Kansas K-12 E-rate Training

Kansas K-12 E-rate Training
Nov 13, 2013 Southeast Kansas Education Service Center Nov 14, 2013 South Central Education Service Center Nov 19, 2013 Southwest Plains Regional Service Center Nov 20, 2013 Smoky Hill Education Service Center, Hays Nov 21, 2013 Smoky Hill Education Service Center, Salina Nov 25, Topeka

Today’s Topics: State & Federal Update General E-rate Information
Understanding Eligible Services E-rate Process Avoiding Pitfalls Questions

Support for the Process
KSDE E-rate listserv weekly + posts Send to With message: Subscribe KS_Erate Firstname Lastname USAC Weekly Newsbrief Service Center Staff! Kansas E-rate Hotline (thru 6/2014) Melinda Stanley:

State & Federal Updates
E-rate Modernization / E-rate 2.0 /ConnectED Other Universal Service Programs: Lifeline State Broadband Initiative: Dept of Commerce Community Pilots (Dodge City, Fort Scott/Bourbon Cty, Shawnee County, Douglas County) State Broadband Map: Gigabit Library Pilot Education Superhighway Partnership KS Speed Test Month Internet Pricing Portal

General E-rate Information
E-rate Organization Federal Communication Commission (FCC), currently oversees E-rate program Universal Service Administrative Company (USAC), administers the E-rate program Schools and Libraries Division (SLD) is the part of USAC with responsibility for the E-rate program Congress directed the FCC to establish the Erate program in 1996 The FCC sets rules and policies through ‘orders’ USAC develops procedures for specific actions, such as how to process applications

E-rate Timeline Commitments are made by funding year (FY) which runs from July 1 through the following June 30 USAC refers to the funding year as the year in which most services will begin FY 2013 is July 1, 2013-June 30, 2014

Funding for E-rate The FCC capped program funding at $2.25 billion per year until 2010 when the FCC began to adjust the cap annually for inflation Once a year, the FCC is required to roll over all unused funds from prior funding years to the next full funding year $2.29 billion annually

E-rate Eligibility Who is eligible for funding? Elementary and secondary schools and school districts Libraries and Library Systems Consortia – groups of eligible entities that band together to aggregate demand and negotiate lower prices

E-rate Discounts How large are the discounts on eligible products and services? 20%-90% of eligible costs Discount level for a school or library depends upon: Percentage of students who are eligible for the National School Lunch Program (NSLP) in the school Urban or rural location of the school KSDE NSLP Free & Reduced Data: KSDE can provide F/R Validation if requested.

General E-rate Information What’s My Discount
General E-rate Information What’s My Discount? Understanding the Discount Matrix INCOME % of students eligible for NSLP URBAN LOCATION Discount RURAL LOCATION Discount If the % eligible is... ...and you’re in an URBAN area, your discount will be... ...and you’re in a RURAL area, your discount will be... Less than 1% 20% 25% 1% to 19% 40% 50% 20% to 34% 60% 35% to 49% 70% 50% to 74% 80% 75% to 100% 90% USAC Urban/Rural Status:

Year AFTER Year Before E-rate Cycles Item 21 reviews
Additional Certifications Hopefully receive Funding Commitment Letter Year Before

Understanding Eligible Services
E-rate Categories of Service Priority 1 (P1): funded first Telecommunications Services Internet Access Telecommunications Priority 2 (P2): funded second and starts with neediest applicants Internal Connections Basic Maintenance of Internal Connections Miscellaneous Interconnected Voice over Internet Protocol (VoIP) Eligible Services List Published Annually (FY14 released Oct 22, 2013) Priority 2 connections are funded at the 90% level then move ‘down’, i.e.89%

Understanding Eligible Services Priority One
Telecommunications Services Digital Transmission Services Digital Subscriber Line (DSL) Primary Rate Interface (PRI) T-1, T-3 Satellite Service

