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Arkansas State Library November 9-10, 2010
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Amber Gregory Coordinator of E-Rate Services 900 West Capitol Avenue, Suite 100 Little Rock, AR 72201 (501) 682-8576 amber@library.arkansas.gov www.library.arkansas.gov
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Arkansas State Library provides E-Rate support in the following ways. E-Rate Training and Support Amber Gregory, Coordinator of E-Rate Services Technology Plan Approval Sally Hawkes, Manager of Network Services Advice and Consultation on Technology Donovan Mays, Coordinator of Technology Support
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E-Rate is a program through the Federal Communications Commission (FCC) that allows for schools and libraries to receive discounts on technology. The discount level is determined by the urban/rural designation and the percentage of students who qualify for the National School Lunch Program (NSLP) in the school district in which the library is located. Discounts range from 20% to 90% of eligible services. E-Rate is the common name for the Schools and Libraries Division (SLD) of the Universal Service Fund.
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E-Rate began with the Telecommunications Act of 1996 FCC sets rules and policy E-Rate is funded by the FCC through the Federal Universal Service Fee
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Not-for-profit that administers the fund Four programs: ◦ Schools and Libraries Division (SLD) ◦ Rural Health Care Program ◦ High Cost Program ◦ Low Income Program ◦ http://www.usac.org/sl/ http://www.usac.org/sl/
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Each funding year the program is capped at $2.25 Billion. Starting with FY2010, the fund is adjusted for inflation, making the commitment $2.27 Billion. Each year a rollover amount is released by the FCC ◦ FY2009 $900 million
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USAC sends the applicant a letter each time a form is filed. ◦ FY 2008 Blue ◦ FY 2009 Canary ◦ FY 2010 Pink Retain all correspondence from USAC. Sample E-Rate binder labels and outline available from USAC: ◦ http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-E-Rate-table- contents.pdf http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-E-Rate-table- contents.pdf ◦ http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-E-Rate-binder- dividers.pdf http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-E-Rate-binder- dividers.pdf
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Keep all letters and E-Rate documents for 5 years after the last service is provided for any individual funding year.
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Libraries & Library Systems Schools & School Systems Consortia ◦ Libraries ◦ Schools ◦ Libraries & Schools
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Library * Eligible for assistance from a State library administrative agency under the LSTA act of 1996 Non-Profit Budget separate from a school system * Block 5 Certification on Form 470
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P1 (First Priority) ◦ Telecommunications Services ◦ Internet Access P2 (Second Priority) ◦ Internal Connections ◦ Basic Maintenance of Internal Connections Each year a new Eligible Services List (ESL) is approved by the FCC.
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Establishes authority to file an application on behalf of an applicant ◦ May be required by USAC if applicant is part of a consortia or uses the services of a consultant When would a Letter of Agency be required? Consultant ◦ Complete (sign & date) LOA before first action taken on your behalf by consultant Consortia ◦ Complete (sign & date) LOA before date of 471 certification
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470 – 4 Hours 471 – 4 Hours 486 – 1.5 Hours 472 – 1.5 Hours ◦ Based on Office of Management and Budget calculations
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USAC recommends filling out forms, filing and certifying online. 90% of applicants file online. Helps eliminate errors before the application is filed. Forms can be filled out using interview mode or manually. Forms can be saved online to complete at a later time.
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Develop a Technology Plan File Form 470 (RFP) Wait 28 days ◦ Negotiate and sign contract File Form 471 ◦ Application window stays open 75 days July 1 - begin receiving service File Form 486 ◦ 120 days after service begins or after receipt of FCDL, whichever is later. File Form 472 (BEAR)
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Four required elements ◦ Goals and Strategies for using technology to improve education or library services ◦ Needs assessment ◦ Staff training ◦ Evaluation plan Budget: no longer required in the technology plan
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Deadlines ◦ Must be approved by the time services begin or when the 486 is filed, whichever is earlier. ◦ Technology plan must be approved by Sally Hawkes, Arkansas’ USAC certified Technology Plan Approver (TPA). ◦ Current technology plans on file at the Arkansas State Library cover 2009-2012. ◦ Changes can be made to the current technology plans via addendum.
