Brett HintonAZ Dept. of Education

Mala MuralidharanAZ State Library Archives and Public Records

Modified from Train-the-Trainer Workshops

E-rate - Get those dollars back to Arizona!

Process overview

Video Tutorials at http://usac.blip.tv/

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Overview

General information about E-rate

1.Technology planning

2.Request services (Form 470)

3.Competitive bidding

4.Choose/contract for services (Form 471)

5.Application review & funding commitments

6.Start services (Form 486)

7.Invoice USAC (Form 472 or Form 474)

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General information

Federal Communications Commission (FCC), an independent U.S. government agency, oversees the E-rate program

Universal Service Administrative Company (USAC), a not-for-profit, administers E-rate 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 information

FCC sets rules and policies through orders– Rules are compiled in the Code of Federal

Regulations (CFR)– Policies are defined in the text of orders

USAC/SLD sets procedures for specific actions, such as how to process applications– USAC sends its procedures to the FCC for

approval each year

E-rate? What is it? E-rate Program provides reimbursements to

eligible schools and libraries for

1. Telecommunications Services 2. Internet Access, 3. Internal Connections 4. Basic Maintenance

Applicants must apply each year Reimbursements are based on the poverty

level and the maximum one can get back is 90% of your billed amount

Funding cap each year is $2.25 billion5

FCC

Vendors

USAC

Schools

$2.25 Billion

Funding Waves

Telecomm

Internet

Internal connections

IC Maintenance

Submitted each Quarter

Library

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Timetable

Form 470: File from April before the Window to 28 days before the Window closes

Form 471: Must be filed during the Window, generally mid-November to early February before the start of the funding year

Funding waves: Groups of funding decisions issued after USAC review – waves generally start in April before the start of the funding year

Invoices: Can file after services are received for the funding year.

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General information

Who can apply?

– Schools and school districts

– Libraries and library systems

– Consortia – groups of eligible entities that band together to aggregate demand and negotiate lower prices

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General information

How large are the discounts on eligible products and services?– Discounts: 20% to 90% of eligible costs

– Discount for a school or library depends on:

• Percentage of eligibility of students for National School Lunch Program (NSLP) in:

– (for a school) the school– (for a library) the school district in which the

library is located

• Urban or rural location of the school or library

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General information

What services are eligible? Priority 1 (funded first)

– Telecommunications Services – Internet Access

Priority 2 (funded beginning with neediest applicants first)– Internal Connections – Basic Maintenance of Internal Connections

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General information

How do I file a program form?– In general, you have three options:

• File online, certify online• File online, certify on paper• File and certify on paper

– USAC encourages you to file online• Online filing speeds processing and

reduces errors

What is sent ……and received

Receipt Notification Letter (RNL)

Receipt Acknowledgment Letter (RAL)

Funding Commitment Decision Letter (FCDL)

Form 486 Notification Letter (486NL)

BEAR Notification Letter — Form 472 only

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Applicant to USAC -> Letters received from USAC

Technology plan created but not sent

Form 470

Form 471

Form 486

Form 472

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1. Technology planning

You must write a technology plan that contains the following elements:1. Goals and strategies for using technology to improve

education or library services

2. Staff training/ Professional Development

3. Needs assessment

4. Budget

5. Evaluation plan

Note: if you are only requesting basic telephone service, a technology plan is not required

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Necessary Resources

Does the applicant have the resources needed to provide the service– Are there end user computers?

• Must have reasonable plans to fully utilize all internal connections for which you are requesting discounts

– Do you have software to run on the computers?– Staff trained on how to use the technology?– Electrical capacity?– Can you maintain the eligible and ineligible

equipment?

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Budget This is an important part of the Tech plan

and the purpose is to show USAC that the applicant can fund their share

Operating budget (or draft) has dates that cover the funding year (July – June)

Budget documentation should have clear expense line items not all bundled together

If budgets are not passed at that time, can provide letter for reasonable expectation that funds will be secured by 7/1

Non-Discounted portion

Obligation to Pay Non-discount Share• Applicants are required to pay their share of the cost

(the “non-discount” portion or share) — this share cannot be donated, forgiven or ignored.

• Service providers cannot waive or credit the applicant’s share.

• Service provider must bill the applicant for non-discount share of services. If applicant can’t show proof of payment during invoice review; invoice may be denied.

• Deferred payment plans that allow the applicant to pay after USAC has paid will jeopardize a funding request. 16

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Free Goods and Services

• Applicants and service providers are prohibited from using E-rate to subsidize the procurement of ineligible or unrequested products and services

• E-rate cannot be used to get free stuff or kick-backs. The value of ineligible products that are needed to run the service have to be backed out in your vendor selection process.

