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Fall 2011 Library E-Rate Training
E-Rate FY2012 Fall 2011 Library E-Rate Training
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Today’s Agenda Understanding the Basics OPLIN News CIPA Update Break
Correcting Ministerial & Clerical Errors Eligible Services Break or Lunch on Your Own Form 470 Step - by - Step
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Understanding the Basics
Overview General information about E-Rate Technology planning Requesting services (FCC Form 470) Competitive bidding process Ordering services (FCC Form 471) Application review & funding commitments Begin receiving services (FCC Form 486) Invoicing USAC (FCC Form 472 and FCC Form 474) Deadlines
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General E-Rate Information
E-Rate Organization Federal Communications Commission (FCC), an independent U.S. government agency, established and oversees the E-Rate program Universal Service Administrative Company (USAC), a not-for-profit, administers the E-Rate program along with three other programs Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-Rate
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General E-Rate Information
E-Rate Rules Congress directed the FCC to establish the E-Rate program in 1996 The FCC sets rules and policies through orders Policies are defined in the text of orders USAC/SLD develops procedures for specific actions, such as how to process applications
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General E-Rate Information
E-Rate Timeline Commitments for E-Rate 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 E.g., FY2010 is July 1, 2010 – June 30, 2011
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General E-Rate Information
E-Rate Budget The FCC has set the E-Rate fund at $2.25 billion for each funding year. However, beginning in FY 2010, the cap is now adjusted for inflation each year Cap is now $2.29 billion Once each year, FCC can roll over unused funds from previous funding years into the current funding year Money for ALL FY2010 Applications at all discount bands $850 million for FY2011 Applications
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General E-Rate Information
E-Rate Eligibility Who is eligible for E-Rate funding? Schools and school districts Non-traditional facilities (conditionally by state) Libraries and library systems Consortia – groups of eligible entities that band together to aggregate demand and negotiate lower prices
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General E-Rate Information
E-Rate Discounts How large are the discounts on eligible products and services? Discounts= 20% to 90% of eligible costs 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 2) Urban or rural location of the school or library → Determine Your Classification
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School District’s October Data reported to ODE can be found in the MR-81 document located at From the ODE website, search for MR-81 Numbers to use: Total Student (ADM) Count Combined Free/Reduced Lunch Count
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General E-Rate Information
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%
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General E-Rate Information
E-Rate Categories of Service Priority 1 (P1): funded first Telecommunications Services Internet Access Telecommunications Priority 2 (P2): funding starts with neediest applicants Internal Connections Basic Maintenance of Internal Connections
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General E-Rate Information
E-Rate Forms How do I file a program form? In general, you have three options: File online, certify on paper File online, certify online File on paper, certify on paper Two versions of each online form: standard and interview *Note* USAC encourages you to file online, because online filing speeds processing and reduces errors
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General E-Rate Information
E-Rate Letters Each time you file a program form, USAC sends you a letter Letters are color-coded by funding year Blue Canary Pink *Note* When storing documents, USAC encourages you to separate your program forms & letters by funding year to better organize them.
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Filing Process Technology Planning FCC Form 470 & RNL
FCC Forms 472 (BEAR) & 474 (SPI) FCC Form 486 Application Review & FCDL FCC Form 471 & RAL Competitive Bidding FCC Form 470 & RNL Technology Planning
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Technology Planning Tech Plan Elements A technology plan must contain the following elements: 1) Goals and strategies for using technology to improve education or library services 2) Needs assessment 3) Staff training 4) Evaluation plan *Note* Starting with FY2011, if you are only requesting P1 services, a technology plan is not required
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Tech Plans Tech plan should not cover more than 3 years
Should cover the funding year (July 1 – June 30) Sufficient detail to support & validate services requested Must follow FCC rules AND applicable state or local technology plan requirements Created prior to FCC Form 470/RFP (month & year) Contains four elements (goals/strategy, professional development, needs assessment, and evaluation process) Must be approved on or before the date when you begin receiving services
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Understanding the Basics
Requesting Service (FCC Form 470)
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Requesting Service FCC Form 470 Purpose
Open a competitive bidding process (acts as an RFP) Identify and describe desired categories of service and function of the services Describe scope of your needs Notify potential bidders of the types and quantities of services that you need Must be posted a minimum of 28 days Must file yearly for month-to-month service or prior to signing a new contract For multi-year contracts, you do not need to file during the term of the contract
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FCC Form 470 & RFPs Tips for Success
Applicants must ensure that they post for the correct category or categories of service (Non-allowable correction. Must repost FCC Form 470) Sufficient detail in FCC Form 470 Cannot provide generic descriptions (e.g., “All eligible telecom services” or “Digital Transmission Services”) Cannot provide laundry lists of products and services Addendums or changes to the RFP may require applicants to re-start the 28 day period when there is a significant change to the original scope of the procurement If a service is not listed on a Form 470, you cannot list on a Form 471 *Note* RFPs are not required by E-Rate but may be used to describe specific needs and circumstances
