Title: E-rate/CTF Training for Year 2004 Version 4.0
1E-rate/CTF Training for Year 2004Version 4.0
- California Department of Education E-rate/CTF
Training Collaborative - October 2003
2Workshop Objectives
- Provide unbiased guidance to apply for E-rate and
CTF telecommunication discounts. - Provide information about program changes.
- Provide state, local, and vendor perspectives.
- Provide information references.
3E-rate and CTF Application Process
4What is E-rate?
- E-rate (Education-rate) is a federal program,
officially known as Universal Service Fund (USF),
Schools and Libraries - The annual fund is 2.25 billion. It is
administered by the Schools and Libraries
Division (SLD). - The fund offers 20-90 discounts on
telecommunications, Internet service, and
internal connections.
5What is CTF?
- California Teleconnect Fund (CTF) is a state
program administered by the California Public
Utilities Commission (CPUC). The fund is now 55
million annually.
6California Teleconnect Fund (CTF) Program
- A Program of the California Public Utilities
Commission (CPUC)
7Purpose of the CTF Program
- The CTF offers 50 discounts on monthly recurring
costs of telecommunications services to eligible
entities. - Eligible entities
- Schools and libraries
- Hospitals and health clinics
- Community Based Organizations
- Consortia of eligible entities
- Discounts
- 50 below the rates (tariff or negotiated rate)
charged to other businesses for the same services
or their functional equivalents
8How the CTF Is Funded
- Funded by all end users of telecommunications
services through a surcharge on their
telecommunications bills
9Services That Qualify for a CTF Discount
- Measured business or its functional equivalent
- Switched 56 or its functional equivalent
- Integrated Services Digital Network (ISDN) or
its functional equivalent - T-1
- OC3-OC192
10Charges/Taxes Eligible for CTF Discount
- Monthly recurring charges
- Company-specific surcharge/surcredit
- CPUC user fee
- Federal excise tax
- 911 tax
- Local/city Tax Variable
- The taxes and surcharges or surcredits covered by
the CTF Program are based only on the approved
CTF discount amounts.
11Charges Not Discounted by CTF
- Nonrecurring charges (e.g., installation charge)
- Usage charges
12CTF Application Process
- Applicant submits CTF application to CPUC with
all required information (e.g., IRS tax-exempt
statement) - New CTF application and instructions are
available at - http//www.cpuc.ca.gov/static/industry/telco/publ
icprograms/ctfapp.pdf
13CTF Application Process
- The CPUC calculates discounts based on the date
the application is received by the CPUC. - Once the application is approved by the CPUC, it
is not necessary to reapply for CTF discounts. - Applicants inform telecommunications providers of
changes or additions to lines/services to receive
CTF discounts for additional services.
14Applying for E-rate
15E-rate
- Eligible entities schools and libraries
- Eligible services
- Eligible uses new definition
16Discount Percentages
- Number of students eligible for National School
Lunch Program - Rural and urban designation
17Funding Priorities
- Priority One Telecommunications and Internet
access - Priority Two Internal connections
18E-rate Application Steps
- File Form 470 to request services.
- Receive Form 470 acknowledgment letter.
- File Form 471, Request for Funding.
- Receipt Acknowledgement Letter (RAL) from SLD
- SLD Review Form 471.
- Review and correct Funding Commitment Decision
Letter - File Form 486 (Aug 2003) and Form 486
notification. - Receive discounts.
- Modify funding requests on Form 500.
- Reference http//www.sl.universalservice.org/appl
icants/processflow.asp
19Why File a Form 470?
- Its required for competitive bidding and
procurement of services. - It initiates the application process.
- It describes the technology services being
sought.
20Form 470 - Items to Consider
- Calculate your E-rate discount.
- Choose an E-rate application strategy.
- Design an education technology plan.
- Identify your non-discounted costs
- File online by applying for user ID and PIN .
