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E-rate Training Workshop for Beginners Funding Year 2014


E-rate Training Workshop for Beginners Funding Year 2014 Presented by Julie Tritt Schell PA E-rate Coordinator For the Pennsylvania Department of Education – PowerPoint PPT presentation

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Title: E-rate Training Workshop for Beginners Funding Year 2014

E-rate Training Workshop for BeginnersFunding
Year 2014
  • Presented by Julie Tritt Schell
  • PA E-rate Coordinator
  • For the Pennsylvania Department of Education
  • Fall 2013

  • History and Program Administration
  • Applicant and Services Eligibility
  • Step-by-Step Program Requirements and Forms
  • Additional Rules
  • Morning break, if needed
  • Questions at end of each section
  • Lunch from 12 -1230
  • What does this mean?

Who is Here?
  • School Districts
  • IUs
  • Charter Schools
  • AVTSs
  • Non-public Schools
  • Libraries
  • Superintendents/Asst Supt
  • Business Managers
  • Technology Directors
  • Vendors
  • Consultants
  • Who is brand new to E-rate?
  • Who NOT on PA E-rate listserve?

What is E-rate?
  • Telecommunications Act of 1996 established
    Universal Service Discount Program for Schools
    and Libraries
  • Annual 2.25 billion program, adjusted for
  • Funding years named for the year in which they
  • FY 2014 July 1, 2014 June 30, 2015
  • Application process begins 6-10 months ahead of
    start of next funding year
  • Provides 20-90 discounts on eligible services
  • Fund made up from charges on your phone bills
  • Not a typical grant program

Who Administers E-rate?
  • FCC
  • Federal Communications Commission
  • Created program and sets rules and policy
  • USAC
  • Universal Services Administrative Company
  • Created by FCC to run E-rate and other universal
    service programs
  • Pays invoices
  • SLD
  • Schools and Libraries Division
  • Entity within USAC that runs E-rate
  • Makes no policy decisions

What is Julies Role?
  • Under contract with PDE to serve as PA E-rate
  • Provide outreach and training to schools and
    libraries in PA
  • Represent PA before federal policymakers
  • Maintain PA E-rate website and listserve
  • Act as resource when E-rate administrator cant

Fair Warning!
  • E-rate is not a short, easy process
  • Read listserve messages
  • Read form certifications
  • Be prepared for an audit
  • Stay organized!

Who is Eligible?
  • Public libraries eligible for LSTA funding
  • Public and private K-12 schools
  • For-profit schools not eligible
  • Pre-k eligible in PA (age 3)
  • Head Start entities eligible in PA but only if
    operated by a public school entity
  • Cannot have endowment exceeding 50 million
  • Consortia comprised of eligible schools and/or
  • What is a NIF?
  • Non-instructional facilities of schools and
    libraries are eligible for Priority 1 E-rate
    funding and Priority 2 E-rate funding if the NIF
    is the hub of the network

Eligible Residential Locations
  • Residential locations within schools serving
    (began in FY 2011)
  • tribal students
  • children with physical, cognitive, or behavioral
  • juvenile justice students, or
  • residential schools where 35 or more of their
    students are eligible for NSLP 
  • Schools can be public or private and both
    Priority 1 and Priority 2 services are eligible
  • Residential locations of cyber school students or
    employees are not eligible

Questions aboutApplicant eligibility?
What Services areEligible and Ineligible?
  • Eligible Services List in Binder
  • FCC revises each fall

Funding Priorities
  • FCC established funding priorities because demand
    always exceeds cap.
  • Priority 1
  • Telecommunications and Internet Access Services
  • All services -- nothing that is purchased
  • All eligible requests filed by application
    deadline likely to be funded, regardless of
    discount level
  • Priority 2
  • Internal Connections and Basic Maintenance of IC
  • If funding remains after Priority 1 funding has
    been committed, funds are then committed to
    neediest applicants (90 discount level), then to
    others in order of discount until funds are

P1 Eligible Telecom Services
  • Local, long distance, cellular phone service and
  • Includes voice mail and custom calling features
  • Centrex, hosted VOIP phone service
  • Broadband services
  • T-1, PRI, Frame Relay, ISDN, leased lit and dark
    fiber, etc.
  • Installation of eligible telecom services
  • if installation is included on your application
  • Most taxes and surcharges
  • Must be provided by an Eligible
    Telecommunications Provider (ETP)
  • Except hosted VOIP and fiber