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Requesting Service Acronyms & Terms
Billed Entity Number (BEN): an identification number assigned by USAC to each school/district or public library responsible for paying the bills An Entity Number is assigned to each individual school/building Personal Identification Number (PIN): a code assigned by USAC to applicants for use in certifying program forms online USAC issues a PIN to every new authorized person filing a paper certification for FCC Form 470, 471, or 486
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Requesting Service Acronyms & Terms
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 Allowable Vendor Contract Date (ACD): the date 28 days after the FCC Form 470 is posted to the USAC website
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Competitive Bidding Competitive Bidding Requirements
You 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 All potential bidders have access to the information from your FCC Form 470 and RFP, and they can respond to your requests Price as the primary factor: In evaluating bids, the price of the eligible products and services must be the most heavily-weighted factor in your evaluation of bids
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Price of the ELIGIBLE goods and services
Competitive Bidding Bid Evaluation Matrix (sample) 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
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Competitive Bidding 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
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Competitive Bidding Examples of Rule 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
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Competitive Bidding Choosing a Service Provider
After you close the competitive bidding process for your services (on or after the ACD): 1) You can evaluate the bids received 2) You can choose your service provider(s) 3) You can sign a contract 4) You can submit an FCC Form 471 No bids or one bid ( yourself noting the fact) Retain all vendor selection documentation Winning and losing bids, correspondences, memos, bid evaluation documents, etc.
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Understanding the Basics
Ordering Services (FCC Form 471)
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Ordering Services FCC Form 471 Purpose Provide information on the service providers and eligible services you have chosen Identify the eligible schools and libraries that will receive services Calculate and report how much support you seek for the year Include your discount calculation information Certify your compliance with program rules Must be filed on a yearly basis
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Contracts Overview Contract must be signed and dated by the applicant prior to the FCC Form 471 certification postmark date Applicant must not sign a contract before the Allowable Contract Date (ACD) Service providers may sign before the ACD
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Ordering Services Item 21 Attachment
Item 21 attachment describes the eligible products or services requested for each FRN It is a FCC Form 471 window filing requirement. It should be submitted on or before the window close. Can be submitted via Online tool, mail, fax or to USAC Remember to click SUBMIT when using Online tool Tip for Success Clearly label the Item 21 attachment (Applicant name, BEN#, FRN, Page #, Application #)
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Ordering Services Receipt Acknowledgment Letter (RAL): a letter issued by USAC to the applicant and the service provider that summarizes the information provided in the FCC Form 471 Many of the entries on the form can be corrected after submission by using the RAL Ministerial and clerical errors can be corrected until USAC issues the Funding Commitment Decision Letter
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Ordering Services NIFs are eligible for Priority 1 services
Acronyms & Terms Non-instructional Facility (NIF): a school building with no classrooms or a library building with no public areas NIFs are eligible for Priority 1 services NIFs are eligible for Priority 2 services only if necessary to provide effective transport of information to classrooms or public areas of libraries
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Application Review & Funding Commitments
Understanding the Basics Application Review & Funding Commitments
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Application Review/ Commitments
During Program Integrity Assurance (PIA) USAC reviews FCC Form(s) 471 to : Check the eligibility of the schools and libraries and their discount levels Verify that the services you requested are eligible for discounts Give you an opportunity to make allowable corrections to your form In some cases, ask for additional verification of your compliance with program rules
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Application Review/ Commitments Receiving Your Funding Commitment
Following application review, USAC issues a Funding Commitment Decision Letter (FCDL) to both the applicant and the service provider(s) Applicants and Service Providers should carefully review their FCDL for details on approved or denied requests and your next steps
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Begin Receiving Services (FCC Form 486)
Understanding the Basics Begin Receiving Services (FCC Form 486)
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Begin Receiving Services
FCC Form 486 Purpose Notify USAC that your eligible services have started or been delivered and invoices for those services can be processed and paid Provide the name of the TPA that approved your technology plan Report your status of compliance with the Children’s Internet Protection Act (CIPA) Can only be filed after the Funding Commitment Decision Letter is issued
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Understanding the Basics
Invoicing USAC (FCC Forms 472 & 474)
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Invoicing USAC 2 Methods of Invoicing
Billed Entity Applicant Reimbursement (BEAR) FCC Form 472 is filed by the applicant and approved by the service provider after the applicant has paid for the services in full Service Provider Invoice (SPI) FCC Form 474 is filed by the service provider after the applicant has been billed for the non-discount portion of the cost of eligible services *Note* Applicants can choose their method of invoicing; service providers cannot force applicants to use a particular method.