• Cost of eligible goods and services cannot be inflated to cover the“free” ineligible stuff

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Technology plan approval

– Technology Plan Approver (TPA) – the agency certified by USAC that approves your technology plan

– It has to be written (drafted) before the filing of the Form 470, finalized and approved before the start of services.

– Can be multi-year but major changes have to be re-approved

Tech Plan Validity

Year 1 Year 2 Year 3

Tech plan submitted

for approval

Approved

Must submit another plan

No longer valid for E-Rate

Approved Year 1 Year 2

Major change occurs between approved years 1 & 2

Tech plan drafted

Technology Planning: Do’s and Don’ts

DO draft your technology plan before Form 470. verify that it contains all five required elements. make sure your technology plan covers at least 12

months make sure that your technology plan approver is

certified by USAC. verify that plan is approved before services begin

and before your Form 486 is filed. PRINT A COPY of your Tech Plan for your

records. PRINT A COPY of your approval for your records.

DO NOT ask the service provider direct advice on technology planning.

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Questions?

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2. Request services (470)

You post a Form 470 to:– Open a competitive bidding process

– Notify potential bidders (service providers) of the types and quantities of services that you need

– Define the scope of your needs (e.g., a school building, a library system, a state network)

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2. Request services (470)

Acronyms and terms– Billed Entity Number (BEN) – an identification number

assigned by USAC to each school or library 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 Form 470, 471, or 486– Request for Proposals (RFP) – a bidding document (not

required by E-rate) that provides detailed information about your services, locations, bid submission requirements, etc.

– Allowable vendor selection/contract date (ACD) – the date 28 days after the Form 470 is posted to the USAC website

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3. Competitive bidding

When you open a competitive bidding process for your services:– Potential bidders have the information

from your Form 470 and RFP and can respond to your requests

– You must ensure that the competitive bidding process is open and fair

– You must be prepared to evaluate bids

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3. Competitive bidding

After you close the competitive bidding process for your services (on or after the ACD):– You can evaluate the bids received– You can choose your service provider(s)– You can sign a contract– You can post a Form 471

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

Calculate the discounts

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Reimbursements are based on Discounts calculated using•Percentage of students eligible for National School Lunch Program (NSLP) •Urban or rural status of county in which school or library is located (see USAC web site)•http://www.usac.org/sl/applicants/step05/urban-rural/default.aspx

These two pieces of information are carried into the Discount Matrix

% 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%

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4. Choose services (471)

You post a Form 471 to:– Report information on the service providers and

services you have chosen– Provide a list of the schools and libraries that will

receive services– Include discount calculation information including

student NSLP counts– Certify your compliance with program rules

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4. Choose services (471)

Acronyms and terms– Funding Request Number (FRN) – the identification number

assigned to a Form 471 Block 5 funding request– Service Provider Identification Number (SPIN) – the

identification number assigned by USAC to a service provider• Service providers may have more than one SPIN in order

to identify separate business units, different states in which they operate, etc.

– 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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4. Choose services (471)– Item 21 Attachment (Item 21) – the description of

services associated with a funding request (Item 21 on Form 471)

• Item 21 attachments can be submitted online or on paper

• USAC encourages online filing, especially for simpler applications

– Form 471 Receipt Acknowledgment Letter (RAL) – a letter issued by USAC to the applicant and the service provider that summarizes the information provided in the Form 471

• Many of the entries on the form can be corrected after submission by using the RAL

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5. Application review USAC reviews your 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– Program Integrity Assurance (PIA) – the USAC group that

reviews and makes funding decisions on program applications– Funding Commitment Decision Letter (FCDL) – a letter issued

by USAC to the applicant and the service provider that contains commitment decisions on funding requests

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6. Start services (486)

You post a Form 486 to:– Notify USAC that services have started 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 CIPA

Acronyms and terms– Form 486 Notification Letter – a letter issued by USAC to the

applicant and service provider after a Form 486 has been processed

– Children’s Internet Protection Act (CIPA) – a law with specific requirements on Internet safety policies and filtering

– TPA Tech plan approver

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7. Invoicing USAC (472/474)

Applicants have a choice of two invoicing methods to receive discounts on eligible services:– Billed Entity Applicant Reimbursement (BEAR) Form 472– Service Provider Invoice (SPI) Form 474

BEAR Form is filed by the applicant and approved by the service provider after the applicant has paid for the services in full

SPI Form is filed by the service provider after the applicant has been billed for the non-discount portion of the cost of eligible services

Acronyms and terms– BEAR Notification Letter – a letter issued by USAC to the

applicant and service provider after a BEAR has been processed– Quarterly Disbursement Report – a report issued to the applicant

detailing all invoicing activity (BEARs and SPIs) during the previous quarter

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Questions?

Break- Time!

Eligibility and

Eligible Services List

Eligibility - Schools

• Must meet the statutory definition of elementary or secondary school found in the No Child Left Behind Act of 2001.

• Must be a non-profit institutional day or residential school, including a public charter school, that provides elementary or secondary education, as determined under state law eg Pre-kindergarten( Sp Ed. Only), Adult Education, Juvenile Justice students facilities may be eligible.

• Must not have an endowment exceeding $50 million.• USAC requests updated eligibility information from

state departments of education every two years.

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Eligibility - Libraries

• Must meet the statutory definition of library or library consortium in the Library Services and Technology Act (LSTA) of 1996.

• Must be eligible for assistance from a state library administrative agency under LSTA.

• If they are a joint use facility (school + public library) each can apply separately for their portions provided budgets are completely separate.

• Must not operate as for-profit business.

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Eligibility - Consortia

Eligible schools and/or libraries may form consortia with• Other eligible schools and/or libraries• Certain health care providers• Public sector (governmental) entities

Helps bring the prices down May even help bring higher band-width or better service May bring more competition to your areaBUT – Only eligible entities can receive discounts Be careful about consortial applications –

– not easy to administer– there are consequences and responsibilities.

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Eligible Services - Priority 1

Priority 1 – funded first

• Telecommunications Services– Basic telephone service — wireline or wireless phone

service (local, cellular/PCS, and/or long distance); Voice over IP- PBX and Centrex; Radio loop

Internet Access– Basic conduit access to the Internet including but not

limited to: Broadband over Power Lines (BPL), Cable Modem, Digital Subscriber Line (DSL), Satellite

– T-x, DS-x, OC-x . E-mail service, and web hosting

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Eligible Services – Priority 2

• Priority 2– Internal Connections (switches, hubs, routers, wiring,

cabling)– Basic Maintenance on Internal ConnectionsNOTE: End user equipment - such as computers, monitors, or phone sets - is NOT eligible

• Priority 1 funded first, then Priority 2 begins with neediest applicants (90% first, then 89%, 88%, etc.).

• Internal Connections funded in only two out of five funding years.

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Special Eligibility Conditions

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Internal Connections Example 1

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Internal Connections Example 2

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Classroom Internal Connections

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Classroom Internal Connections Ex. 2

This leased router may be eligible for P1 funding if all conditions are met.

Single demarcation – If the router is removed, the LAN would continue to function.

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On-Premise Equipment 1

This leased router is NOT eligible for P1 funding. Multiple demarcations – If the router is removed, the LAN

would cease to function which violates program rules for Priority One eligibility. Router may be eligible in IC.

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On-Premise Equipment 2

Internal Connections Maintenance

Ensures the necessary and continued operation of eligible internal connection components at eligible locations.

Ex: Repair and upkeep of eligible hardware, wire and cable maintenance, and configuration changes.

Basic technical support of eligible hardware is Eligible but end-user support such as a student calling a help desk for technical assistance is NOT Eligible.

BMIC is a Recurring service - Delivery must be within July 1st – June 30th

BMIC is exempt from the Two-in-Five rule

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Purpose

Must be for Educational Purpose only– Activities that occur on library or school property are

presumed to be integral, immediate, and proximate to the education of students or the provision of library services to library patrons and therefore qualify as educational purposes.

– Customary work activities of employees of a school or library are presumed to fall under the definition of education purposes.

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Non-instructional Facilities Non-instructional facilities are school buildings with (few

or) no classrooms or library buildings with no public areasNon-instructional Facilities Eligible for Priority 1 services

– Telecommunications– Internet Access

Eligible for Priority 2 services only if the services are essential for the effective transport of data to classrooms or public areas of a library

School examples:– Administration buildings– Bus barns– Athletic stadiums

Library examples:– Administration buildings– Bookmobile garages– Technology centers

Non-instructional Facilities (NIFs)

SCHOOLS: Administrative buildings School bus barns and

garages Cafeteria offices Facilities associated with

athletic activities Teachers accompanying

students on a field trip

LIBRARIES: Administrative buildings Bookmobile garages Interlibrary loan facilities Library technology centers

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NIFs can receive Priority 1 services. Examples are

NIFs – Priority 2NOT eligible unless it is essential for the effective transport of information to an instructional building of a school or to the patrons of a library.

Eligibility- Service Provider

What should you know about your Service Providers Must be an authorized Telecom Carrier and

supply on a common carriage basis. Must file form 498 (Service Provider Information

Form) Must have a Service Provider Identification

Number (SPIN) Must file Form 473, Service Provider Annual

Certification (SPAC) Form Must contribute to the Universal Service Fund.

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Questions?

Website and Links

Eligible Services List http://www.usac.org/_res/documents/sl/pdf/ESL_archive/EligibleServicesList_112108.pdf

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What are we?

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What are the following services? P1, P2, or Not Eligible

Telephone Handsets

Switch

Internet Access

Router

Cabling

VOIP

Not Eligible

P2

P1

P1 / P2

P2

P1 / P2

Calculating Discounts

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Overview

Basic discount calculations Alternative discount mechanisms Non-instructional facilities Snapshots New construction

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Basic Calculations

E-rate discounts depend on:– The percentage of students eligible for the

National School Lunch Program (NSLP) or an equivalent measure of poverty

– The urban or rural status of the county or census tract in which the school or library building is located

USAC may request third-party verification of student counts submitted by applicants

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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%

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Basic Calculations Individual school calculation:

– Calculate the percentage of students eligible for NSLP in that school

– Use the urban or rural status of the county or census tract in which the school is located

School district calculation:– Calculate the E-rate discount for each individual school in the

school district– Calculate the weighted average discount

• For each school, multiply the E-rate discount by the total student population of the school (the weighted product)

• Add all weighted products and divide by the total number of students in the school district

School E-Rate Discount# of Students Weighted Discount (B x C)A 70% 2000 1400B 50% 700 350C 25% 1500 375

4200 212551%

TotalsDistrict Average (D/C)

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Basic Calculations Library outlet/branch calculation:

– Calculate the total percentage of students eligible for NSLP in the school district in which the library building is located

– Use the urban or rural status of the county or census tract in which the library outlet/branch is located

Library system calculation:– Calculate the E-rate discount for each library outlet/branch in the

library system– Calculate the simple average discount

• Add together the discounts for the outlet/branches and divide by the total number of outlets/branches

Consortium calculation:– Calculate the E-rate discount for each individual member of the

consortium– Calculate the simple average of all the member discounts

Library E-Rate DiscountA 70%B 50%C 25%

48%Totals

Library District or Consortium Average (B/3)

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Alternative Mechanisms Head Start (NSLP)

– Head Start is a federal program that provides comprehensive developmental services for low-income children ages three to five

• Head Start students meet free lunch guidelines under NSLP, so Head Start entities automatically qualify for 90% discount

• Children under age three are never considered eligible and must be cost-allocated out

• Home based Head Start is not eligible Direct certification (NSLP)

– State social services agency works with local educational authority to directly certify students for NSLP based on household participation in other poverty-based programs

• USAC will accept the student counts determined using this method if the school can demonstrate participation in direct certification

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Alternative Mechanisms Other alternative discount mechanisms measure a level of poverty in

a household equivalent to that required by NSLP– Income Eligibility Guidelines (IEGs) are published each year by

the U.S. Department of Agriculture (USDA)– Students from households whose income is at or below 185% of

the federal poverty guideline are eligible for the NSLP Examples

– Medicaid, Food stamps– Supplementary Security Income (SSI)– Section 8 (federal public housing assistance)– Low Income Home Energy Assistance Program (LIHEAP)

Other programs can be used as mechanisms ONLY IF their requirements are at least as stringent as IEGs– Examples of programs that do not automatically qualify

• Temporary Aid to Needy Families (TANF)• Title 1 eligibility, Scholarship programs

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Alternative Mechanisms- Survey Applicants can conduct surveys to establish eligibility (see

sample survey on USAC website)– Survey requirements:

• Must be sent to all families whose children attend the school• Must contain names of family and students• Must contain size of family• Must contain income level of family• Data must not be more than two years old

Surveys can request information on household income level or participation in eligible alternative mechanisms or both

With one exception, applicants must be able to provide data on an individual student basis– Exception: if a school sends a survey to the households of all of its

students and at least 50% of the surveys are returned, the school may project a percentage of eligibility based on the percentage of eligibility in the returned surveys

Retain copies of all surveys for your records

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Other Sources Applicants can match siblings or collect data from other

existing sources– Example: if a elementary school student from a

household participates in NSLP, an older sibling in that household can be counted as eligible

Multiple entities

Discount is based on the total enrollment for the entity and NSLP data and each location receives the same discount

Obtain an entity number for each facility if the facility has a different address or a public right-of-way crosses the campus

Maintain adequate documentation

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Non-instructional Facilities

Discounts for NIFs without classrooms In general, the discount for a NIF on the same

campus as a school or library is the same as the discount of the school or library

A NIF shared by more than one school in a school district or library in a library system is eligible for the shared discount for that school district or library system

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Non-instructional Facilities- snapshot

Separate NIFs (not a part of the campus) that are used by a class should use the snapshot method– Choose a specific day– Determine the percentage of students eligible

for NSLP for the student population that attends class on that day

– Use that percentage and the urban/rural status to find the discount in the Discount Matrix

Save your documentation

New Schools and Libraries

Is it really a new school or library?– Does the State consider this a replacement

facility for the same school or library? • If yes, use current discount information

– Does the State consider this a new school or library?

• If yes, the may use New School Construction guidance

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New Constructions

If a school is under construction –– If the student population is known, use the percentage of NSLP

eligibility of those students to calculate the discount– If not, do a pre-enrolment survey

If a library is under construction –– Use the discount for the school district in which the library

building is going to be located Charter and Private Schools

If population is unknown use 20% discount . You cannot use school district average

If population is known - Must be able to provide supporting documentation. Use that data to calculate discount rate

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Questions?

Form 470 & Competitive Bidding

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Competitive Bidding / 470

• Filing Form 470 opens a competitive bidding process, which is fair and open.

• The Goal is – to have a healthy competition– to promote better service and lower prices

• Avoid conflicts of interest – Independent consultant Service

Provider– Applicant Service Provider

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Competitive Bidding / 470

• Fair and open process– All bidders treated the same– No advance knowledge of RFP

information– No secrets in the process– All bidders know what is required of them

including the selection criteria.• Follow all rules – FCC and state/local

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Pre-bidding Discussions

Applicants may:– Discuss their product offering with SPs– Learn about new technologies from SPs

Applicants may NOT accept/use the following from service providers:– Vendor-specific language for RFP or the 470– Template RFPs or Forms 470– Assistance with tech plan – Assistance with RFP

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Vendor Involvement Service providers cannot:

– Determine the types of service the applicant will seek on a Form 470

– Assist applicants with the filling out of the FCC Form 470 which requires an applicant’s certification

– Influence or run the competitive bidding process for the applicant

– Be privy to information about the bid not shared with other potential bidders

Competitive Bidding / 470

Request for Proposal (RFP)– Not required under FCC rules, but a good practice – Must comply with local and state procurement

laws (check for limits on sealed bid requirements etc.)

– Describes your project scope, location, other requirements in detail

– Even if you have an RFP, you must describe the services you desire on your Form 470.

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Competitive Bidding / 470

Form 470Must indicate a multi-year contract or contract with extensions if appropriate.

Must list services sought in the correct category of service. If you are not sure put it in both categories (Telecom and Internet). You can decide when doing Form 471

Must indicate if it is for a single entity or multiple entities and if there are likely to be changes in the middle of the contract period

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The 28 day rule• WAIT 28 DAYS after your Form 470 is posted and

your RFP is issued before you evaluate the bids• No hard deadline for filing Form 470 but is based

on Form 471 window closing

• RFP handed out at walk through-28 day clock starts after last of the RFP issued

• Clock for 28 days restarts when• If you issue a new RFP, then your 28 days starts again (do not have to post a new 470)• Changed services sought• Make other cardinal changes to RFP• Post new Form 470 76

Qualifying factors

• Qualification Factors– Can require that potential bidders meet minimum

number of qualification factors

• Disqualification Factors– Can require that potential bidders that meet any

disqualification factors are not considered• Ensure that all potential bidders have adequate

notice of these items• If no bids received after 28 days, you may

contact vendors to seek bids

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Sham bid process

“I want to stay with my incumbent” Avoid appearances of a “done deal” Must respond to all legitimate inquiries.

Need not respond to spams Cost to transfer to another provider alone

is not by itself a good enough reason to stay with incumbent, but can be one of the bid evaluation criteria

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Competitive BiddingIf you wait until the last date to file a Form 470, the following must all occur on the last day of the window for Form 471:Bid Evaluation

Selecting a service provider

Signing and dating a contract

Submitting Form 471 online or mailing the manual paper copy

Certifying, signing and dating

Retain your documentation Retain, retain, lessen your pain

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Competitive Bidding / 470 – Tips

• Retain worksheets, bid evaluation criteria, winning AND LOSING bids

• Prepare a memo to file if you received only one bid or no bids

• File online to reduces errors and speed processing

• Read the contract’s fine print

Personal Identification Numbers (PINs)• Will be automatically issued to any new authorized persons

filing Forms 470, 471 and 486 after at least one wet signature.

• Do not use the pin that was issued to a former staff (Pins are electronic signature of the individual)

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Competitive Bidding / 470

Form 470 Receipt Notification Letter (RNL)– Cover page of important reminders– Notifies applicant that Form 470 has been posted to

the USAC web site– Contains Allowable Vendor Selection / Contract Date

(ACD)– Use the calendar tool on the website rather than

calculating it yourself.– Remember if you posted your RFP after posting

form 470 – you will have to wait 28 after posting the RFP even if you have a ACD on your RLN.

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Questions?

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Video Tutorials at http://usac.blip.tv/

Vendor Selection, Contracts, & Form 471

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Selecting a vendor

• Applicants must choose the most cost-effective solution to their Form 470 or RFP.

• Price has to be the primary factor – the one with the most weightage (next slide)

• See Rubric on how to do the bid evaluation(Handout)

• Bid evaluation process should be carefully documented and filed - winning and losing bids

• If only one bid or no bids are received – make a memo for your files

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Vendor Selection

Applicants must retain all vendor selection documentation– This includes winning and losing bids

Price of the eligible goods and services must be the primary factor in all rounds

Applicants determine remaining vendor selection criteria and relative weighting

USAC sample evaluation matrix available

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Cost-Effectiveness• Solution must be cost-effective

• Routers priced at two or three times greater than the prices available from commercial vendors would not be cost-effective, in the absence of an explanation of extenuating circumstances.

• Receiving only one bid does not automatically make it cost-effective

• Service Providers may work with the applicant to help them understand the technical needs for this expensive solution.

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Selecting Factors Selecting the winning bidder

– Price of the ELIGIBLE goods and services must be the primary factor.

– Other factors, including other price factors, can be considered as well but they cannot be weighted equally or higher than cost of the eligible goods and services

– See Step 4: Construct An Evaluation for weighting samples

USAC bid evaluation template

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Contracts Once you have selected your vendor applicants and

service providers must sign contracts for services that are not provided under tariff or month-to-month arrangements

Contracts have to be signed by the applicant before filing form 471

It is a good practice for the applicants to get the vendors to sign the contracts too, to make it legally binding.

Contracts can cover more than one year or contain extensions, but applicant must indicate these options in the Form 470.

TIP: You may want to add some contract language that allows the contract to be extended into another program year in the event you are awarded late in the funding cycle and an opt out clause in case of funding denial 89

Funding Requests / 471

Form 471• Provides specific information on services, service

providers selected, and contracts• Provides discount calculation information• Details itemized services – item 21 attachments• Must be filed for each funding year even if you do not do

a Form 470• Contains certifications of compliance• Has a hard deadline date.• You can do multiple form 471s (Block 5s ) by breaking it

out. • File Priority 1 and Priority 2 requests separately. Review

of Priority 2 requests may hold up Priority 1 commitments

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Funding Requests / 471

Form 471 Deadline

• Must be filed online or postmarked on or before the close of the Form 471 application filing window. (midnight Eastern on the date of the deadline).

• Be prepared for a logjam and software timeouts closer to deadline.

• Good practice to file Certifications for associated Forms online or postmarked by deadline.

• Certifications and Item 21 attachments are accepted even after the close of the window.

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Funding Requests / 471

• Remove ineligible costs from funding requests• Document ineligible costs carefully and cost

allocate it out• 30% rule – if 30% or more of the dollar value of the

request is for ineligible products, services, or entities you will get called during PIA review and asked to remove it.

• Work with your service provider • to help you unbundle the services and products• to break out eligible and ineligible costs• to create your Item 21 attachment(s)

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Funding Requests / 471

Enter recurring and non-recurring costs carefully in the cost summary of each Funding Request

• Recurring costs ALWAYS must be received by June 30 of the Funding Year.

• Non-recurring costs must be received by September 30 following the Funding Year, and this deadline can be extended under certain circumstances

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Funding Requests / 471

• 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 changes

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Questions?

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Video Tutorials at http://usac.blip.tv/

PIA Review

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Application Review - PIA

All Forms 471 are reviewed by Program Integrity Assurance for compliance with program rules concerning areas such as:•Competitive bidding process, contracts, discount calculation, sufficient budget, establishing form 470, Technology plan, CIPA•Some errors can be corrected during PIA review but not all. •All certifications and attachments (esp item 21) will be scrutinized.

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PIA Reviews• Initial & Final Review

• Applications always start in Initial Review. Reviewer contacts the applicant with questions, gives them 15 days to answer. • Final Reviewer reviews the Initial Reviewer’s comments.

• Quality Assurance (QA) Review• Some Form 471 applications are selected for QA review• QA has Initial and Final review levels as well

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Clerical Corrections Bishop Perry Order allows applicants to make

corrections to Forms 470 & 471 - known as ministerial & clerical corrections.

Applicants have additional time to certify Forms 470 & 471, make corrections that do not require the Form 470 to be reposted or the Form 471 to be re-filed, and do not violate FCC regulations and/or program rules.

USAC, with FCC guidance, developed a list of correctable items. List of Correctable M & C Errors

Subsequent FCC Orders issued identified more corrections allowable during PIA review.

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Clerical CorrectionsExamples: Entered the incorrect amount (i.e., data entered

$100 instead of $1,000) Omitted an entity from the Block 4 Provided the incorrect Form 470 number on the

Form 471 Selected the wrong category of service Submitted an unsigned contract to PIA Omitted an FRN Did not include all of the required elements in the

written tech plan

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PIA Review : Tips

Provide information to PIA promptly• Work with your service provider to comply with

information requests.• Make sure your answers respond completely to the

questions asked.• Ask for more time to respond if you need it.

• However, if you ask for more time, your PIA representative will work on other applications and you may wait longer for a decision.

Ask for everything in writing, respond in writing Check the 471 Application Status Tool on the web.

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Deadlines, Deadlines15 Day Rule

– PIA corrections MUST be submitted 20 calendar days (5 days for mail receipt + 15 days) from the date of USAC’s letter

• Receipt Notification Letter (RNL) – 470• Receipt Acknowledgment Letter (RAL) – 471

– Mail, email or fax corrections to USAC– RAL doesn’t contain Block 4 information, so

include the corrected Block 4 worksheet with your RAL corrections

– 7 day reminder 102

RNL/RAL Corrections

Corrections submitted after the deadline in the letter:

– Requests to increase funding will not be granted.

– PIA will work with applicants to make clerical error corrections until the FCDL is issued• PIA will request documentation to support the

correction, such as contract, invoice, bill, etc. 103

PIA Identified Changes

• Errors may be detected during PIA review• PIA may contact you and allow corrections

if they find certain discrepancies:– Item 21 doesn’t match Block 5– Discount for single entity doesn’t match

discount reported on different application– Item 21 includes entities missing from your

Block 4– Tech Plan is missing one or more required

element(s)

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Funding Commitments

After PIA review is successfully completed you get a Funding Commitment Decision Letter (FCDL)

– Cover page has important date-reminders– Reports status of individual funding requests:

• Funded• Not funded• As yet unfunded (Priority 2 requests)

– May receive more than one FCDL

Check all entries on the FCDL carefully to make sure there are no data entry errors.

Use the information on the FCDL to prepare your Form 486.

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Questions?

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Start of services Form 486and

Invoicing Form 472/474

Starting Services / 486

• Notifies USAC that services have started and invoices can be paid

• Certifies that Tech Plan (if required) meets program requirements.

• CIPA compliance – file proof ofInternet safety policyPublic notice or meetingTechnology protection measure (filter) CIPA does not apply to Telecom Services Local and Long distance.

• But if you apply for cell phones and blackberries or any data transmission services – you must be CIPA compliant

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Starting Services / 486

• Form 486 Deadline• Form 486 must be filed no later than

• 120 days after the Service Start Date OR• 120 days after the date of the FCDLwhichever is later.

If you file late your funding commitment will be adjusted to reflect the new start date corresponding to 120 days before the filing date.

Form 486 Notification Letter (486NL)– USAC will accept invoices once the Form 486 is

certified.109

Invoicing BEAR or SPI? Why?

Why would you choose one or the other?

• Form 472, Billed Entity Applicant Reimbursement (BEAR) Form

– Applicant pays for services in full and then requests reimbursement from USAC

– The form is submitted through the SP and they have to certify the invoices

• Form 474, Service Provider Invoice (SPI) Form– Service provider discounts customer (applicant)

bills and then requests discount amount from USAC

– The applicant pays only the non-discounted share

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How do reimbursements or BEARs work?

How do discounted bills or SPIs work?

Review of Invoices

• Service providers and applicant must review BEAR/SPI to ensure:– Only eligible services are being billed – Only services that were approved on the

application are being billed– Services were delivered consistent with the FCDL

and any agreements– Any service interruptions are accounted for

Follow through and ensure that Service providers sign off all months and all invoices

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Invoicing / 472 or 474: TIPSForm 472 (BEAR Form)

• DO NOT wait till the last day to file. Remember that the Service provider has to sign off on these.

• DO keep checking that your service provider has signed off on your 472 online

• DO check your calculations.• Do make sure you have paid your non-discount share.

Invoicing deadlines• Form 472 or 474 must be filed online or postmarked no later than

• 120 days after the last date to receive service• Can be monitored online to ensure that vendors have certified.• File for invoice extension if needed

You will receive a BEAR Notification Letter after your BEAR filing read it to see if you have submitted successfully

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Questions?

Program Compliance

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117

Know Your Role Applicants

– Write tech plan, file Form 470 and write RFP, evaluate bids, select provider, document the process, file Form 471, get tech plan approved, file Form 486, select invoice method, file BEARs

Service Providers

– Respond to 470/RFPs, assist with preparing Item 21 attachments, provide technical answers on questions regarding specific goods and services requested, but NOT on competitive bidding; file SPIs and/or approve BEARs; file SPAC

Consultants

– Follow the role of their client – either applicant or service provider

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Certifications Applicants certify that:

– Have secured access to necessary resources– Have complied with all FCC, state and local competitive

bidding and procurement regs– Non-discount portion of the costs for eligible services will

not be paid by the service provider – false statements on this form can be punished by fine or

forfeiture Failure to comply with program rules could result in

civil or criminal prosecution– Persons who have been convicted of violations in the

program are subject to suspension and debarment from the program

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Selective Review and Heightened Scrutiny

These reviews will take additional time and will hold up commitments until they are completed

Selective Review Information Request (SRIR) contains some of the questions that may be ask

May include review of: – Budget– Necessary Resources– Competitive Bidding and Contracts– Pattern Analysis– Targeted questions based on potential violations

Document Retention• Document retention timeframes:

– 5 years from last date to receive service • FY 2010 – this is at least June 30, 2016

– Any document from a prior year that supports current year must be kept until 5 years from last date to receive service as well

– Eg. Contract from 2004, used to support FY 2010 FRNs, must be kept until at least June 30, 2016

– Applicants must retain all pre-commitment documents that show compliance with all FCC rules

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Document Retention and Audits

Audits are done by an external agency – to ensure compliance to rules, – To ensure that there is no waste, fraud and abuse – To ensure that there are no improper payments made.

It is easier to keep track as you go along than to scramble when auditors are knocking on your door.

Appearances are important If you are listed as the contact - you need to keep all

documents – don’t expect the accounts to keep documents or archives to trace them for you.

Applicants have been asked to pay back what they have received, sometime years later.

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Retain, retain, retain

Retain documents to show your compliance:

– Letters of Agency and any agreements with all consultants

– Technology Plan (both draft and final approved version) and TPA Plan Approval letter

– RFP, including evidence of publication date and any solicitation you did

– Any and all bids (winning and losing)

– Email to yourself if you get no or one bid

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Retain, retain, retain

Applicants retain documents to show compliance: – Documents describing bid evaluation criteria

and weighting– Any correspondence with potential bidders– Documents related to the selection of the

service provider(s)– Signed and dated copies of contracts– Also, see further list on USAC website under

document retention

Appeals USAC decisions can be appealed to USAC or to the

FCC.• Generally, appeal first to USAC.• Can appeal to the FCC if USAC does not grant

the appeal. Can be filed electronically or on paper. Must be filed electronically or postmarked within 60

days of the USAC decision. Requests for waivers of rules must be filed with the

FCC.

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SL News Briefs

Emailed each week Subscribe from website Cover topics of current interest Archive of past issues Search by topic or date

Tip

Sheets

One-page high-level guidance documents on major program topics

Contain links to guidance documents Available on website and during site visits

http://www.usac.org/sl/about/tip-sheets.aspx

Viewing Options USAC Tutorials at Blip.tv – For slower connections; can be viewed by most browsers.USAC Blog – Higher quality; requires latest Flash player.USAC Tutorials at MotionBox – Higher quality. Click "View All" to see all available tutorials. You should have latest version of your browser, and select "SD - Standard Definition" if not already selected.Video Tutorials: http://www.usac.org/sl/about/video-tutorials/Presentation slides: http://www.usac.org/sl/about/training-presentations/

Video Tutorials and presentations

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E-rate resources for AZ

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Arizona Department of Education (ADE) http://www.ade.az.gov/erate

Arizona State Library Archives and Public Recordshttp://www.lib.az.us/erate/

Arizona State Procurement Office (AZSPO) https://procure.az.gov/bso/login.jsp

E-rate Central http://www.eratecentral.com/• E-rate resource center http://www.eschoolnews.com/resources/reports/ffl/index.cfm

USAC Resources• USAC Homepage

http://www.usac.org/sl/

• USAC Reference Pagehttp://www.usac.org/sl/tools/reference-area.aspx

• USAC toolshttp://www.usac.org/sl/tools/search-tools/

• USAC Outreach and Traininghttp://www.usac.org/sl/about/outreach-training.aspx

• Use the “Submit a Question” link on the web site http://www.slforms.universalservice.org/EMailResponse/EMail_Intro.aspx

• Fax toll-free at 1-888-276-8736• Telephone toll-free at 1-888-203-8100Always ask in writing and insist on a written response.

AZ Contact Information

Brett Hinton 602-542-4214

Brett.Hinton@azed.gov/ Brenda Wright 602-542-4214

Brenda.wright@azed.gov/ Mala Muralidharan 602-926-3601

mala@lib.az.us/

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Questions?