P1 Ineligible Telecom Services
  • Sharing of bandwidth to ineligible entities
  • 1-900-type calls
  • Payphone service
  • Non-published phone numbers
  • Additional directory listings
  • End user equipment (phones, beepers, cell phones,
    fax machines, etc.)
  • Certain fees or charges
  • Late fees or finance charges
  • Paper statement fees
  • Cost recovery fees
  • Property tax fees

P1 Internet Access
  • Eligible
  • Basic conduit Internet access
  • Hosted E-mail service
  • Basic webhosting, including
  • discussion boards, blogging, instant messaging
    and chat
  • Firewall fees
  • if part of standard vendor service
  • Data plans (3G/4G)
  • Lit fiber service
  • Leased dark fiber service
  • Hosted VOIP service
  • Ineligible
  • Filtering
  • Unless part of standard vendor service
  • AntiVirus/AntiSpam
  • Any remote access outside school property to
  • Broadcast messaging services
  • Ineligible webhosting features
  • content, website development costs, searchable
    databases or content, student attendance
    reporting, and grade books
  • Any Internet or data usage off school campus

Equipment Eligibleto be Bundled
  • Called On-Premise, Priority 1 Equipment
  • Permitted if bundled with service
  • Must tell SLD make/model of equipment
  • Must certify to TN Test
  • No applicant ownership ever
  • No exclusive use
  • LAN functions without use of equipment
  • Service provider maintains equipment
  • Not applicant
  • Ask Julie if youre unsure of your answers

Lit Fiber Eligibility
  • Can be leased from telecommunications provider
    (such as Verizon, Comcast, Sunesys, Sting, etc)
  • OR
  • Can be leased from any other provider (such as
    electric company, cable company, regional
    network, etc.)
  • Service may be posted in either telecom or
    Internet access category

Dark Fiber Eligibility
  • Beginning in FY 2011, applicants may lease dark
    fiber from any provider, with these conditions
  • E-rate will not pay for new fiber networks off
    school property
  • Installation (non-recurring) charges eligible
    from school building to edge of school property
  • Modulating electronics must be provided by the
    applicant and cannot be bundled with the cost of
    the service

Dark Fiber Eligibility, cont.
  • Fiber must be lit immediately
  • Excess fiber that is not lit is not eligible
  • Network maintenance costs are eligible
  • Service may be posted in either telecom or
    Internet access category
  • Apples-to-apples comparison should be done to
    ensure that leasing dark fiber is most cost
    effective method of delivering service

Hosted VOIP Service
  • Service may be posted in either telecom or
    Internet access category
  • Leased Gateway or router may be included with
    monthly lease cost
  • End user handsets and softphones are not eligible
  • Be wary of vendors that try to bundle this
    equipment in their proposals
  • FCC requested comment on whether bundled VOIP
    should be E-rate eligible. Decision is expected
    in October/November 2013

P2 Eligible Internal Connections
  • Wireless access points
  • Private branch exchange (PBXs)
  • Firewalls
  • Installation of eligible internal connections
  • System operating software
  • For eligible equipment only
  • Network and phone wiring
  • Routers, hubs, switches
  • Certain network servers
  • e-mail, DHCP, firewall, DNS
  • Video codecs
  • VOIP networking equipment

Beginning in FY 2013 When seeking bids,
descriptions must be non-manufacturer specific.
Descriptions may state Cisco 2811 switch or
P2 Ineligible Internal Connections
  • Personal computers
  • FAX machines
  • Asbestos removal
  • Cameras
  • Electrical wiring
  • Teacher training
  • Security wiring
  • Servers for storage
  • Network management s/w
  • Curriculum software
  • Phones, beepers, aircards
  • Salaries of school or library staff
  • Filtering software

P2 Basic Maintenance
  • Beginning in FY 2011, maintenance severely
  • Eligible
  • Bundled manufacturer warranties up to 3 years
  • Cannot have a separate price
  • Software, patches, online tech support
  • Actual labor and break-fix cost
  • Ineligible
  • Unbundled warranties, insurance-type warranties,
    including full Smartnet (portion of Smartnet