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Starting FY2011, the technology plan will only be required for P2 – Internal Connections. P1 services will no longer require a technology plan. USAC warns to be aware of services that appear to be P1 but are moved to P2 upon review of the application (bucket switch). ◦ Refer to “On-premise P1 equipment” in reference section of USAC SLD website. ◦ http://www.usac.org/sl/tools/reference-area.aspx#o http://www.usac.org/sl/tools/reference-area.aspx#o
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Form 470 opens the competitive bidding process. ◦ File yearly for terrified and/or month-to-month services ◦ File once for multi-year contract Describes the scope of the service & the categories and function of service. ◦ Must be sufficiently detailed Consistent with the technology plan. USAC sends Receipt Notification Letter (RNL) to applicant summarizing Form 470 after Form 470 is posted. The service provider cannot file Form 470 for library.
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Billed Entity Number (BEN) – Number assigned by USAC to each library. Personal Identification Number (PIN) – Number assigned by USAC to each person filing E-Rate forms. ◦ If more than one person is authorized to fill out forms, each person needs a PIN. Contact Client Services Bureau to get BEN or PIN: (888) 203-8100
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Request for Proposals (RFP) are documents that give details about the services desired, location and bid requirements to potential bidders. RFPs are not required by E-Rate. ◦ Check for local and state requirements on competitive bidding guidelines. Follow the stricter of the rules – state, local or E-Rate.
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Block 2 – Item 7 Select all that may apply: tariffed, month-to- month or contracted services in order to get the best bid response. Select multi-year contracts and voluntary extensions. If this option is not selected, you will not be able to enter into a multi-year contract or a voluntary extension without submitting a new 470 the following funding year.
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Block 2 – Items 8,9,10,11 Request service in any category in which you may file a Form 471 ◦ Example: telecommunications services & internet access If your Form 471 category of service does not match your Form 470, funding can be denied.
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If you are requesting telecommunications services, the service provider must be an eligible telecommunications service provider. ◦ Conduct a SPIN search on the USAC website. ◦ Print and file the page with E-Rate records.
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RFP Development and Contract Execution ◦ Consider requiring that vendor must have a SPIN as condition of bid award ◦ Consider requiring that vendor must have filed a Service Provider Annual Certification Form ◦ Consider requiring documentation as a condition of bid award that vendor is an eligible telecommunications service provider if you are requesting telecommunications services ◦ Consider requiring the method of payment in the contract (BEAR/SPI) *Tips from EdTech Strategies, LLC
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Receipt Notification Letter (RNL) confirms receipt of 470 Form 470 Application Number as assigned by SLD Provides date (29 th day) when you can sign contract Confirms receipt status of Block 5 certifications
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Make sure to wait at least 28 days after posting a Form 470 or an RFP before selecting a vendor, signing a contract or submitting a Form 471(when the application window is open). ◦ Consider how long it will take to: Conduct the competitive bidding process Evaluate bids Negotiate bids Receive administrative authorization Execute Contract Obtain signatures
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Bidding process must be fair and open. Responsibility for bidding process rests on the applicant. A service provider cannot run the competitive bidding process on behalf of the applicant.
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Price for eligible services must be the most heavily weighted factor. As long as price is the most important factor, the other factors can be up to the library. ◦ Examples include: ◦ Past positive experience with vendor ◦ Environmental Objectives ◦ Price for ineligible services ◦ Flexible invoicing (Bear or SPI)
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* Sample from USAC website
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FY 2011- Stricter rules for competitive bidding and gifts ◦ Rules apply not just during the application window, but at all times. ◦ Gift Rules – Nothing worth over $20 in value may be accepted at any one time from a service provider. Cannot accept more than $50 in gifts/meals per year from any one service provider. ◦ Be very careful when accepting gifts/meals. E-Rate funding could be at stake.
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Arkansas Vendor information on ASL website ◦ Public Library Services Vendors & Purchasing List is not an endorsement of the vendors, but a list of possible service providers We will continue to update the website with current vendor information
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Respond to 470/RFP Assist applicant with Item 21 attachment on Form 471 (after contract signed) Assist with technical questions from PIA Provide discounted bills or reimbursements Comply with certifications *Roles from EdTech Strategies, LLC
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Wait 28 days after posting 470/RFP Evaluate Bids Choose Service Provider Sign a Contract Submit Form 471 (after the window has opened)
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Form 471 provides more detail about: ◦ Entity requesting discount ◦ Service provider ◦ Eligible Services applied for ◦ Discount calculation information Certifies compliance with program rules
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The discount amount is based on two factors: ◦ Number of students in the school district in which the library is located who are eligible for National School Lunch Program (NSLP) Information available on Arkansas Department of Education website: http://arkansased.org/programs/tech_resources/erate.html http://arkansased.org/programs/tech_resources/erate.html Also available on Arkansas State Library website ◦ Rural or Urban designation Based on Metropolitan Statistical Area (MSA) data Designation can be found at USAC website http://www.usac.org/sl/applicants/step05/urban- rural/default.aspx http://www.usac.org/sl/applicants/step05/urban- rural/default.aspx
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Calculate the discount based on NSLP. Total number of students in the school district where library is located. Determine number of students eligible for NSLP. Divide the number of students eligible for NSLP by the total number of students to arrive at the percentage. Locate discount in discount matrix. Designation needed for application process.
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*Spreadsheet from Arkansas Department of Education website
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*Table from USAC website
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Usually opens in early November FY 2011 – Expect window to open early January (close mid-March) Open 75 days Application window applies only to Form 471. Form 470 can be posted before window opens.
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Funding Request Number (FRN) – Number assigned to Form 471 Block 5 funding request Service Provider Identification Number (SPIN) – Identification number given to a service provider by USAC ◦ SPIN contact search available on USAC website ◦ Service Providers may have more than one SPIN ◦ Contact Service Provider to clarify Item 21 Attachment – Details the services requested in funding application ◦ Service Provider can provide clarification and details for Item 21 Attachment.
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Receipt Acknowledgement Letter (RAL) – Sent to applicant and service provider by USAC summarizing form 471 ◦ Contains FRN, SPINs, Service Provider names, Category of Service, Pre-Discount amount requested, discount percentage ◦ Clerical corrections can be made to 471entries via RAL no later than 20 days after date of RAL Non-Instructional Facility (NIF) ◦ Eligible for P1 service ◦ Eligible for P2 service if necessary to provide transport to public areas of library
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Applicants are required to cost allocate out ineligible services from eligible services on the Form 471. If an ineligible service must be cost allocated out, the corresponding service and installation must be as well. Document and retain files associated with cost allocation process Cost allocation must be “based on tangible criteria that provide a realistic result”. - USAC ◦ USAC makes this determination
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Examples of Cost Allocation ◦ A bundled service with individualized prices for services ◦ Use the simple average of the eligible services performed by a component if it performs both eligible and ineligible functions. ◦ If a bundle of eligible & ineligible services/products receives a discount, the discount must be cost allocated across both eligible & ineligible services ◦ Other examples of cost allocation can be found at USAC website
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Reminders… File Priority 1 (P1) and Priority 2 (P2) services on separate 471 forms. Applicant must be able to pay for the non- discounted portion of the service. File Item 21 attachment when Form 471 is filed.
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2 in 5 Rule Library may not receive funding on P2 (internal connections) more than two out of every five years. This does not apply to basic maintenance of internal connections.
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Program Integrity Assurance (PIA) – begins reviewing applications when 471 and Item 21 attachment are submitted. ◦ Makes funding decisions Checks for program compliance ◦ Eligible Entity ◦ Eligible Purpose ◦ Eligible Services ◦ Eligible Sites/Locations
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USAC checks to make sure application properly completed ◦ Competitive Bidding Process ◦ Discount Calculation ◦ Contracts ◦ Sufficient Budget ◦ Certifications ◦ Form 470 ◦ Technology Plan ◦ Letters of Agency
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Applicant’s Role in PIA Review ◦ Have documents ready and organized ◦ Respond with required information within the specified time frame Review Selective Review Information Request (SRIR) found in SLD reference area ◦ Document the communication in writing ◦ Document the call and response ◦ If more time is needed, ask SLD Receive confirmation, Document that extra time is granted
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Informs applicant of status of funding requests ◦ Funded Completely In Part ◦ Not Funded ◦ As Yet Unfunded (Internal Connections) ◦ Canceled There may be multiple FCDLs for a Form 471 FCDL synopsis used to prepare Form 486
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Common Reasons for Funding Denials ◦ Ineligible entities ◦ Ineligible services or products ◦ Insufficient support resources ◦ Insufficient documentation ◦ Form 470 not certified ◦ Did not wait 28 days after 470 (RFP) posted
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Other Reasons a Funding Request may be denied ◦ Ineligible Telecommunications Provider ◦ Ineligible use ◦ Did not file Form 470 ◦ Services were not requested on Form 470 ◦ Competitive Bidding Violations ◦ No Letter of Agency ◦ Tech plan not prepared before Form 470 is posted (P2 services)
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Meet the certifications Work with the PIA inquiries Separate out services to avoid including eligible and ineligible services together File and Certify online ◦ Potential mistakes can be avoided ◦ Guarantees that the application is submitted in the application window Document, Document, Document! ◦ Retain all paperwork & correspondence with USAC
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File no later than 120 days after start of service or FCDL, whichever is later Purpose ◦ Let USAC know that eligible service has begun Invoices can be processed and paid ◦ Provide the name of the Technology Plan Approver who approved the technology plan ◦ Report CIPA status USAC will send a Form 486 Notification Letter to applicant and service provider after Form 486 has been processed.
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Both Applicant and Service Provider receive FCDL for services to be invoiced Applicant must file from 486 Applicant receives Form 486 Notification Letter from USAC Service Providers must file Form 473 ◦ Filed by Service Provider after USAC announces the opening of the application filing window ◦ Check with Service Provider about Form 473 filing
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BEAR vs. SPI – Applicants can choose between two ways to invoice USAC Billed Entity Applicant Reimbursement (BEAR) ◦ Applicant pays for services in full ◦ Applicant files Form 472 ◦ Service Provider approves Form 472 Service Provider Invoice (SPI) ◦ Applicant is billed for non-discount portion of eligible services. ◦ Service Provider files Form 474 for reimbursement on discounted portion of bill,
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If applicant prefers SPI ◦ list this preference in the RFP ◦ Add it as a qualification ranked in the bid evaluation matrix Applicant should double check invoice to ensure that they are receiving SPI discounts
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Applicants can appeal decisions made by USAC 1 st – Appeal to USAC 2 nd – Appeal to FCC Appeals should be postmarked no later than 60 days after the date of USAC’s decision letter
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Children’s Internet Protection Act (CIPA) ◦ Signed into law December 21, 2000 Library must be CIPA compliant or “undertaking actions” to become CIPA compliant in order to receive E-Rate discounts Exception: Telecommunication Services only
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Filtering is not required of public libraries according to Arkansas law ◦ Required for E-Rate CIPA Compliance ◦ Technology Protection Measure ◦ Internet Safety Policy ◦ Public Notice & Hearing
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Billed Entity will certify on Form 486 that the applicant is CIPA compliant If an Administrative Agency certifies that the Billed Entity is CIPA compliant.. ◦ Form 479 must be filled out by Administrative Agency ◦ Submit Form 479 to Billed Entity before Form 486 is filed
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USAC Client Service Bureau ◦ Phone: 888-203-8100 ◦ Fax: 888-873-4665 ◦ Website: http://www.usac.org/sl/http://www.usac.org/sl/ Use Submit a Question link to e-mail questions Amber Gregory, Coordinator of E-Rate Services ◦ Phone: 501-682-8576 ◦ Fax: 501-682-1693 ◦ e-mail: amber@library.arkansas.govamber@library.arkansas.gov ◦ Website: www.library.arkansas.govwww.library.arkansas.gov
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