Not Eligible as Telecommunications Services Broadcast ‘Blast’ Messaging Monitoring services for 911, E911 or alarm telephone lines Services to ineligible locations End-user devices Cell phones, tablet devices, netbooks and computers

Eligible Services List 2014
Eligible Services List for FY 2014 has been approved by the FCC. The following minor change was included: Applicants may seek web hosting services from a single provider and may not request funding for multiple web hosting providers (i.e., there can be only one host of a school’s basic website) Interactive webhosting features, such as blogging, are not eligible as stand-alone services

Understanding Eligible Services Priority One
Internet Access Support for Internet Access includes charges to access the Internet and costs for the conduit to the Internet Other eligible Internet Access services include: service Wireless Internet access Interconnected VoIP Web hosting

Not Eligible as Internet Access Costs for Internet content Subscription services such as monthly charges for on-line magazine subscriptions Internet 2 membership dues Website creation fees Web-based curriculum software Software, services or systems used to create or edit Internet content

Understanding Eligible Services Priority Two
Internal Connections Support for equipment and cabling on-site that transport info to classrooms or public rooms of a library Subject to the Two-in-Five Rule Entities can only receive funding every two out of five years

Understanding Eligible Services Priority Two
Basic Maintenance of Internal Connections Support for basic maintenance of eligible internal connections such as: Repair and upkeep of hardware Wire and cable maintenance Basic tech support Configuration changes

Not eligible as Internal Connections End-user components Computers, laptops, tablets, speakers, white boards Most software Anti-virus, anti-spam, curriculum or productivity software Spare parts Intercom or public address (PA) systems

Bundled VOIP Handsets The eligible services list states:
“The following charges are NOT ELIGIBLE for E-rate support: End User Equipment. Support is not available for end-user equipment.” Be wary of vendors trying to bundle phone handsets with VOIP service, calling the phones, “free” Leased gateway or router is eligible FCC going to issue more formal guidance in the next few months on this issue

FY 2014 & Beyond Funding Projections

Funding Predictions for FY 2014
Let’s look at FY 2013 $2.38 billion available Demand for Priority 1 (telecom and Internet) is $2.709 billion an increase of 10.8% from last year FCC rolled over $450M in unused funds from prior years to be able to fund all eligible Priority 1 requests Demand for Priority 2 (internal connections) at 90% discount level is $1.76 billion If P1 grows again by 10%, P1 demand will be almost $3 billion

Funding Predictions for FY 2014
P1: Doubtful that FCC would not find funding to cover all P1 requests P2: There is very little chance that any P2 funding will be available for FY 2014 unless the FCC institutes major reforms

Questions Thus Far?

You already know the process is simple….Right?
Tech Plan 470 Contract 471 FCDL 486 Bear/SPI RNL BID RAL 472 or 474

E-rate Process Technology Planning
FCC Form 470 and Receipt Notification Letter (RNL) Competitive Bidding FCC Form 471 and Receipt Acknowledgement Letter (RAL) Application Review and Funding Commitment Decision Letter (FCDL) FCC Form 486 FCC Forms 472 (BEAR) and 474 (SPI) USAC Flow Chart of Process:

E-rate Process 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 online USAC issues a PIN to every new authorized person Request for Proposals (RFP): a bidding document (not required by Erate) that provides detailed information about your services, locations, bid submission requirements FCC Form 470 Receipt Notification Letter (RNL): a letter issued by USAC to the applicant that summarizes the information provided in the FCC Form 470 USAC Acronyms & Terms

E-rate Processs Acronyms and Terms
Allowable Vendor Contract Date/Contract Date (ACD): the date 28 which marks 28 days after the FCC Form 470 is posted to the USAC website Funding Request Number (FRN): the identification number assigned to a funding request Service Provider Identification Number (SPIN): the identification number assigned by USAC to a service provider Item 21 Attachment: the description of services associated with a funding request Item 21 attachments can be submitted online, by fax, , or on paper