- Applicant PIN Request System https//slpin.univers
alservice.org/SL_PIN/NECAServlet.jrun?hszActionST
ARThszCommandREQUESTszUserTypeSLD
21Online Form 470
- Apply online at http//www.sl.universalservice.org
/menu.asp. - Select either the Form 470 PDF or
- Form 470 Interview.
- Print each page of the application as you
complete it online before selecting "Next" to
move to a new screen.
22Form 470 - Blocks 1 and 2
- Complete all requested information in Blocks 1
and 2. - Print and file the screen that displays the
application number. You will need to refer to
the application number later. Read Form 470
instructions and directions on the form.
23Form 470 Block 3
- Technology assessment of services being sought
What kind of other technology is to support the
effective use of E-rate equipment?
24Form 470 Block 4
- Identifies recipients of services eligible
entities. - Identify billed entities and ineligible entities.
- This information is required to help service
providers understand the scope and location(s) of
the services being sought.
25Form 470 Block 5
- Certifies that discounts are for eligible
schools/libraries. - Certifies the technology plan.
- Certifies eligible purposes, no resale or
transfer - Secures access to necessary resources
26Form 470 Follow-up
- Work with potential vendors to estimate costs for
Form 471. - Keep copies of all responses to Form 470 and bids
considered. - Develop and keep documentation of the process for
selecting a specific vendor (price is the most
heavily weighted factor in the decision). - Select the most cost-effective provider.
27Form 470 Reminders
- Procurement must be competitive and follow the
rules. - Excessive vendor involvement is not allowed.
- Form 470 cannot be completed by a service
provider.
28Form 471 Request for Discounts
- Form 471 must be preceded by the filing and
posting of a Form 470 for at least 28 days. - Online, filing is easier and more accurate.
- File individual Form 471 for Priority 1 and
Priority 2 discounts. - Need to submit item 21 attachments after filing
online.
29Form 471 Guidelines
- Wait 28 days before signing up for services.
- Note contract extensions and contract expiration
dates. - Note the E-rate funding escape clause.
- Include product or service upgrades/substitutions
in contract. - Separate internal connections/wiring portions of
contracts for highest discount schools. - Make sure procurement complies with local and
state procurement rules.
30Form 471 Blocks 1 and 2
- Block 1 is to provide information on the billed
entity - Contact information, billed entity number
- Summer contact information
- Block 2 is used to indicate changes to the
contract information. Contact SLD Help.
31Form 471 Block 4
- Discount calculations
- See http//www.sl.universalservice.org/reference/
Discount.asp - Maximize discounts by counting the number of
students eligible for free and reduced price
lunches. - Use Form 471 instructions and SLD references for
calculating discounts. - Review alternative mechanisms for calculating
discounts. - See http//www.sl.universalservice.org/reference
/alt.asp
32Form 471 Block 5
- Document the services ordered.
- Create a separate Block 5 worksheet for each
- Service provider
- Contract
- Category of service (telecommunications,
Internet, internal connections) - Establishing Form 470
- Separate out ineligible services.
33Form 471 Block 6
- Use Block 6 to certify form 471.
- Submit online if you have a PIN. Attach a copy
of the online confirmation page and attach that
to the top of the item 21 attachment(s). - Justify duplicative services in item 21.
34Form 471 Item 21 Attachments
- Label clearly to identify the correct Form 471.
- List services/items requested (quantity,
description, cost, type of cost, narrative). - Separate ineligible services/items.
- Attach quote or bill from the vendor (phone
bills). - Document nonduplicative services.
35Form 471 Submission
- Was Form 471 signed after contract?
- Was Form 471 signed by an authorized person?
- Is the applicant prepared to prove that they had
the money in the bank? - Tips to handle the program Integrity Assurance
teams questions - Make sure you know what it is asking.
- Dont answer more than you were asked.
- Retain PIA responses for audit purposes.
36Form 471 Receipt Acknowledgement Letter (RAL)
- Correct data entry errors.