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Invoicing USAC Requirements Before Invoicing USAC
Applicants and Service Providers receive an 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 Service Provider Annual Certification (SPAC) each funding year to certify that it will comply with FCC rules concerning invoicing and documentation FCC Form 473 can be filed after USAC has announced the opening of the application filing window
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Understanding the Basics
Deadlines
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Deadlines Application Deadlines
FCC Form Posted at least 28 days before the filing of the FCC Form 471, keeping in mind the FCC Form 471 application filing window opening and closing dates FCC Form Received or postmarked no later than 11:59 p.m. EST on the day of the close of the FCC Form 471 application filing window (exact date will be announced) FCC Form Received or postmarked no later than 120 days after the date of the USAC Funding Commitment Decision Letter or the service start date, whichever is later FCC Form 472/ FCC Form Received or postmarked no later than 120 days after the date of the FCC Form 486 Notification Letter or the last date that the applicant can receive service from the provider in the funding year at issue, whichever is later Appeals - Received or postmarked no later than 60 days after the date of USAC's decision letter
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OPLIN News
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a Letter of Agency (LOA) And a Form 479
OPLIN News All library organizations receiving Internet connectivity from OPLIN are required to submit: a Letter of Agency (LOA) And a Form 479
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OPLIN News LOA and Form 479s can be found at http://oplin.org/erate
Once generated, the forms must be signed, dated, and either faxed to , or scanned to Please complete ASAP so OPLIN can begin work on our E-Rate applications
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CIPA Update
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CIPA Compliance Documentation Tip:
Children Internet Protection Act requirements: Proof of public notice of public meeting or hearing Proof of public meeting or hearing Copy of Internet Safety Policy Technology protection measure (filtering) Documentation Tip: Must maintain documentation from prior years if it supports current funding year Filter documentation examples: maintenance logs, filtering logs, proof of purchase or vendor filter description
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New Requirements New “Internet Safety Training” requirements under CIPA FOR SCHOOLS – By July 1, 2012, amend your existing Internet safety policy (if you have not already done so) to provide for the education of minors about appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms, and cyberbullying awareness and response. FOR LIBRARIES – No new requirements You will not be required to provide Internet Safety Training
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CIPA Compliance If you are not currently CIPA compliant because you do not have the resources to support an Internet content filter : OPLIN will be making a free content filter available to all libraries next year. see
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CIPA Compliance Some libraries may be reviewing their CIPA compliance as a result of the new OPLIN-provided filter. You may go to and resubmit forms as often as needed until Friday, February 24, 2012, the deadline for form submission. As we put the final touches on our E-Rate applications, we will determine a library's CIPA-compliance based on the last Form 479 received from the library prior to 5:00 pm February 24.
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Clarifications Public comment
The FCC plans to seek public comment in a separate proceeding on the following issue: Do CIPA requirements apply to the use of portable devices owned by students and library patrons – such as laptops and cellular telephones – when those devices are used in a school or library to obtain Internet access that has been funded by E-Rate? The FCC may raise other issues as well.