E-rate Process Acronyms and Terms
Receipt Acknowledgement 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 Ministerial and clerical errors can be corrected until USAC issues the Funding Commitment Decision Letter Program Integrity Assurance (PIA): the USAC group that reviews and makes funding decisions on your application Funding Commitment Decision Letter (FCDL): a letter issued by USAC to the applicant and the service provider that contains commitment decisions on funding requests Applicants and Service Providers should carefully review their FCDL for details on approved or denied requests and your next steps and next steps

E-rate Process Technology Planning
A technology plan must contain the following 4 elements: Goals and strategies for using technology to improve education or library services Needs assessment Staff training Evaluation plan KSDE Tech Plan Info & Resources: Beginning with Erate Year 2011, if you are only requesting Priority 1 services, a technology plan is not required by the Schools and Libraries.

E-rate Process Requesting Service
FCC Form 470 Purpose Opens your competitive bidding process Notifies potential bidders of the types and quantities of services that you need Must be posted on the USAC website at least 28 days before filing the FCC Form 471

E-rate Process Requesting Services
Applicants must ensure they post for the correct category of services New FCC Form 470 combines Telecommunications and Internet Access Sufficient detail in FCC Form 470 to enable service providers to formulate bids Be specific on what you put on your Form 470….don’t copy and paste from the Eligible Services List

Changes to Form 470 Use old form until new one comes online (expected to be the end of November) New form will consolidate Telecommunications and Internet into a single “Priority 1 Services” category on the Form 470 Must continue to distinguish between Telecom/Internet on the Form 471 If you select the wrong category on the 471, PIA will not deny, but will reach out to you and ask you to change

Applicants may set some eligible services requirements May require service providers to provide services that are compatible with one kind of system over another Cannot list specific make and model of services sought without also allowing equivalent products and/or services to be bid

Bid Equivalent Products
470s/RFPs cannot be manufacturer-specific known as ‘Queen of Peace Decision’ Must use the words “or equivalent” or “or compatible”. For example: NOT OK: ‘Cisco 3750 Switch’ OK: Cisco 3750 Switch or equivalent Must evaluate “equivalent” bids received In bid evaluation, may consider other factors, such as the amount of staff training required to support alternate manufacturer equipment

E-rate Process Requesting Service
Competitive Bidding Requirements Noone other than the applicant or an authorized representative of the applicant should prepare, sign or submit the FCC Form 470 or certification The Form 470 must describe the desired products and services with sufficient specificity to enable interested parties to submit bid responses

New RFP Definition At the USAC training this year, it was stressed that if an applicant posts a 470 and then provides additional written instructions or information to bidders, this would constitute an RFP for E-rate purposes and therefore the box indicating you have an RFP should be used on the 470 Providing building addresses is ok Answering written questions from vendors is ok

Competitive Bidding Process All potential bidders must have access to your FCC Form 470 or RFP Applicants must ensure that the competitive bidding process is open and fair You must keep all incoming bids/correspondence with bidders and prepare to evaluate bids equally You must evaluate the incoming bids fairly and equally Encourage bidders to submit their most cost effective solutions by providing options.

Retain all vendor selection documentation for at least 5 years from the last date to receive service Winning and losing bids, correspondences, memos, bid evaluation documents, etc. Service Providers are required to offer applicants their services at the lowest corresponding prices charged to other similarly situated customers throughout their geographic service area Ensures schools in the Erate program are not charged more for the same services because of their participation

E-rate Process Bid Evaluation Matrix Requesting Services
Price needs to be on every matrix and weighted heavier than any other criteria Sample Bid Evaluations:

Erate Process Competitive Bidding
After the 28 day waiting period closes, on the 29th day, you can: Evaluate bids received Choose your service provider (s) Sign a contract (if applicable) Submit an FCC Form 471

