FUNDING YEAR 2012: COMPLETING FORM 470 Funding Year 2012: July 1, 2012-June 30, School Year

Topics for today’s session 1.What are some helpful resources? 2.What is the purpose of form 470? 3.Form 470: Common errors made in filing 4.What’s new with the E-rate program in 2012? 5.Form 470: We’ll walk through the online form

Numbers to remember SLD Client Service Bureau – Pam Jacobs (schools and districts) – – Jay Peterson (public libraries) – –

Online resources Actual online filing: Funding commitments/disbursements: Iowa E-rate information

What is the purpose of form 470?

To open the competitive bidding process for the E-rate services you seek. This form is required prior to filing form 471. There is a required 28-day “waiting period” between form 470 filing and 471 filing.

E-rate Timelines 1.Complete an E-rate tech plan (required if applying for priority 2; not required if only filing for priority 1) 2.Form 470 (File any time between now until early December) 3.Wait at least 28 days after filing form Select provider and sign contract (if applicable) 5.Form 471 (deadline is likely early March 2012). Form 471 is often called “the application” 6.Answer questions/call from PIA (March-?) 7.Funding commitment decision letter 8.Form No discounts on bills? File form 472/BEAR form

4-pronged test for Eligibility Requirements for eligibility: – Must be an eligible product or service – Used by an eligible entity – Used at an eligible location – Used for an eligible purpose

Do I file form 470 every year? Question: Do I have to file a form 470 every year? Answer: Yes, if you are applying for month-to-month services, you must file form 470 every year. Yes, if you want to sign a new contract, you must file a form 470. No, if you have an existing multi-year contract that meets certain conditions (more info is provided later in this presentation)

Form 470: How many separate 470 forms to file? Your choice! You may file one form 470 OR You may file a separate form 470 for each type of service Recommendation: If you are applying for internal connections or basic maintenance, file a separate form 470 for these priority 2 services

Common Errors in filing form 470

Form 470: Common errors made in filing Error 1: Applicants don’t wait the full 28 days before choosing a service provider or signing a new contract FIX: Wait at least 28 days!

Form 470: Common errors made in filing Error 2: Applicants do not properly keep records of their bid evaluation process. Fix: (See the following slide for guidance).

Bid evaluation process SLD is getting more particular about documenting a fair and open bidding process 1.Have a written process for evaluating bids and criteria for selection prior to selecting your provider and signing a contract. 2.Keep a record of bids received!!! (not just the winning bid). 3.Complete your bid evaluation document, even if you just received one bid. 4.Date the completed bid evaluation document to show you waited at least 28 days to make your vendor selection.

Must I accept the lowest bid? No, not according to e-rate rules…but cost must be the primary consideration Other factors might be prior experience of vendor, qualification of personnel, financial stability of the company, service that meets the needs of your school/library, in-state preference For sample bid document, see raining/samples-checklist-vendor-selection- templates.pdf raining/samples-checklist-vendor-selection- templates.pdf

May we sign a contract? Yes, but only after the “allowable contract date” of 28 days Include contingency language in case you don’t get funded, especially for internal connections

What if we already have a contract for school year? Did you already file form 470 in a previous year “establishing” this contract? (If you’re not sure your 470 qualifies to “establish” a multi-year contract, contact me and I’ll check it over with you). Does the contract cover ALL of school year? If both above statements are true, you do not need to file form 470 for this service. You will have to file form 471 in order to get funding.

Form 470: Common errors made in filing Error 3: Not enough quantity and/or capacity requested for telecommunications services and/or Internet FIX: Don’t limit your capacity. Use words like “no less than 8 cellular phone lines” or “minimum of 3 mps”. Avoid using words like “8 phone lines.”