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Ministerial & Clerical Errors
Correcting M&C Errors Ministerial & Clerical Errors
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Overview Ministerial & Clerical Errors M&C errors Corrections
What are M&C errors What is new & what is the same Corrections Allowable Non-allowable Conditional Submitting Corrections to USAC Notifications from USAC (FCDL Comments)
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Ministerial & Clerical Errors
Definition “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)
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Ministerial & Clerical Errors
What Is New? 15 Day Rule eliminated (CORRECTIONS ONLY) RNL & RAL corrections can be submitted until the FCDL is issued PIA will ask if this is a ministerial or clerical error Tell us what error occurred Provide a reasonable explanation Documentation may be requested
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Ministerial & Clerical Errors
What Is The Same? Minimum Processing Standards (MPS) for the FCC Forms 470 & 471 and Certifications FCC Forms 470 & 471 and Certifications corrections FCC Form 471 Certification must be submitted on or before the Window close 15 Day Rule still applies for responses to reviewers’ inquiries Additional documentation may be required to support your requested change
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Ministerial & Clerical Errors
M&C Errors Examples 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.)
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Ministerial & Clerical Errors
FCC Form 470 Allowable Corrections Update or change contact person and/or consultant information Billed entity information Add the authorized person signature Change or update eligible entities receiving service (Note: changes are accepted if it is not a significant change from the original scope) Certification not submitted by Window close
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Ministerial & Clerical Errors
FCC Form 471 Allowable Corrections Incorrect citation such as: FCC Form 470 number Discount percent Urban/rural status Contract number Billing Account Number/Multiple Billing Account Numbers Block 4 worksheet entries
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Ministerial & Clerical Errors
FCC Form 471 Allowable Corrections Cont’d Update or change contact person and/or consultant information Correct errors to dollars figures on an FRN Add or remove entities accidentally omitted or included in block 4 Provide accidentally omitted FRNs Amount budgeted for ineligible services (Block 6)
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Ministerial & Clerical Errors
Conditional Corrections SPIN corrections are ALLOWABLE when requesting a Corrective SPIN change Data entry errors, company merger or acquisition Contract Award Date/ Expiration Date Consortium Letters of Agency (LOA) Applicants may provide supplemental documentation dated on or before FCC Form 471 certification postmark date when: LOA service timeframe is missing or not specified Lack of detail regarding the services provided Missing consortium members
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Request SPIN change after FCDL issued
Ministerial & Clerical Errors Non-Allowable Corrections FCC Form 470: Adding Service Category Must post new FCC Form 470 FCC Form 471: Operational SPIN change Request SPIN change after FCDL issued Not allowed pre-commitment
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Ministerial & Clerical Errors
Submitting Corrections FCC Form 470 corrections submitted via Receipt Notification Letter (RNL) FCC Form 471 corrections submitted via Receipt Acknowledgement Letter (RAL) and/or during FCC Form 471 review Follow submission instructions on letter Send a copy of Block 4 Worksheet if entity changes are made
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Ministerial & Clerical Errors
Program Integrity Assurance (PIA) Review Discrepancies may be detected during PIA review. PIA will contact you when PIA is unsure an error happened. PIA will: ask if an error occurred ask if you wish to make a correction ask for an explanation request supporting documentation, if applicable
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Ministerial & Clerical Errors
Program Integrity Assurance (PIA) Review Supporting documentation examples: Contract, Service Agreement Vendor quote, bill, invoice, etc. Documented communication like s between the applicant & the service provider Source list RFP, Newspaper listing NSLP documentation or student enrollment data Board Minutes, Resolutions Budget
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Ministerial & Clerical Errors
Correction Notification PIA Review Your reviewer will inform you if the correction was completed or not (preferred mode of contact) FCDL Global Comment informs applicant that a RAL correction was received Informs the applicant about corrections affecting multiple FRNs (e.g., discounts, entity removals) appears at the top of the FCDL FRN report FRN Comment: states the specific changes
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FY2012 Eligible Services The E-Rate Program
Fall 2011 Applicant Trainings
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Eligible Services Overview Priority One (P1)
Telecommunication Services, Telecommunications, Internet Access (IA) Priority Two (P2) Internal Connections (IC) and Basic Maintenance of Internal Connections (BMIC) Miscellaneous Dark Fiber Equipment Transfers, Disposals and Trade-ins
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Priority One Telecommunications Services
Support for telecom services such as: Local and long distance service Interconnected Voice over Internet Protocol (VoIP) Cellular voice service Including text messaging, voic (For /Internet on your phone, remember to check the IA box on your 470!) Centrex Service
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Priority One Telecommunications Services
Digital Transmission Services Digital Subscriber Line (DSL) Primary Rate Interface (PRI) T-1, T-3 Satellite Service Not Eligible as Telecom Services Broadcast “Blast” messaging Monitoring services for 911, E911 or alarm telephone lines Services to ineligible locations End-user devices Cell phone, tablet computers
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Priority One Internet Access (IA)
Support for IA includes Internet Service Provider (ISP) fees as well as the conduit to the Internet Other eligible Internet Access services include: service Wireless Internet access Interconnected VoIP Web hosting
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Priority One Not eligible as Internet Access
Costs for Internet content Subscription services such as monthly charges for on-line magazine subscriptions Internet2 membership dues Web site creation fees Web based curriculum software Software, services or systems used to create or edit Internet content
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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
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Priority Two Internal Connections
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Priority Two 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
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Priority Two 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 1st to June 30th timeframe Two-in-Five Rule does not apply to BMIC
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Priority Two BMIC Updated Guidance
Standard manufacturer warranties of no more than three years remain eligible. If there is a cost associated with the warranty, then the warranty is not eligible Support for BMIC is limited to actual work performed under the contract
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Priority Two BMIC Updated Guidance
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.
