Presented by: Bob Rice, President Triple R Consultants E-Rate Top 10 things you need to know! ©2011 Triple “R” Enterprises, Inc.

Introduction o Who We Are o What We Do o Session Goal

Session Overview o Recent Orders made by the FCC regarding USF E-Rate funding for schools indicate changes ahead for funding years 2011 and 2012 o This session will provide you with important information regarding these “new” FCC rules and how they will impact your E-Rate bidding and application processes

#10 Community Use o E-rate Discounted Service s Only some of the E-rate funded services Cannot charge for any E-rate funded services May charge fees for community use of facilities and/or computers Optional and based on school’s own policy(ies) Must be outside of school hours o Community Use Policy(ies) Responsible for developing policy(ies) and hours for community use of facilities outside of school hours Urged to post these policy(ies) and hours publicly on the school’s website

# 9 Program Integrity o Record Retention Applicants and service providers must maintain E-rate program documentation for a period of at least 5 years from the last date of receiving products and services If Department of Justice (DOJ) is involved, the time limit does not apply Archive all E-rate documents after the 5 year period expires E-rate requirements and list of documents to retain can be found on USAC/SLD website:

#9 Program Integrity o Gift Restrictions Prohibits E-rate applicants from soliciting or accepting any gift or other thing of value from a service provider participating in or seeking to participate in the E-rate program Consistent with the gift rules applicable to all federal agencies which permit only certain de minimis gifts Applicants must adhere to and follow the most stringent provision relating to the acceptance of gifts from a vendor Applicants have been and are required to certify on the Form 471 that they have not received anything of value or a promise of anything of value other than the services and equipment requested on the form

#9 Program Integrity o Consultant Information Applicants must identify the consultant, if any, used to assist in the E-rate competitive bidding and application process(s) Applicants must indicate on the Forms 470 & 471 whether the consultant is “Authorized”  Must have authority to procure and order products and services on the applicants behalf  Must have authority to make certifications on the applicants behalf  Must supply a Letter of Agency (LOA), upon request by USAC/SLD

#8 Program Compliance o Program Quality Assurance Program (PQA) The number of assessments fluctuates monthly Information is used to calculate estimates of improper payment rates across all USF programs, including E-rate Increases amount of document requests by USAC 10 days to comply with additional time - if needed USAC will seek to recover funds if there is a rule violation associated with payments under assessment

#8 Program Compliance o Invoice Certifications Service providers are required to submit detailed invoices sent to the applicant to support the requested products and services Service Providers must complete, sign and date a Service Certification for SLD Invoices (SCSI) Applicants are required to certify that products and services have been installed and/or received

#7 Dark Fiber o Leased Dark Fiber Must be the most cost effective solution and lit immediately upon installation Categorized as either Telecommunications or Internet Access Limited eligibility for installation and maintenance o Ineligible Costs Lighting dark fiber Special constructions costs Acquiring unneeded capacity

#6 Errors and Corrections o Clerical and Ministerial Errors 2006-Bishop Perry Order (RAL and RNL) 2011-FCC Order extends the deadline for corrections until receipt of the Funding Commitment Decision Letter (FCDL) May increase document requests by USAC/SLD Applicants must appeal to FCC for making any corrections after the FCDL date

#5 Technology Plans o Tech Plan Rules Applicants must have a written plan before filing the Form 470 for Priority 2 products and services only Add a creation date on tech plan cover page The budget element is no longer required for E-rate o Form Certifications Applicants certify on Forms 470 and 471 that their requests for services will be based on a technology plan – if required by program rules Tech plans must be approved prior to the start of the funding year (July 1) or the date the Form 486 is submitted to USAC – whichever is first

#4 Basic Maintenance of Internal Connections (BMIC) o Eligible Basic Maintenance The agreement must specify the eligible components covered The service must be for basic maintenance services only Applicant invoice requirements o Ineligible Basic Maintenance Services more than basic Unbundled warranties Eligible vs. Ineligible service agreements

#3 Service Provider Identification Number (SPIN) Changes o SPIN Change Requests Corrective SPIN Changes Operational SPIN Changes Must comply with Form 486 deadline o Allowable SPIN Changes (Began FY2011) Breach of contract Service provider unable to perform Newly selected service provider must be the next highest point value in bid evaluation Must receive FCDL prior to submitting change

#2 Competitive Bidding o Bidding Process All E-Rate bids must be “Fair and Open” As many bidders as possible so applicants receive better services and lower prices The bid must describe specific services or functions for support - No generic or encyclopedic descriptions o Form 470 Must be completed by the negotiating party Must be ready to accept any/all bids Service providers who prepare or certify forms cannot bid Must follow own state and local procurement laws All tariffed/month to month services or “new” contracts for services must be rebid each year May use an RFP in addition to the Form 470

#1 Children’s Internet Protection Act o CIPA Compliance Must enforce an Internet safety policy Must have a technology protection measure in place (CIPA filter) o Internet Safety Policy Must be in place prior to receipt of service and address specific issues Beginning FY2012 must comply with the Protecting Children in the 21st Century Act Beginning FY2012 must retain a copy for 5 years Must give reasonable public notice Forms compliance and certifications

Questions & Answers P.O. Box 302 South Lyon, MI Phone: