e-rate: a review for 2010 e-rate: a review for 2010 - session starts at 3pm – (slides, nov. 10...
TRANSCRIPT
E-rate:E-rate: AA Review for 2010Review for 2010
- Session starts at 3pm –(slides, Nov. 10 version)
Steve Sanders [email protected]
Bob Bocher608-266-2127cell [email protected]
November 10 and 12, 2009November 10 and 12, 2009
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Agenda
1. Overview of the program
2. Eligibility and discounts
3. Technology plans
4. Application forms, follow-up processes
5. Common issues
6. TEACH and BCN update
Video and PowerPoint: http://dpi.wi.gov/pld/erate.html
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Overview Created by 1996 Telecom Act $2.25 billion annually from interstate phone revenue
Can use rollover funds WI averages $25 million annually
FCC has regulatory and legal oversight SLD does program administration
SLD division of USAC Eligible applicants
K-12 public and private schools, CESAs, Head Starts Public libraries, library systems
Program has many acronyms
The Telecom Act created a program to enable “access to advanced telecommunications and information services for K-12 schools and public libraries.”
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Check your application status at http://www.sl.universalservice.org/FY3_form471/471StatusCheck.asp
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What Are The Eligible Services?
Priority 1 Telecommunications services (telco’s only)
Local/long distance, wireline and wireless, voice, video, data FCC Nov 3 Public Notice emphasizes bandwidth
Internet access Basic access
Priority 2 Internal connections (2 in 5 year rule)
Basic maintenance of IC (each year)
Very few WI applicants get P2 Funding now at 85%, may drop to
mid-70s
Demand exceeds funds available.Priority 1: Funded first. Priority 2: Funded starting at highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.
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2010 Eligible Services List (ESL)
Official 2010 ESL not yet released by FCC ESL release opens 471 filing window
FCC issued draft ELS in June Clarifies that text messaging is eligible Email archiving is ineligible (archiving vs. storage issue) Interactive "white boards" are not eligible VoIP may be applied for as telecom or Internet access
FCC Nov. 3 Notice: Expand eligible services to PCs, staff CE?
Eligible Services
If it’s not in the ESL, assume it’s not eligible Must be used in an eligible location for eligible purposes See SLD site “Determine Eligible Services” Ineligible components/services must be removed
Full funding may be provided as Ancillary Use
Funding requests must be cost effective Update on TEACH and BCN
USAC will not approve funding requests that have unreasonable costs compared to the marketplace. -FCC’s 2003 Ysleta Order
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How Much Discount Can I Get?
Discounts range from 20% to 90% Based on free/reduced lunch eligible Enrollment and lunch data entered on ISES
Data now being reviewed, most districts doing revisions
DPI does not verify schools using their own data DPI posts Excel file mid-December
DPI sends file to SLD
If you use DPI data and are contacted by PIA, contact DPI
Actual Calculating Discount Methods done on Form 471
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Discount Matrix
Percent of Eligible Students
Urban Rural
Less than 1% 20% 25%1% - 19% 40% 50%20% - 34% 50% 60%35% - 49% 60% 70%50% -74% 80% 80%75% -100% 90% 90%
State average is 57%
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Technology Plans
Technology plans must be “developed” before the Form 470 is filed. (1st step in process)
Plans must support requested services on Form 470
Plans must be approved before service begins, usually July 1, 2010
Technology plans must cover the entire funding year for which a service is being sought. (Can’t expire before June 30, 2011)
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Technology Plans
Timelines for Information and Technology Plans
Plan ExpiresDeveloped prior to 470
Filing **
Plan to DPI by:
Plan Approved by:
June 30, 2010 Dec 2009 May 1, 2010 July 1, 2010
** E-Rate Note: A change in the E-Rate technology plan requirements occurred in August 2004. Technology plans must be “developed”, but not approved, before Form 470 is submitted.
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CIPA/NCIPA Compliance (Children's Internet Protection Act)
See DPI’s CIPA FAQ at: http://dpi.wi.gov/pld/cipafaq.html
Compliance with CIPA required for:o Internet access o Internal connectionso But not telecommunications
CIPA requires filtering and having an Internet Safety Plan New law will require Internet safety policy to include educating minors
about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response.
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Form 470 posted
Wait 28 Days
Pick vendor, sign contract
Submit 471
Tech Plan before 470
RNL
RAL
Select vendor, cost main factor. If no bids, applicant
selects provider.
E-Rate Flowchart* (Part 1)
* See also the SLD’s flowchart
Oct - Dec
Dec – Feb ?
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PIA Review
Form 486 – Service Start
FCDL - Decision
BEAR (472)
Discount on bills
Form 500 (optional)
SLD mails applicant and service provider a BEAR approval letter.
Applicant can appeal a denial of funding to the SLD within 60 days of date on FCDL.
SLD mails applicant and service provider a 486
approval letter.
E-Rate Flowchart (Part 2)
July – Oct
April - Aug
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Forms and Deadlines
Form or Event Deadline or Dates
Funding Year July 1 through the following June 30; Current year is 2009. Applying for 2010.
Form 470 Starts request for services. Must be posted at least 28 days before the filing Form 471. Note
(1) timeframe for all bids (2) Form 471 filing closing date. Will receive Receipt Acknowledgement Letter – RAL. 470 deadline will be late Dec. or Early Jan.
Form 471 Tells SLD what services you want, the provider, costs, schools getting services, discount %,
contract or MTM, etc. Will probably be due early February 2010. Will receive Receipt Notification Letter – RNL.
PIA review SLD’s Program Integrity Assurance (PIA) staff review all applications, which can take over 8
months. PIA will contact you with questions.
FCDL sent Starting late April, Funding Commitment Decision Letters sent to applicants. This continues
for months.
Form 486 Confirms start of service. Must be received/postmarked within 120 days after FCDL date or
120 days after the Service Start Date, whichever is later.
Form 472 / Form 474
Get discounts on bills (#474) or reimbursements (#472). Received or postmarked no later than 120 days after the date of the Form 486 Notification Letter or 120 days after the last date to receive service, whichever is later.
Appeals Must be received within 60 days of date on the FCDL. DPI can help with appeals.
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Form 470
470 begins bidding process, must be filed for 2010 If you have no contract for the requested services
Often tariffed or monthly telco or Internet service
If a contract expires on or before June 30, 2010 File 470 once for length of multi-year contracts or
contracts with voluntary extensions 470 and any RFP must indicate this
Check 7a and b and both options under b
In out years on the 471, site the original 470
Be sure to file for correct category of service
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Form 470
Can file the 470 now for 2010 services Be certain to have draft Tech Plan
File one 470 for all services, or file separate forms for each service
470 must be posted on SLD website for at least 28 days before you select a provider or sign a contract
See “Form 470” in News Briefs (10-30 Brief)
Form 470 drop dead filing date is 28 days before 471 deadline. But do not wait until then!
137 WI applicants have already filed 236 form 470s.
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Form 470 and Competitive Bidding
Must have a fair and open bidding process Bid document (RFP) optional, is a local decision All vendors are treated the same; have access to same information Vendors cannot be involved in your 470 Applicant’s consultant cannot be associated with vendor
Must choose most cost-effective bid Cost must be primary factor Non-eligible products/services not part of cost effectiveness Fully document your bid review process and any decision(s)
Record dates of any decisions, actions taken, etc.
Online Forms Training Site(http://sldtraining.usac.org)
470 options
See Oct 3, ‘08 News Brief for training site information.
NOTE: For “Quantity and/or Capacity” be certain to enter maximum
bandwidth needed. Example for schools on BCN:
“20Mbps to 100Mbps service for 3,000 teachers and students”
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Use Print Preview to check all data, then Submit and certify online or via paper
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E-rate Form 471
Provides specific information on services, service providers selected, and contracts and/or agreements, costs, etc.
Provides discount calculation information Must be filed each funding year
Applicant certifies compliance with all program rules
Must be postmarked or filed online by ???
Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window
2010 Form 471 drop dead date:
Likely Early-Mid Feb, 2010, 10:59PM CST
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Block 4:Calculate Discount.
Adding entities (schools)
NCES Codes: http://nces.ed.gov/ccd/schooLSearch
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Block 5:One for each funding request.
Adding entities (schools)
Spin search toolhttp://www.sl.universalservice.org/Forms/SPIN_Contact_Search.aspBut VERIFY with service provider!
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Block 5:Service start and end dates
OR
Contract award and expiration date
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http://www.sl.universalservice.org/reference/Form471item21Attachments.asp
”You MUST attach a description of the service, including a breakdown of components, costs, manufacturer name, make and model number….” Examples are provided in the document “Item 21 Attachments for Form 471”
Block 5 — Item 21 Attachment
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Tips on Filing Form 471
File separate Forms 471 for Priority 1 and Priority 2 services
Remove ineligible costs and document or estimate eligible costs carefully (30% Rule) – (Now Bishop Perry makes less important)
Filing online speeds processing and reduces errors
Examine, correct, and save Receipt Acknowledgement Letter (RAL)
Paper forms and instructions: http://usac.org/sl/tools/required-forms.aspx
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Receipt Acknowledgement Letter (RAL)
Form 471 Receipt Acknowledgment Letter (RAL) Cover page of important reminders Provides confirmation of certain information entered from Form
471 Data entry errors may be corrected within three weeks by
using the RAL (including Block 4 worksheets) Applicants can request funding reductions but not funding
increases
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Funding Commitment Decision Letter (FCDL)
FCDL reports status of individual funding requests:FundedNot fundedAs yet unfunded (internal connections)Canceled
May receive more than one FCDL Use info on FCDL to prepare Form 486
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E-rate Form 486
Notification that services have started and that SLD can pay invoices
Certifies that Tech Plan (if required) has been approved and covers the entire funding year.
Form 486 deadline is 120 days after service starts
–OR–
120 days after date of Funding Commitment Decision Letter date, whichever is later
October 29 deadline for FCDL before July 1
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E-rate Form 472/474 (Invoices)
Invoices — Form 472 or Form 474 BEAR (Billed Entity Applicant Reimbursement) Form 472 filed
by applicant and certified by service provider after receipt and payment for services
Form due October 28, 120 days after last service date, June 30 Or 120 days after date of Form 486 Notification Letter
-OR-
SPI (Service Provider Invoice) Form 474 filed by service provider after providing services and billing applicant for its non-discount share
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Issues of Waste, Fraud, Abuse
W/F/A still problem in program, mostly caused by 90% discount, P2, complex program rules Vendors have been debarred, people are in prison
W/F/A drives many FCC decisions More certifications More PIA requests for information More audits leading to more COMADs
FCC can recoup funds going back 5 years
See SLD Fall 2009 slides on audits
March 2009 - A former school administrator in Michigan was sentenced to four years in prison after pleading guilty to defrauding the federal E-rate program.
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Contract Issues
FCC/SLD E-rate contract rules trump local policies Telecom and Internet may/may not be contracted services As noted, on the 470, always check #7, options a and b Don’t sign contract before RFP due date or before 28 days But, you must sign/date contract before filing Form 471
Verbal agreements are not acceptable Quotes are not acceptable
Have contract timed to E-rate cycle
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State Master Contracts
DOA cell contract School files 471 for cell service using
your own or DOA 470 School must file 470 if using handheld device for Internet Contract expires 6-30-10, DOA will likely extend
DOA STS, Centrex, VoIP contract DOA did not file 470; you must file
both Form 470 and 471 471, #18, Contract Award Date (CAD) is date
you selected SMC as winning bid
Can use TEACH circuits for VoIPMark Rappe, DOA VoIP contract 608-264-9406; [email protected])
Gary McFall, DOA cell contract 608-266-1032 [email protected],)
Mike Kessenich, DOA STS, Centrex contract 608-264-9383; [email protected]
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Program Integrity Assurance (PIA) Application Review
PIA reviews all applications To ensure that funds are used for eligible services/products To ensure that funds are for eligible purposes To ensure that funds are for eligible entities To annoy you by asking for same documents multiple times
Common PIA requests to applicants Need more information on requested services Competitive bidding process and contracts Establishing Form 470
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“Please provide the Form 470 that established the bidding for the contract extension.”
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Program Integrity Assurance (PIA) Application Review
Respond within 15 days to PIA requests Work with service provider if needed Respond completely to PIA questions, but no more
If needed, ask for more time or for clarification; contact DPI
17% of all WI denials: No response or insufficient info
10% of FRNs move to “Selective Review” Check 471 status at 471 Application Status Tool
• Applicant has not provided sufficient documentation to determine the eligibility of this item• No documentation was provided for item(s): item 21 attachment.
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Appeals
Funding denials can be appealed Generally, appeal first to the SLD Then appeal to FCC if SLD denies appeal
Must be postmarked within 60 days of denial on FCDL FCC has been granting many appeals
But can be a year or more
Contact DPI for appeal advice and template No appeal form
See Appeals Procedure on SLD Website
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When You Need Help
SLD website: www.usac.org/sl/ Fall 2009 SLD training slides Reference area News Briefs
E-rate Central, WI site Enter your BEN and get info on your application
SLD Client Service Bureau: 888-203-8100 Email: [email protected] Fax: 888-276-8736
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DPI Help
DPI’s E-rate website: dpi.wi.gov/pld/erate.html
DPI’s WIERATE email list: dpi.wi.gov/pld/wieratelist.html
DPI Staff:
Bob Bocher608-266-2127; fax [email protected]
Steve Sanders 608-266-3856; fax 608-266-2529 [email protected]
E-rate for 2010E-rate for 2010 ? Questions ?? Questions ?
Steve Sanders [email protected]
November 2009