Examples of Rule Violations The applicant has a relationship with a service provider that would unfairly influence the outcome of a competition or furnish the service provider with ‘inside’ information Someone other than the applicant or an authorized representative of the applicant prepares, signs, or submits the FCC Form 470 and certification

Examples of Rules Violations A service provider representative is listed as the FCC Form 470 contact person and that service provider is allowed to participate in the competitive bidding process The FCC Form 470 does not describe the desired products and services with sufficient specificity to enable interested parties to submit bid responses

After the 28 day waiting period closes, on the 29th day you can: Evaluate bids received Choose your service provider (s) Sign a contract (if applicable) Submit an FCC Form 471

Erate Process Ordering Services
FCC Form 471 purpose Identify the service providers and eligible services you have chosen Identifies the eligible schools that will receive services Calculates how much support you seek for the year Includes your discount calculation information Certifies your compliance with program rules

New 471 Coming, Too New 471 will be available when window opens in January Biggest Block 2 removed in lieu of other questions in Block 5 More info will follow!

Erate Process Begin Receiving Services
FCC Form 486 Purpose Notifies USAC that your eligible services have started or been delivered and invoices for those services can be processed and paid Certify compliance with Technology Plan requirements (if applicable) Certify compliance with the Children’s Internet Protection Act MUST be filed within 120 days of Service Start date or FCDL issue date

Erate Process Invoicing
Requirements before invoicing USAC: Applicants and service providers receive a FCDL from USAC for the services being invoiced Applicants must file an FCC Form 486 and receive an FCC 486 notification letter Service providers must file an FCC Form 473 (Service Provider Certification) each funding year

Erate Process Invoicing
2 Methods of Invoicing: Billed Entity Applicant Reimbursement (BEAR) Form 472 filed by applicant after services have been paid in full (refund method) Service Provider Invoice (SPI) Form 474 is filed by the service provider after the applicant has been billed for the non-discount portion of eligible vendors (discount method) Note Applications can choose their method of invoicing; service providers cannot force applicants to use a particular method

Do you have $ on the table for FY 2012?
List by district as of Oct 22, 2013 posted online at: Missing Invoice = Completing homework & not turning it in .

Erate Process Application Deadlines
Form 470 Posted at least 28 days before the filing of the Form 471, keeping in mind the Form 471 application filing window has specific opening and closing dates Form 471 Received or postmarked no later than 11:59 pm EST on the day of the close of the Form 471 filing window Form 486 Received or postmarked no later than 120 days after the Service Start Date OR the date of the Funding Commitment Decision Letter, whichever is later. Form 472 BEAR (Unless Service Provider Discounts) Invoice the SLD no later than 120 days after the last date to receive service or the date on the Form 486 Notification Letter, whichever is later. Can file an extension if you miss the date. Automatic extension for FY2012. Requires Service Provider signature.

Erate Process Document Retention
All applicants and service providers are required to retain receipt and delivery records relating to the technology plans, pre-bidding, bidding, contracts, application process, invoices, provision of services, and other matters relating to the administration of universal service for a period of at least five years from the last date of service. Technology Plan (drafted by 470 Posting- approved by SSD) Technology Plan Approval Letter RFPs or similar documents All bid responses and correspondence Bid evaluation (scoring rubric) Contracts, service agreements, addendums, etc. Eligibility (school charter, accreditation) Consortium LOA Discount (NSLP) Item 21 attachment(s) Budget CIPA compliance documents Purchase requisitions, Pos, packing slips, customer bills Delivery and installation records Maintenance logs Inventory records Payments (cancelled checks, credit card receipts, etc.)

FY 2013 (Year 16) Details For services rendered 7/1/2013 - 6/30/2014
FY 2013 is PINK Priority 1 FCDL’s: USAC very behind other years File the 486 after FCDL arrives Request discounted bills from vendors, if desired Watch KS E-rate Listserve closely Is your Form 486 due? Check the list (as of 10/22/13): Haven’t been funded? the USAC Ombudsman Include your BEN and 471 #

FY 2014 (Year 17) Details For services rendered 7/1/2014 - 6/30/2015
FY 2014 is BLUE 471 application window will likely open on or about January 8 and will close on or around March 18 Form 470’s being accepted now! Don’t wait until Jan to file, especially if you need to take contracts to your board File by Thanksgiving!