Cellular data services Very important: If you are filing for cellular data services (e.g. Smartphone-type services or wireless “card” service), indicate this on form 470 in two places: Telecom services and Internet services When you get to form 471, you will select only one of the above types of service

Form 470: Common errors made in filing Error 4: Form 471 requests services not listed on form 470 (forgot some services on form 470) FIX: You may file more than one form 470 (but must wait 28 days before selecting a service provider and signing a contract)

Question What about companies that offer bundled services? (such as phone service and Internet in one package) How do I fill out form 470? (which category of service?) – Answer: Internet may be provided by a either a telecommunications provider or non-telecommunications provider. If you’re considering bundled service across 2 categories, you must state on form 470 under telecomm services category that you will consider bids bundled with Internet service. Also repeat the same description under the Internet category too.

Question? What if I put a service in the wrong category? (e.g. put “local phone service” as Internet?) – Answer: May result in NO FUNDING! If in doubt, list under 2 categories on form 470 (e.g. telecomm services and Internet)

Question? What about the section of the eligible services list that isn’t category specific? – Answer: To date, telecomm and Internet are leased services. Internal connections MAY be purchased goods and services.

What’s new for E-rate funding year 2012?

What’s new with E-rate for funding year 2012? New item 1: CIPA (applies only to districts/schools/AEAs) By July 1, 2012, amend your Internet safety policy (if you haven’t done so) to provide for monitoring of online activities of minors and the education of minors in appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms, cyberbullying awareness and response.

CIPA changes Your school/district/AEA is not required to have a new public notice and hearing for this policy change (assuming you have record of previous action) If you don’t have a record of the public notice and hearing for the original establishment of the Internet safety policy, it is recommended that you refresh the record by posting public notice and holding a public hearing.

CIPA reminders CIPA reminders: The following are already required if requesting discounts on Internet and/or internal connections: 1.Internet safety policy 2.Public notice of – and public meeting or hearing on – the Internet safety policy 3.Technology protection measure (filter)

CIPA reminders Your school/district/AEA does not have to buy an Internet safety student curriculum! There are plenty of great/free online resources. See Also see Common Sense Media (requires free online registration):

CIPA reminders Local school and library authorities must determine what matter is inappropriate for minors. Social networking sites are not automatically considered harmful to minors. Put into local policy how your school or library locally interprets the requirements and make sure your implementation aligns with the policy. (Do what you say you’re going to do).

CIPA reminders The following is not yet determined by FCC. Public comment likely to be sought on the following type of question: Do CIPA requirements apply to the use of portable devices owned by students and library patrons when those devices are used in a school or library to obtain Internet access funded by E-rate?

CIPA reminders Keep some sort of documentation to show filtering/technology protection measure is in place (e.g. bill from vendor of filtering software; sample of a couple computer logs showing filtering, etc.) (Schools/districts/AEAs only): Keep some sort of documentation that the education of minors occurs (e.g. copy of the curriculum used; sample lesson plan from teachers, etc.)

CIPA resources For a detailed discussion of CIPA requirements: Children’s Internet Protection ActChildren’s Internet Protection Act website guidance Form 486 Instructions Form 479 Instructions For more details on CIPA, see recent USAC training slides at sessions/training- 2011/fall/presentations.aspx#presentationshttp:// sessions/training- 2011/fall/presentations.aspx#presentations

What’s new for E-rate funding year 2012? New item 2: Have the deadlines been set? No, the deadlines are not yet set. However….. USAC predicts the 471 “window” will open in early January and close in early-mid March. To meet the 28-day waiting period between filing form 470 and filing form 471, it is recommended that you file form 470 no later than early December.

What’s new with E-rate for the 2012 funding year? New item 3: Eligible Services List s/Daily_Business/2011/db0928/DA A2.pdf

Eligible services for funding year 2012 If you want more examples and updated details on eligible services, take a look at the USAC training slides on eligible services, especially: Basic maintenance of internal connections Leased dark fiber as priority 1 service sessions/training- 2011/fall/presentations.aspx#presentations

What’s new for E-rate funding year 2012? Item 4: Further clarification on gift rules See the following for more details FCC Rules - 47 C.F.R. § (d)FCC Rules Federal Gift Rules - 5 C.F.R. § Federal Gift Rules FCC Sixth Report and Order - 25 FCC Rcd (2010)FCC Sixth Report and Order FCC Clarification Order - 25 FCC Rcd (2010)FCC Clarification Order

Gift Rules Gift rules apply to everyone participating in the E-rate program, whether public or private, and whether operating at the local or regional level Gift prohibitions are applicable year-round, not just during the competitive bidding process

Gift Rules Gifts or prizes received at conferences are exempt from the gift rules only when such conferences are open to the public (for free) or meet narrowly-defined conditions as “widely attended events.” E-rate applicants who are not yet concerned about the gift rules might do well to reflect on a recent FCC filing on behalf of the East Central Board of Cooperative Educational Services (“ECBOCES”) which included the following point: ECBOCES believes that it is because ECBOCES employees accepted gratuities that total no more than $674 over a five-year period, USAC rescinded funding for FY2006, FY2007 and FY2008, and denied funding for FY2009 and FY2010 in the aggregate amount of $3,370, East Central Board of Cooperative Educational Services

Gift Rules USAC has requested gift clarification from the FCC about several items, including what constitutes a “widely attended event.” See USAC slides for examples about gifts, especially the slides on charitable donations and conferences and training sessions. – sessions/training- 2011/fall/presentations.aspx#presentations sessions/training- 2011/fall/presentations.aspx#presentations

What’s new with E-rate for funding year 2012? New item 5: Ministerial and clerical errors “ 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) New guidance (Ann Arbor decision) allows even more examples of errors that may be corrected prior to funding commitment decision letter.

More on ministerial and clerical errors What’s new? The 15-day rule is eliminated (for corrections only) – Corrections to 470 and 471 can be submitted until the funding commitment decision letter is issued If you made an error and your PIA review has already started, tell your reviewer right away that you made an error

More on ministerial and clerical errors If you find you made an error and need assistance to get it corrected, contact Pam (schools/districts/AEAs) or Jay (libraries)

What can I do to get ready for funding year 2012? Do you have/will you have new buildings? Have you closed any buildings? Will you have buildings closing in school year? Are buildings changing their purpose? (once were attendance centers and now are for purposes such as admin offices) Have you reorganized with another district? (or will you reorganize for ?) Have you formed a “system” (non-publics)?

Names of school buildings Want to speed up your 2012 application review? Take a look at the Iowa Educational Directory for the school year tent&view=article&id=692&Itemid= tent&view=article&id=692&Itemid=2697 Note the names of your buildings (and district/system) in the Directory If changes need to be made for school year, notify USAC. Notify me of changes as well

Contact USAC Call the USAC Client Service Bureau to notify them of changes to building names, contact person information, corrections to building addresses, etc. They may request the information in writing on school/district/library letterhead

Completing the form 470

Form 470: What’s eligible for funding Requirements for eligibility: – Must be an eligible product or service – Used by an eligible entity – Used at an eligible location – Used for an eligible purpose

Form 470: What’s eligible for funding? Five categories of services: – Telecommunications services(priority 1) – Telecommunications (priority 1)* – Internet access (priority 1) – Internal connections (priority 2) – Maintenance of internal connections (priority 2) *There’s no separate filing area on form 470 or 471 for this category of service.

Examples of telecomm services Local telephone services Long distance telephone service Cell phone service Text messaging on cell phone Cellular data service/Internet access (Smartphone type service or wireless access “card” service)…also list under Internet access Service to bus barns, custodial facilities, etc. IS eligible!!!!!!!