- Provide or correct applicants contact
information. - Correct (not change) a Service Provider
Identification Number (SPIN). - Reduce, cancel, or split a Funding Request Number
(FRN). - Submit corrections, if any, within 3 weeks after
date on RAL
37Form 500
- Modify funding requests Cancel or reduce the
FRN. - Modify service dates See SLD guidance on
changing service dates and contract expiration
dates.
38Keep Copies
- All form submissions and proof of submission
- All bids, awards, contracts, assumptions,
decisions, budgets, tech plan certifications - All communications with the SLD (e-mail may be
used for documentation) - Documents should be kept for 5 years, and
organized by funding year.
39Actions to Take After Receiving the FCDL
- Actions to Take After Receiving FCDL
40Overview
- File a Form 486 by the deadline or else lose
discounts. - Communicate all necessary information to service
providers. - Document all new work done during funding year.
- Track discounts OR file a Billed Entity Applicant
Reimbursement (BEAR Form 472)
41Form 486
- Why file
- When to submit (dont miss the deadline)
- Ways to submit
- tips
42Form 486 Why File
- No discounts until the Form 486 is filed
- To alert SLD that services are being provided
- To certify that your technology plan is approved
- To certify compliance with the Childrens
Internet Protection Act (CIPA) compliance
43Form 486 Submission
- Submit Form 486 within 120 days of FCDL date or
start of service, whichever is later. - Submit Form 486 on paper or online.
44Form 486 Tips
- File on time or else you will lose some funding.
- Make sure your technology plan is approved by the
start of service. - CIPA compliance has not changed for school
districts. - Libraries are now required to comply with CIPA
(see http//sl.universalservice.org/whatsnew/2003/
082003.asp082003).
45Steps to Take After Receipt of FCDL
- Provide necessary information service providers
- - Existing Services which FRN will fund
discounts and at what percent eligibility - - New services which FRN funds the project and
timeline for project (may change due to date
of FCDL) - - Service substitution or SPIN changes (complete
paperwork earlier in the FY)
46Steps to Take After Receipt of FCDL
- Document all new work performed during funding
year - All lines and circuits installed and the date of
installation - Dates of lines and circuits disconnected, if any
- Every piece of equipment installed or moved
(Documentation is necessary in case of an audit
in the future)
47Steps to Take After Receipt of FCDL
- Track discounts OR file BEAR Form 472
- Discuss with each service provider whether
discounts will appear on bills or BEAR Form 472
will be needed. - Work with service provider to understand where
discounts appear on the bills. - If BEAR Form 472 is needed, pay bill in full and
then follow the process at http//www.sl.univers
alservice.org/form/default.aspapplicants
48California Procurement Options
- California Department of General Services
49Purchase Options
- Purchase from a single vendor
- Can integrate multiple technologies
- Purchase from multiple vendors
- Potentially wider variety of choices
- Make consortia arrangements
- Leverage buying power of multiple entities
- Purchase through State of California contracts
- - CMAS, CALNET
50Masters/State Contracts
- Information technology services
- Bid-based contracts
- Competitive products, services, agencies, and
prices - No order limit for local agencies
51Eligible Services Available through State
Contracts
- Telecommunications services
- Internet access services (many suppliers)
- Internal connections
52Contract Agreement Number
- Give resulting E-rate contract local contract
agreement number (for CALNET, use locally defined
number). - Contract agreement number and state contract
number need to be included on purchase order.
53Contract Term
- Issue date - Date agreement signed (must be
before the Form 471 application deadline for the
funding year) - End date - Use last date of the funding year to
allow for delays (for telecommunications and
Internet access June 30th and for nonrecurring
services September 30th). - http//www.sl.universalservice.org/reference/Servi
ceDeliveryDeadlines.asp
54Contract Considerations
- Verify current status of small business, Disabled
Veteran Business Enterprise (DVBE), and
contractor license certifications - Verify that products/services are on the contract
(ask for pages from the contract). Make sure that
the state contract contains all required products
and services.
55Contract Considerations
- Consider the E-rate funding cycle
- Stipulate in purchase order that award is
contingent upon full, anticipated E-rate funding. - Require that prices for change orders be at or
below the purchase order rates (not to exceed the
state contract rates).
56Contract Considerations
- Communicate with supplier up front regarding
eligibility for a project discount. - Specify functional equivalent substitution if
products become outdated between application date
and actual date of delivery. - Note that procurement could result in multiple
contracts. - Separate E-rate eligible and noneligible items
- Ensure accurate tracking of discounts.
57CMAS Considerations
- Asking for CMAS-only vendors is allowed, but you
must still have a competitive procurement process
and evaluate multiple CMAS vendors. - Multiple CMAS responses allows price comparisons
and competitive bidding to take place.
58Contracts Documentation
- Be prepared to provide legal opinion to prove
such documentation constitutes a contract
pursuant to California Public Contract Code. - Quotes are not considered contracts according to
SLD rules.
59Program Topics
- Vendor Involvement
- Managing Phone Bills
- Reviews and Audits
- Program Updates
- Strategies
60What Vendors Can Do and May Not Do in the E-rate
Program
- California Department of Education E-rate/CTF
Training Collaborative - October 2003
61Vendor Involvement
- What the vendor can do to help you
- What the vendor may not do to help you
- Waive the nondiscounted cost.
- Give proper assistance in Form 470 process.
- Assist applicants customers with tech plans.
- Give proper assistance in Form 471 process.
- Inappropriate roles for service providers
62Vendor Selection
- The applicant has a duty to conduct a fair,
open, and competitive procurement process that
seeks the most cost-effective solution to its
technology needs. Price must be the most
important factor under consideration but should
not be the only consideration.
63Vendor Qualifications
- Vendor/service providers (SPs) experience
- Ability of SP to meet deadlines
- Proximity of SP to work site
- Quality of work and ability to manage the project
- Ability to provide necessary maintenance and help
- Prior E-rate experience
64Appropriate Role of Vendor/Service Provider
- Before submission of the Form 470, service
providers should - Understand the requirements of the E-rate
technology plan requirements - Understand the E-rate program rules,
requirements, and timelines. - Offer unbiased technical assistance that does not
have an undue influence on the applicants
ability to follow the open, fair competitive
bidding process.
65Appropriate Role of Vendor/Service Provider
- Before submission of the Form 470 (Continued)
- Provide assistance within guidelines of the
E-rate program. - Provide input ONLY on development of the Request
for Proposal (RFP). - Wait 28 days before signing contract with
vendor/service provider.
66Appropriate Role of Vendor/Service Provider
- After submission of the Form 470
- Provide information on products and services
being offered. - Assist the applicant in the creation of the Form
471 item 21 attachment documentation. - Provide a quote or a bill and a copy of the
contract. - Provide quantity, product/service description,
unit cost, extended pre-discount cost. - Visit the site if all bidders are allowed to do
so.
67Appropriate Role of Vendor/Service Provider
After the FCDL
- Assist with service substitution information and
SPIN change requests (if required). - Provide easy-to-understand account information.
- Review billing arrangements with applicant
(discounts or reimbursements). - Provide current information on SPIN numbers and
legal names. - Remind applicants of deadlines and timelines.
- Encourage compliance with program rules.
68Service Providers May Not
- Complete or sign applicants Form 470 and Form
471. - Serve as the contact or evaluator on Form 470.
- Serve as a technology plan approver.
- Prepare an applicants Request for Proposal
(RFP). - Enter into a contract prior to the required
28-day waiting period. - Provide Alternative Funding grants or
foundations as payment applicants undiscounted
portion of the service providers bid. See
http//www.sl.universalservice.org/reference/frees
ervices.asp - Make determinations on product or service
eligibility.
69Service Providers May Not
- Interfere with or hinder the competitive bidding
process. See http//www.sl.universalservice.org/d
ata/ppt/2003/Service20Provider20Issues.ppt - Offer to waive the nondiscounted portion of the
bill for which the applicant is responsible. - Provide the answers to the Selective Review
Information Requests on behalf of the applicant.
70Consequences for Violation of Program Rules
- Denial of funding
- Cancellation or adjustment of funding
- Audit or other investigation
- Criminal investigation
71County Office of Education (COE) as a Service
Provider
- The SLD views intermediate service agencies, such
as county offices of education, that provide
services to be the same as any other vendor.
COEs must must follow the same rules.
72Managing Phone Bills
73Managing Phone Bills
- Summary billing
- Applying for nondiscounted costs
- Summary billing and your E-rate Form 471
- What to do before requesting summary bills
- What to expect from summary bills
- Other phone bill management strategies
74Summary Billing Preparation
- Check to see if your carrier has summary billing.
- Get a list of all telecommunication lines.
- Decide how you want the bill to be organized.
- Convert all billed telephone numbers and working
telephone numbers to the same billing cycle. - Determine level of detail (eligible/ineligible,
by site, voice/data, etc.).
75Summary Bills
- Summary pages
- Detail pages for each billed telephone number and
working telephone number - Tracking costs for filing your Form 471
- -Makes Item 21 attachments easier
- -Separates ineligible numbers
- -Lists E-rate discounts
76Phone Bill Strategies
- Always pay current charges.
- Request a check for credits accumulated.
- Build an E-rate process tracking system.
- Use summary billing to track your discounts.
77Review and Audit Readiness
- Documenting Compliance with E-rate Program Rules
78Documentation for Audits and Reviews
- Program Integrity Assurance (PIA) reviews
- Selective reviews
- Audits
79Minimum Processing Standards
- Correct form.
- Complete applicant information.
- Complete submission of form.
- File online to ensure you have met minimum
processing standards.
80PIA Reviews
- The PIA team checks for eligibility of entity.
- The PIA team checks for eligibility of service.
- The PIA team verifies discount rate calculation.
- Applicant should be aware of timelines to
respond to the PIA team.
81Selective Reviews - Item 25
- Preparing for Selective Reviews
- October 2003
82Selective Reviews
- They are used by the SLD to verify
- Competitive bidding and vendor selection
- Form 471 item 25 certification, Can you use and
support the product and services requested? - Ability to pay for nondiscounted costs
- Technology plan
- They are conducted at the billed entity level.
83Tips on Selective Reviews
- Provide the requested information in 14 days.
- Request an extension of time if necessary.
- Document the approval of the extension (date, SLD
contact, extension date). - Fax or e-mail requested information to SLD.
- Contact PIA representative to establish a
relationship.
84Competitive Bidding Vendor Selection
- Provide RFP or reason for not providing an RFP.
- Keep all bid responses, not just the one
selected. - Document how you selected the vendor and keep the
documentation. Remember cost must be the
heaviest weighted factor, but there can be other
factors.
85Item 25 Certification
- Documentation of your ability to pay for your
share of E-rate discounts - Estimates of non-E-rate hardware, software,
professional development, retrofitting, and
maintenance investments that are necessary to
make effective use of the E-rate discounts - Technology plan review
- Estimate of the technology level of all schools
or libraries in your organization after the
receipt of E-rate discounts
86Preparing for Audits
87Purpose of E-rate Audits
- To protect the program from waste, fraud, and
abuse - To ensure the program accomplishes its mission of
affordable telecommunications and information
services for all eligible schools and libraries - To help the program meet its mission in the most
effective and efficient manner possible
88What Auditors Look for
- Inadequate competitive procurement process
- Ineligible services being funded
- Lack of resources to support effective use of
E-rate-funded equipment - Unauthorized equipment substitutions with
increased costs and decreased functionality - Incorrect discount calculations
- Implemented evaluations as indicated in your
technology plan - Location of E-rate-funded equipment
89Potential Consequences of Selective Reviews and
Investigations
- Denial of funding commitment
- Rejection of invoices
- Commitment adjustment
- Audits
- Reimburse E-rate
- Civil lawsuit
- Subpoena
- State or local prosecution
- Recovery under the Federal Debt Collection Act
- FCC enforcement action
- Civil false claims action
- Criminal action
90Audit Findings
- Asset or inventory tracking documents missing or
not complete - Competitive bidding violations
- Invoice documentation, SP invoice/bills
- Disbursement
- Tech plan and evaluation
- National School Lunch Program data documentation
not available
91Be Prepared for the Auditors
- Rules require records to be kept for five years.
- Keep e-mail, notes, memos, FCC Form instructions,
eligibility list, etc. - Audit is based on the rules in place at the time
your application was processed. - Be responsive to auditors
- Make it as easy as possible for them,
- but dont be afraid to question their requests
and/or decisions. - Turn to experts, reputable vendors, and
third-party consultants
92Document Testing
- Free and reduced-price lunch surveys
- Technology plan
- Budget documents
- Original RFP and bidders list
- All bids, selection criteria, and reasons for bid
selection - Original contracts
- Purchase orders
- Original invoices
- Shipment receipt information
- Inventory records
- Canceled checks and payment dates
- Item 21 attachments
93Contract Review
- Test all contracts.
- Are you in compliance with state and local
regulations? - Did you really conduct a competitive bid?
- Can you demonstrate how you chose the winner?
- Is the contract consistent with Form 470?
- Do contract dates correspond to Form 471?
94Signing Contracts
- Applicant must have contract, PO, or other
binding agreement. - Applicant may want to make contract contingent on
receiving funding. - Dont sign before allowable contract date (No
agreement to purchase, no P.O., etc.) - Funds will cover services delivered only during
the funding year (e.g., July 2004 - Sept. 2005
for YR 7).
95Signing Contracts (Continued)
- Be careful that contract language doesnt cause
problems down the road. - The term functional equivalent allows for
easier product/service substitutions later. - Specify responsibilities of applicant and
vendors - Form 486 submission
- Payments and invoicing of its portion
- Eligible services/locations
- Make sure original contract language specifies
the terms of renewal.
96Free Services
- The value of all price reductions, promotional
offers, and "free" products or services must be
deducted from the prediscount cost of services
indicated in funding requests. - Costs, trade-in allowances, and discounts must be
fairly and appropriately derived. - A proportionate cost allocation is required
between eligible and ineligible components.
97Invoices and Payments
- Vendor must invoice applicant before invoicing
SLD. - Applicants must pay their nondiscount share
- Invoices must clearly show what services are
being delivered (and where). - Applicant verifies that discounts are applied
properly - Applicant credits or adjustments must also be
applied to SLD.
98Changing a Service Provider
- The change is subject to deadline.
- The process is easier than it once was.
- Applicant can get out of old contract.
- Applicant has informed original vendor.
- State and local procurement regulations allow the
change. - The change will be reviewed by auditors.
99Service Substitution
- New product(s) must have the same functionality
- Same medium (e.g., voice, data, video), same
category - Service substitution must be permitted under
procurement rules. - Substitutes must not cost more than the original
product/service, or the applicant must pay any
increase.
100Service Substitution (Continued)
- The substitute must not include greater
percentage of ineligible services. - The substitute must be in line with Form 470 and
RFP, if any. - The substitute will be reviewed by auditors.
101Possible Penalties/Recoveries
- Potentially several millions of dollars may be
recovered, based on Andersen and Office of
Inspector General audit work - Potential consequences
- Recovery of any and all funds paid from either
the beneficiary or the service provider - Suspension and/or debarment from the program for
either beneficiaries or service providers
102Transition to Investigation
- Intentional fraud, waste, and abuse uncovered by
audit will result in an investigation. Possible
investigative issues - Procurement irregularities
- Billing for goods and services not provided
(false claims) - Ineligible items being funded
- Misappropriation of assets
- Beneficiaries not paying the undiscounted costs
- Misrepresentations on forms/certifications (false
statements)
103Audit Reminders
- Audits are easier if you make them part of your
E-rate application process. - Document your access to resources to pay for
nondiscounted costs to make effective use of
E-rated services and equipment. - Keep E-rate documentation by funding year.
- Review SLD audit references on the Web.
104Year 2004 E-rate Program Updates
- Program Changes, New Eligible and Ineligible
Services, New Interpretations of Rules
105Program Changes
- Unused funds rollover more funds?
- Appeals deadline 60 days
- Technology plans more specific, written by the
date the Form 470 is submitted - Legally binding contracts quotes not acceptable
- 30 rule ineligible and unsubstantiated
- Duplicative services need to justify
106New Eligible Services
- Definition of educational purpose on the
premise - Voice mail in any category
- Wireless same as wireline
- Firewalls servers or service
- Alarm lines but not 911 or E911 (yet)
- Web hosting but not Web site development
- File servers firewall servers
107New Ineligible Services
- Dark fiber vs. lit fiber
- VoIP Voice-over IP as a service
- UPS/battery backup limits
- Maintenance - limited to basic, no managed
network services
108Definition of Educational Purpose
- . . . in the case of schools, activities that
are integral, immediate, and proximate to the
education of students, or in the case of
libraries, integral, immediate, and proximate to
the provision of library services to library
patrons, qualify as educational purposes under
this program. Presume that activities on school
or library property meet this standard.
109Duplicative Services
- Deliver the same function to the same population
in the same location during the same period of
time. - Duplicative is considered excess capacity, and
redundant needs should be justified (e.g., system
reliability). - Justify on Form 471, item 21.
110Technology Plan
- Technology plan must be written by Form 470
submission. - Technology plan must be approved by Form 486
submission. - Did you correctly characterize your technology
inventory? - Does your technology plan actually match what you
are doing? - Are all the E-rate services/products addressed in
the technology plan?
111What Does All This Mean?
- More eligible services, more E-rate funds
- Procurements by the rules
- More specific technology plans, written by Form
470 - Budget documentation
- Documentation to show effective use
- Alignment of Form 470, tech plans, budgets
- More reviews and audits
112Top Reasons for Denial
- 30 ineligible services
- Excessive vendor involvement
- Documentation not provided to SLD within
timeframe requested - Ineligible service provider or ineligible entity
- No Form 470 reference
- No contract when Form 471 filed
- Payment of nondiscounted costs
- Violation 28-day rule
113Looking Forward
- Possible new FCC initiatives
- Limits to internal connections requests
- Guidance on transferability of equipment
- Eligibility of 911 and E911 lines
- New Notice of Proposed Rule Making this fall
114Telecommunications Discount Strategies
115Year 2004 Strategies
- Improve your districts count of students
eligible for the free reduce-price lunch
program. - Understand rules regarding vendor involvement.
- File one Form 471 for Priority One and one Form
471 for Priority Two requests. - Understand your phone bills and use summary
billing.
116Year 2004 Strategies - Continued
- Document, Document, Document
- Use a stacking strategy to apply for E-rate and
CTF discounts. - Data retrieval tool and E-rate manager tool
- http//www.sl.universalservice.org/funding/opendat
asearch/search1.asp - http//eratemanager.com/
- Add new eligible services on Form 470.
- Do not use the term VoIP on your Form 470 for
telecommunication services. - For some applicants a consortia might work.
- See http//www.sl.universalservice.org/reference/
costaloc.asp
117Web References
- Schools and Libraries Division www.sl.universalser
vice.org - California Department of Education
www.cde.ca.gov/ls/et/ft/eratemain.asp - E-rate Central
- www.e-ratecentral.org
118Thank you
- Access to training materials and E-rate
references is available at www.cde.ca.gov/ls/et/ft
/eratemain.asp - Sign up on the CDE E-rate listserv to get regular
E-rate updates. See www.cde.ca.gov/ls/et/ft/erate
main.asp - Your county office of education and the
California Technology Assistance Project can help
with E-rate too.