E-Certification/PINs*
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 HINT: Don’t make the BEAR Form the first one you sign as USAC will issue a BEAR-only PIN

Gifts and Donations Prizes at Conferences and Training Raffle tickets, prizes, or door prizes that have a retail value of over $20 violate the gift rules unless the event is open to the public. “Open to the public” means the event is free of charge and that members of the public at large typically attend such a gathering. Free Community 4th of July celebration could qualify. State District IT Directors meeting would not qualify.

Gifts and Donations Conferences – Impermissible Actions
Training or conference regarding one or a few vendors services would not meet the definition of a Widely Attended Event even if many people attended. Travel expenses, lodging, meals, and entertainment associated with the event would be considered gifts and therefore violations. Free attendance when it would otherwise cost to attend is also a violation. Meals at a Widely Attended Gatherings not provided to all attendees would be subject to gift limits.

Avoiding Pitfalls Submitting paper forms containing errors
Incomplete PIA responses Missing or incomplete Item 21 attachments Ignoring USAC letters Poor invoicing practices Inadequate document retention Not managing your E-rate process Submitting paper forms containing errors Missing deadlines Not following competitive bidding rules Not communicating with service providers after the competitive bidding process Mixed bucket funding requests Incorrect discount calculations Additional Info:

Avoiding Pitfalls Missing deadlines
Many FCC forms and requests are subject to deadlines. Missing a deadline can have negative consequences, including: An FCC Form 471 submitted after the close of the filing window will not be considered for funding. An FCC Form 486 submitted after the deadline will have its service start date adjusted to the date 120 days before receipt or postmark of the form. Invoices for services delivered before the adjusted service start date will not be paid. An appeal submitted after the 60-day deadline will be dismissed. An invoice submitted after the invoice deadline will be rejected. To resubmit, an invoice deadline extension request must first be submitted to USAC and approved. Ministerial or clerical error corrections submitted after the FCDL is issued will not be made by PIA. PIA questions that are not answered result in a decision based on the information at hand, which may lead to a reduction or a denial.

Avoiding Pitfalls: Closing the Loop
Show me the $: Avoid Poor Invoicing Practices USAC must be invoiced – either through the applicant FCC Form 472 (BEAR Form) or service provider FCC Form 474 (SPI Form) – for discounts on services actually delivered and installed. Delays or denials can occur if: Invoices are filed after the invoicing deadline. Invoice-related forms are not filed first (FCC Form 486!) Invoice entries are incomplete or inconsistent. If the invoice undergoes review, provide requested documentation!

Avoiding Pitfalls Managing Your E-rate Program Process Plan Ahead
Schedule time to complete/file forms—and include upcoming deadlines on your calendar. Subscribe to the E-rate Listserv & USAC Newsbrief! File forms early. Invoice to collect the funding as soon as the FY ends! Identify a back-up, just in case. File everything, keep all documentation. Communicate with your Service Provider.

Managing the Process E-rate Binder: For Each Year
USAC Binder Divider Labels USAC Binder Table of Contents USAC Process Flow Chart USAC Terms & Acronyms: USAC issued paperwork are color coded by Year FY 2013 is PINK FY 2014 is BLUE USAC Search Tools to check Forms Status:

Managing the Process We’ll help you along the way:
Do you have funds from FY2012 yet to claim? Do you need to file a form 486 for FY 2013?

Resources www.usac.org/sl
Erate resources! Melinda Stanley, KSDE KS E-rate Hotline: (thru 6/30/14)

Questions?

Kansas K-12 E-rate Training

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