More examples of telecomm services Centrex Leased circuits (e.g. data circuit to connect your elementary school to the high school) E-911 and 911 lines Voic service (not just considered telecomm service)

Examples of telecommunications category for funding year 2011 This category primarily includes “dark fiber” or leased lit fiber provided by a non-telecomm provider New

Telecommunications There is no item on either form 470 or form 471 for “telecommunications.” On form 470, list and describe dark fiber under both telecommunications services and Internet services

Internet services examples Internet access Wireless Internet access (via wireless “cards”) Domain Name Service (DNS) registration Cell phone data service (e.g. Smartphone type service or wireless access “card” service) for Internet access..also list under telecommunications service

Internet service examples – Web hosting service (not purchase of web server) – Firewall service if included as a part of bundled Internet service (not purchase of firewall software and not as a separate line item; see ESL page 9)

Internal connections These are priority 2! Should I apply? Yes, if your district/school/library needs the eligible goods and services Unused funds from previous years have been rolled into funding year All eligible applicants in 2010 got priority 2 funding.

Internal connections NOTE: priority 2 is the only category where items may be purchased by school/library NOTE: Tech plan is required for all priority 2 requests!!! 2 in 5 rule applies for internal connections (an eligible location may only receive E-rate funding every 2 years out of 5)

Examples of internal connections LANs Routers Switches Hubs Network servers Wireless LANs/wireless access points PBX (private branch exchange) See ESL for more examples and details

Priority 2 Internal connections Internal connections examples

Basic maintenance of internal connections Should I apply? Yes, if you plan to have a third party provide maintenance of internal connections 2 in 5 rule does NOT apply for maintenance (even though this is priority 2)

Basic maintenance of internal connections Support for basic maintenance of eligible internal connections (BMIC) Such as: – Repair and upkeep of hardware – Wire and cable maintenance – Basic tech support – Configuration Changes

Basic maintenance of internal connections Agreements or contracts must state the eligible components covered, make, model and location Service must be delivered within the July 1 st to June 30 th timeframe

Basic maintenance of internal connections Applicants may make estimates based on: – Hours per year of maintenance – History of needed repairs and upkeep – Age of eligible internal connections Applicants using the factors listed above must submit a bona fide request It is not reasonable to estimate an amount that would cover the full cost of every piece of eligible equipment.

Basic maintenance of internal connections Flat rate contracts may be eligible however, applicants may only invoice for services actually delivered/work performed. Exceptions that will not require demonstration that work was performed are: – Software upgrades and patches – Bug fixes and security patches – Online and telephone based technical support

Check out e-rate applications from previous years Dig out old 470 and 471 forms Don’t limit yourself in bandwidth and services (think ahead)

Form 470: Block 1 – Item 5c: “Number of Eligible Entities for which services are sought” (How many buildings, including locations like bus barns, that will receive any E-rate services?) – Item 7: Do not attempt to complete this. This item is only completed by a paid consultant who is filing on your behalf.

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

Iowa counties which are urban: Black Hawk Dallas Dubuque Johnson Linn Polk Pottawattamie Scott Warren Woodbury

Online filing

Should I e-certify? E-certify an option only if – Your principal/supt/authorized person filed a signed and data entered 471 and/or 486 in previous year(s) – Call SLD’s Client Service Bureau if you need a pin number ( ) – Special Pins for BEARs-only (online BEAR filing)

What if we can’t/don’t want to e- certify? Print certification/signature page (as directed on form 470) Have supt/director/authorized person sign Still recommend you use blue ink Mail certification/signature page with return receipt

If you don’t e-certify Use the certification page from the online filing DON’T just copy the cert page of the mail-in version

Final steps: Print and/or electronically save a copy of the completed 470 for your files Photocopy your cert page (if paper cert) Keep the completed copy in e-rate notebook/files (electronic copies are fine) Check to see if your form really was postedwww.sl.universalservice.org/sl/

How do I know my 470 was filed? 2 ways to check – – You will receive a receipt in the mail! Keep the receipt letter (on canary/yellow paper for 2012)

Why should I check about filing? To check the “allowable contract date”…this is the earliest date you may file form 471! Don’t pick a service provider before the 28 days is up!

Are you on the helpful E-rate listservs? (primarily for schools/districts and libraries). Send Debbie Fiscus a message (primarily for libraries). Sign up at the url or contact Jay Peterson.

Numbers to remember SLD Client Service Bureau – Pam Jacobs – – Jay Peterson – –