeting does not state that the contact person is out of the office A live person answering the SLD’s call at the contact telephone number or a return call responding to the SLD’s message. E-rate Modernization 2015

79 Program Integrity Assurance (PIA)
Timing If you need more time to prepare your response, ask for it BEFORE the deadline passes You will very likely only get one 7 day extension E-rate Modernization 2015

80 Program Integrity Assurance (PIA)
Questions? E-rate Modernization 2015

81 E-rate Modernization CIPA Compliance E-rate Modernization 2015

82 CIPA Compliance Children’s Internet Protection Act (“CIPA”) enacted in December of 2000 – effective April 20, 2001 CIPA requirements apply to ALL applicants that receive funding in following categories of service: C1 - Internet Access C2 - Internal Connections or Managed Internal Broadband Services C2 - Basic Maintenance of Internal Connections CIPA compliance is not required for applications for P1 - Telecommunications Services and Voice Over Internet Protocol (VoIP) First-time applicants (ONLY) may have up to two additional years to come into compliance E-rate Modernization 2015

83 CIPA Compliance Requirements:
Internet safety policy Technology protection measure (filter) Public notice of – and public meeting or hearing on – the Internet safety policy For a detailed discussion of CIPA requirements: Children’s Internet Protection Act website guidance Form 486 Instructions Form 479 Instructions E-rate Modernization 2015

84 CIPA Compliance Protecting Children in the 21st Century
Supplements the CIPA Policy Enacted in October 2008 – effective July 1, 2012 Requires applicant to meet certain requirements regarding education of minors and cyberbullying awareness and response. (see next slide for more details) Does NOT apply to Libraries E-rate Modernization 2015

85 CIPA Compliance Protecting Children in the 21st Century Requirements:
Schools must educate minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms (education requirements apply only to minors and not adults) Schools must promote cyberbullying awareness and response Schools must update their Internet Safety Policies to address these new requirements These activities must have been in place by July 1, 2012 E-rate Modernization 2015

86 CIPA Compliance Protecting Children in the 21st Century – additional information “Social networking” and “cyberbullying” are not defined, nor are specific procedures or curricula detailed for schools to use in educating students Congress’ intent is that local authorities should make decisions in this area Resources are available to assist in this process if needed – e.g., For more guidance, go to: Schools do not need to hold a new public meeting or hearing about amendments adopted to meet these requirements unless required to do so by state or local rules E-rate Modernization 2015

87 CIPA Compliance Questions? E-rate Modernization 2015

88 E-rate Modernization Document Retention E-rate Modernization 2015

89 Document Retention 7th Report and Order stipulates a 10 year document retention policy 10 years from last date of service Paragraph 262 5th Report and Order provided clarification on what document should be retained Paragraphs E-rate Modernization 2015

90 Document Retention What should be retained?
Documentation of CIPA compliance Bidding process including any RFPs issued all bids received All communications with service providers and consultants Bid evaluation matrix and bid award process E-rate Modernization 2015

91 Document Retention What should be retained?
Bills Reconciliation worksheet Proof of payment (e.g. cancelled checks) All USAC forms, letters, correspondence Inventory registry Network diagram USAC’s E-rate Table of Contents is a great reference tool E-rate Modernization 2015

92 Document Retention Questions? E-rate Modernization 2015

93 E-rate Modernization Program Compliance E-rate Modernization 2015

94 Program Compliance The applicant is responsible for:
File FCC Form 470 and indicate whether there is, or will be, an RFP (see slide 103) Evaluate bids and select the winning service provider File the FCC Form 471 and Item 21 attachments during the application window E-rate Modernization 2015

95 Program Compliance The applicant is responsible for:
Respond to inquires from PIA File FCC Form 486 after ensuring that you are CIPA compliant (if applicable), and services have started Select the invoice method and file FCC Form 472 (BEAR), if applicable Document your compliance with FCC rules on an on- going basis Retain documentation for at least ten years from the last date of service delivery E-rate Modernization 2015

96 Program Compliance Service providers:
Respond to Forms 470 and RFPs, once they have been issued Assist applicants with preparing their Form 471 Item 21 attachments Provide technical answers on questions regarding specific goods and services requested but NOT on competitive bidding questions File Form 473, the Service Provider Annual Certification Form File Form 474, the Service Provider Invoice, if applicable Retain documentation for at least ten years from the last date of service delivery E-rate Modernization 2015

97 Program Compliance Consultants:
Obtain a Consultant Registration Number to be included on all FCC forms where you have provided assistance to schools and libraries with their E-rate Program applications for a fee Follow the role of your client – either applicant or service provider Avoid conflicts of interest Document your compliance with FCC rules on an on- going basis Retain documentation for at least ten years from the last date of service delivery E-rate Modernization 2015

98 Program Compliance Competitive Bidding Must be a 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 FCC Form 470/RFP responses and contract fine print 6th Report and Order provides further clarifications and examples of rule violations E-rate Modernization 2015

99 Program Compliance Form 470
Indicates the services and categories of service which entities are seeking Must be posted for at least 28 days Indicates if they are planning/have issued RFP or other documents regarding the procurement Indicates any special requirements and/or disqualification factors Indicates who will be receiving the services E-rate Modernization 2015

