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Rex Miller E-Rate Update Fall/Winter 2013. Introduction E-Rate requires ongoing attention Todays session is focused on the E-Rate filing window and approval.

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Presentation on theme: "Rex Miller E-Rate Update Fall/Winter 2013. Introduction E-Rate requires ongoing attention Todays session is focused on the E-Rate filing window and approval."— Presentation transcript:

1 Rex Miller E-Rate Update Fall/Winter 2013

2 Introduction E-Rate requires ongoing attention Todays session is focused on the E-Rate filing window and approval process Seek out experienced assistance Some errors are still difficult to correct Contradiction leads to denial Get it right the first time Filing season is near – key items to note: Deadline – just set this week – March 26, 2014 Q & A At the end of the presentation ENA is available at your convenience

3 ENA Background Customer service and education focus K-12 customized service E-Rate expertise E-Rate Program Service Provider since Year 1 (1998) Experienced E-Rate team Rex Miller, April Scott, Kris Vivrette, Madeline Dusenberry, Ward Chaffin E-Rate Service Provider Leader A Top-10 E-Rate Service Provider Over $500M in E-Rate funded $130M+ in 2013 E-Rate filings

4 E-Rate in a Slide $2.3 Billion Technology Matching Program Run by FCC and its agent SLD Paid for by Universal Service Fees – not by Congress Administered differently than other education programs – more like IRS audit Eligible service to eligible sites for eligible users Priority 1 – Telephone and Internet Priority 2 – Internal Connections/Basic Maintenance Schools, Libraries and Admin Sites can be eligible Typically K-12 students, teachers and admin Annual application process Technology Plan may be required as starting point if P2 funds requested Open procurement run by state/local Annual funding form (471) listing amount, vendor and matching % Matching % based on Free/Reduced Lunch info Detailed forms and deadlines required every step of the wa y Funds Flow – reimbursement (BEAR) or vendor discount (SPI) Documentation – if not kept, funds can be denied or revoked/recovered

5 E-Rate Annual Timeline - Recurring Fall Update Technology Plan (if needed) Do procurements for new services if needed (form 470) FCC updates Eligible Services List FCC sets application deadline Winter Complete Funding Application (471) by deadline – March 2014 Begin responding to Application questions (PIA) Spring Get Tech Plan Approval Letter (if needed) Receive Funding Commitment (FCDL) File Service Start and CIPA Compliance Form (486) Required before vendor can bill SLD Summer Complete installation of new services Begin receiving bills for services – continuing Begin filing reimbursement forms (BEAR 472) if applicable

6 E-Rate News Window dates have been set Opening January 9, 2014 Closing March 26, 2014 Similar to last year Growth in Priority 1 funding requests Rising above funding cap Funding reforms/ConnectED/E-Rate 2.0/NPRM Lots of ideas – unlikely to impact 14-15 Still enough funds for P1 – but getting tight P2 funding unlikely to be available – or only 90% Eligible Services List issued for 14-15 Very little change from 13-14 Web hosting – eligibility of ancillary components Dark vs. lit fiber – construction charge eligibility

7 SLD Training Topics FCC Appeal Order related to RFPs: Relates to 470s that do not have an RFP (box not checked) If any additional information is made available only to entities that contact the applicant, the FCC may deem that to be an RFP If you have an RFP and do not check the RFP box on the 470, you will be denied funding This is a difficult area for many districts as RFP typically has a very specific meaning in local/state procurement law Best practice: consider the term RFP on the 470 to mean any written information describing services to be procured that is not included on the 470 If you are providing interested vendors with additional information – via your website or a written document – check the RFP box to protect yourself If you only have conversations with those that call or e-mail, you are likely OK Use of multiple providers – application of cost-effective rule Applicants cannot award an RFP to multiple providers for the same service at different costs SLD has indicated that using multiple providers for services such as web hosting or cell phone service might be considered inelig ible

8 E-Rate Tips and Notes E-Rate requires ongoing attention Consider the cost/benefit of how your district does E-Rate filings Do you have an internal expert on E-Rate? Is it the right person? E-Rate is only as good as the foundation Must follow rules for tech plan and 470/procurement to get funding If a procurement is canceled, cannot reuse original 470 Need a new one! Dont let your district be an island Seek out experienced assistance Some errors are still difficult to correct Contradiction leads to denial Get it right the first time