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Priority Two BMIC Updated Guidance
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
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Miscellaneous Miscellaneous charges
Miscellaneous charges can apply to all four Service categories and are funded in the category of the service they are supporting. Training is eligible when included as part of the contract and performed coincidently with the installation of the new service/product or in a reasonable time there after. Training for end-users or professional development is not eligible
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Miscellaneous Miscellaneous charges
Taxes, surcharges and other similar reasonable charges are eligible for discount. This includes but is not limited to : Universal Service Fund Excise Tax 911 Local Number Portability Telephone relay service
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Miscellaneous Miscellaneous Charges
Other charges that are not eligible include but are not limited to: Universal Service Administration Fee Interest or finance charges Late payment Termination fees
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Dark Fiber Telecommunications Services vs Telecommunications
Telecommunication Services and Telecommunications are two separate categories on the Eligible Services List (ESL) Telecommunications Services can only be provided by an eligible telecommunications carrier Telecommunications can be provided by non-telecommunications carriers via fiber in whole or in part
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Dark Fiber Leased Dark Fiber as Priority One
Leased Dark Fiber added as Telecommunications in the FY2011 Eligible Services List Allows for the lease of dark fiber as a priority one service, from any entity On the FCC Form 470, file for both Telecom and Internet Access On the FCC Form 471, select the Telecom box if the dark fiber is provided by a telecom carrier In all other cases, select the Internet Access box
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Dark Fiber Leased Dark Fiber as Priority One
Dark fiber must be lit immediately Does NOT allow for unneeded capacity or warehouse dark fiber for future use Maintenance costs of dark fiber and installation costs to hook up the dark fiber are eligible This includes charges for installation within the property line Modulating electronics for leased dark fiber are not eligible
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Dark Fiber Leased Dark Fiber as Priority One Installation costs to hook up the dark fiber is eligible from the eligible entity to the property line
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Dark Fiber Dark Fiber as Priority One
Special Construction charges to build out connections from applicants’ facilities to an off-premise fiber network are NOT eligible
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Dark Fiber Dark Fiber as Priority Two Installation and Fiber costs between two eligible buildings, not crossing a public right of way are considered Internal Connections
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Equipment Transfers Equipment transfer rules
In general, equipment may not be transferred for money or any other thing of value A no-cost transfer may occur three years or more after the purchase of the equipment to other eligible entities No equipment transfer may occur prior to three years from the purchase, unless the eligible entity is permanently or temporarily closing
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Equipment Transfers Equipment transfers less than 3 years Notify USAC
Both the closing entity and the recipient must retain records of the transaction Include the reason for the transfer Records must be kept for five years after the date of the transfer Records for equipment >3 years follow the traditional document retention requirements
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Disposal of Equipment Disposal of Equipment Rules
As of January 3, 2011, applicants can dispose of obsolete equipment, but no sooner than five years after the date the equipment is installed Resale for payment or other consideration is allowable no sooner than five years after the equipment is installed Resale or disposal is prohibited before the five years have passed.
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Trade-ins and Exchanges
Trade-ins of equipment may be permitted if the E-Rate funded equipment to be traded in has been installed for five years This limitation does not apply for equipment not funded through E-Rate
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Questions?
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Support from eTech Ohio
eTech Ohio E-Rate Support and Information Lorrie Germann: Mike Edwards: To subscribe to the E-Rate list, send an with no message to
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