100 Program Compliance Only APPLICANTS can:
Determine the types of service you will seek on an FCC Form 470 Prepare and fill out the FCC Form 470 Sign, certify, and/or submit FCC Form 470 Negotiate with prospective bidders Run the competitive bidding process E-rate Modernization 2015

101 Program Compliance 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. Fail to describe the desired products and services with sufficient specificity to enable interested parties to bid Receive gifts or donations from service providers that violate FCC rules or seek to circumvent FCC rules E-rate Modernization 2015

102 Program Compliance Applicants and Service Providers can have:
Have pre-bidding discussions Discuss new product offerings Teach applicants about new technologies Present product demonstrations Provide or receive de minimis items Modest refreshments, not offered as a part of a meal Items with little intrinsic value such as certificates and plaques E-rate Modernization 2015

103 Program Compliance Request for Proposal (RFP)
FCC rules refer to RFPs generically but they may have a variety of names (Request for Quotes, Scope of Work, Summary of Projects, Instructions to Bidders, etc.) FCC rules do not require RFPs but state and local procurement rules may Must be available to bidders for at least 28 days Applicants must count 28 calendar days from whichever (FCC Form 470 or RFP) was posted or available last Example: RFP posted on December 1, FCC Form 470 posted on December 15; December 15 starts the 28-day count E-rate Modernization 2015

104 Program Compliance Form 470 and RFP issues
Applicants must ensure they post for the correct category of service New FCC Form 470 combines Telecom and Internet Access Sufficient detail in FCC Form 470 to enable service providers to formulate bids Cannot provide generic descriptions (e.g., all eligible telecom services, Digital Transmission Services) Cannot provide laundry lists of products and services E-rate Modernization 2015

105 Program Compliance Imposing Restrictions:
Applicants may 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. Brand X compatible) Bidder disqualification criteria must be spelled out in FCC Form 470 and/or RFP and be available to all Cannot list specific make and model of services sought without also allowing equivalent products and/or services to be bid “XYZ manufacturer's router model 345J or equivalent” E-rate Modernization 2015

106 Program Compliance Bid Evaluation
Retain all vendor selection documentation for at least ten years from the last date to receive service Winning and losing bids, correspondences, memos, bid evaluation documents, etc. Price of the eligible goods and services must be the primary factor or the most heavily weighted overall in any tier USAC sample evaluation matrix available Evaluation begins after 28-day waiting period Service providers may not pay for applicant’s termination charges incurred in breaking a contract E-rate Modernization 2015

107 Program Compliance Most Cost Effective Selecting the winning bidder
Price of the ELIGIBLE goods and services must be the primary factor in the bid evaluation 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 Construct An Evaluation for weighting samples E-rate Modernization 2015

108 Program Compliance Contracts
A contract must be signed and dated by the applicant after the Allowable Contract Date and prior to the FCC Form 471 certification postmark date Tariffed or month-to-month service purchased under contract is contracted service A purchase order may be considered a contract ONLY if the state considers it a contract Voluntary contract extensions are allowable only when the option is stated in the original provisions of the contract E-rate Modernization 2015

109 Program Compliance 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 Multiple winners require vendor selection justification – applicants must conduct mini-bid to award contract E-rate Modernization 2015

110 Program Compliance Paying non-discounted share
All applicants must pay their non-discount share Service providers cannot give the money (directly or indirectly) to pay for the non-discount share Can’t be a charitable donation from the provider or an entity with which the selected service provider has a relationship Funds can’t come from the service provider or an entity controlled by the service 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 E-rate Modernization 2015

111 E-rate Modernization Questions? E-rate Modernization 2015

112 E-rate Modernization Summary – top 6 things to remember
6. Form 471 Window opened Jan 14, 2015 and closes March 26, 2015 5. Last possible day to post a Form 470 is February 26, 2015 – DON’T WAIT THAT LONG 4. File Form 470 NOW 3. Begin preparing Form 471 templates and/or Form 471 recipients of services list 2. Don’t wait till the last week to start Form 471 1. Expect to spend more time on your Form 471 than ever E-rate Modernization 2015

113 E-rate Modernization Next trainings will be webinars specifically to discuss any issues you are experiencing with the filing process Sign up for trainings at K12HSN Join CDE E-rate list serve in order to receive training dates and announcements E-rate Modernization 2015

114 California Teleconnect Fund
The Staff Proposal recommended modifications to the CTF program rules. The recommended changes that would have the most impact on schools and libraries, include: Have voice/VOIP mirror E-rate Keep Schools at a 50% discount Moratorium on CTF application processing.(Note: Issues for Schools and Libraries if this occurs) Eliminate support entirely for nonprofit private schools that have a less than a 40% free and reduced lunch eligibility rate CTFOIRStaffProposalMa y2014.pdf E-rate Modernization 2015

115 E-rate Modernization Contact information State Library: Jarrid Keller (916) CDE: Doris Stephen (916) K-12 HSN/Butte COE: Russ Selken (530) E-rate Modernization 2015

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