9 E-Rate Tips 2014 Open eligibility items Free devices with purchase of eligible service Cell phone is eligible if offered for free to public VoIP phone, laptop, handheld device, etc. – not currently eligible Separate NPRM issued – FCC intends to close this loophole beginning 14-15 Wireless access points On-premise managed wireless access points currently ineligible Under further FCC review Mentioned heavily in NPRM Use of different technologies for same purpose creating E-Rate inconsistency

10 E-Rate Tips 2014 Form 470 New FCC guidance – applicants will no longer be penalized for choosing the wrong Priority 1 category on their 470 470 Form is changing Still need to select the right category on the 471 – Telecom or Internet Access Flexibility is valuable – consider both P1 categories If you want a multi-year contract, consistency is key Make sure your 470, RFP or other bid documents and contract are consistent Cannot add renewal options after initial 470/contract process FCC Order – and equivalents Cannot list a brand name but can list brand name and equivalents PIA review Remember to answer their specific questions Providing extra information creates more work for all parties The SLD must review everything you send them Communicate in writing with PIA Phone calls have no record and can result in misunderstandings with SLD

11 E-Rate Rulebook Break

12 NPRM – Modernizing E-Rate FCC issued very extensive NPRM with hundreds of topics about modernizing the program Newly appointed FCC Chairman Wheeler is a new element to this process Topics included: Broadband goals and measurement How to lower cost of service – with a presumption perhaps that schools cant Potential reset of priority system Potential development of separate fund to promote fiber ownership Consideration of eliminating E-Rate for voice service or traditional voice service How to get more funding for internal connectivity to devices used at schools – wireless access points, switches, etc. Program funding levels Discount matrix Streamlining program administration And many more minute details

13 NPRM – Modernizing E-Rate FCC received over 1,000 different sets of comments and reply comments Many were one-pagers supporting increased funding or web hosting Differing opinions on many levels in the comments Some comments seemed to have universal support including: Delivery of BEAR payments direct to applicant Moving more E-Rate forms and information online Consideration of multi-year contract 471 Streamline E-Rate processes to issue funding decisions quicker Retain flexibility of the applicant to select their provider Given that the FCC has released the ESL for 14-15, we do not expect the NPRM to impact 14-15 Be alert for potentially dramatic changes for 15-16

14 New Forms – 470 & 471 Changes to 470 and 471 are pending review by OMB Form 470 – Combines Telecom and IA into one category Form 471 – Block 2 data moved to Block 5 and focuses on broadband Information consistent with Item 21 Attachment Work with your service provider as needed to fill that information out correctly Likely to be used like Item 21 Attachment in testing invoices Form 471 – formally establishing that Item 21 Attachment is due by filing deadline

15 FCC

16 Streamlining and Simplifying Technology Plans New requirements apply for FY 2011 and beyond No longer required for: –Priority 1 (Telecom and Internet Access) Still required for: –Priority 2 services (Internal Connections and Basic Maintenance of Internal Connections) ENA comment: make sure you keep your Tech Plan and Approval Letters from prior years in case you are audited

17 Tips to Eliminate E-Rate Surprises Make sure you have a solid E-Rate team – internal/external Staffing changes are key Make sure documentation is transferred Consider an E-Rate update report with deadlines and plans – perhaps quarterly E-Rate information requests – PIA, audits and other – develop consistent process to evaluate, understand and reply with the districts best answer Recognize that SLD role is to prevent ANY inappropriate release of E-Rate funding Their role is not to help you get or use the E-Rate funds – different than other programs Gift rules tracking and compliance Stay updated on approval status each year Dont get surprised by a funding denial after the start of the service year Procurement – make sure you are comfortable that the process is simple and compliant and be ready for an audit Documentation – make sure the files are complete and up to date E-Rate rule updates need to be tracked and implemented in a timely manner

18 471 Timing

19 E-Rate Timing Soapbox E-Rate continues the trend of the later closing of filing window in March Strongly encourage applicants who want to get approved before July 1 to file their 471s as soon as possible Target mid-February at the latest PIA will likely start for you before the 471 filing window is closed, so be ready Advantages Earlier approval No last-minute rush to file If you have an error, you can file another 471 before filing deadline and cancel initial incorrect filing – probably easier than using RAL process

20 Resources Contact ENA Rex Miller – April Scott – Kris Vivrette – Ward Chaffin – Madeline Dusenberry – SLD News Brief – make sure your are signed up for these e-mails Go to the SLD websites training section to sign up Key info provided during E-Rate window and throughout the year Websites SLD – main E-Rate rule site – training/WebEx 2013 fall training materials are available and valuable

21 Happy Holidays & Happy E-Rate Season!

22 @ENAconnects Contact ENA Today Rex Miller - 615.312.6000

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