P2 Basic Maintenance
  • Contract
  • Must separately identify cost of maintaining
    E-rate eligible equipment from E-rate ineligible
  • Calculation of funding request
  • Must be based on an estimated number of
    maintenance hours per year for eligible
    equipment, based on current life of equipment and
    history of needed repairs
  • Calculation of reimbursement amount
  • Break/fix - USAC will only pay for cost of actual
    work performed (which includes labor, equipment
    fix, or if it is beyond repair, equipment
  • Software patches/Online tech support 100, no
    documentation needed

2/5 Rule
  • An entity may only receive discounts 2 out of
    every 5 years for internal connections
  • Doesnt include basic maintenance
  • Applies at the building level, not district level
  • If central equipment is purchased for NOC, each
    building receiving benefit of that equipment
    receives a strike
  • Plan accordingly to maximize discounts
  • Strikes related to funding commitment (FCDL),
    not 471 or invoices
  • Can cancel FRN to get strike (year) back, but not
    after funding has been disbursed
  • Hint Dont use a strike (year) for a 500 piece
    of equipment

Transfer of Equipment
  • E-rate-funded equipment must remain at approved
    site for 3 full years after installation
  • After which it may be moved to another eligible
  • Documentation must be retained describing
  • If school or library closes, equipment may be
    moved to another entity, regardless of discount
  • Must send letter to SLD outlining closing of
    school and transfer of equipment
  • Must keep documentation regarding transfer for 5
  • After 5 years, equipment may be disposed of or
  • Disposal does not need to be reported to USAC
  • Proceeds from sale do not need to be returned to

Should You Apply for P2 Funding?
  • FY 2010 -- all funded
  • FY2011 down to 88
  • FY 2012 down to 90 (barely)
  • FY 2013 no P2 funding final decision unknown
  • Year 1 -- funded to 70
  • Year 2 all funded
  • Year 3 down to 82
  • Year 4 down to 87
  • Year 5 down to 81
  • Year 6 down to 70
  • Year 7 down to 81
  • Year 8 down to 80
  • Year 9 down to 86
  • Year 10 down to 81
  • Year 11 down to 87
  • FY 2009 down to 77

Will P2 Be Available in FY 2014?
  • Lets look at FY 2013
  • 2.38 billion available
  • Demand for Priority 1 (telecom and Internet) is
    2.709 billion
  • an increase of 10.8 from last year
  • FCC rolled over unused funds from prior years to
    be able to fund all eligible Priority 1 requests
  • Demand for Priority 2 (internal connections) at
    90 discount level is 1.76 billion
  • USAC board asked the FCC to deny at 80 and below
    but the FCC hasnt yet approved this
  • Unknown what will happen to P2 for FY 2013
  • If P1 grows again by 10, P1 demand will be
    almost 3 billion

Fixing the Funding Problem
  • FCC released E-rate NPRM in July 2013
  • Several issues raised
  • Move voice services to priority 2
  • Eliminate eligibility of certain services and
  • Move networking equipment to priority 1
  • Increase size of the fund
  • Allocate Priority 2 funding more predictably
  • Adjust discount matrix
  • See NPRM section in binder

Questions about Service Eligibility or Funding
Application Process Overview
Pay Full Invoices
USAC Pays Applicant
Receive Services
Pay Discounted Invoices
USAC Pays Vendor
Lets Begin...
Step 1 Technology Plan
  • ONLY required if applying for Priority 2 funding
  • Plan must include four SLD technology plan
  • Goals and Strategies for using technology
  • Needs Assessment
  • Professional Development
  • Evaluation
  • Must align with funding requests
  • Must be written before 470 is filed
  • Must cover full 12 months of upcoming funding
    year (include dates!)
  • 3 year maximum

Technology Plan Approvals
  • Must be approved by SLD Certified approver
  • Public schools PDE approves
  • PDE requires usage of Comprehensive Planning
    Process for tech plan approval
  • Submission by November 30 for plans expiring June
    30, 2013 or for CPP Phase 2 schools
  • Status of LEAs tech plans in binder
  • Nonpublic schools various entities approve
  • List in binder and on SLD website
  • CAIU will approve if no organization on the SLD
    list represents your entity
  • Libraries Approved by Commonwealth Libraries

Posting a Form 470...
Step 2 Posting the Form 470
  • Purpose of the Form 470
  • Opens the competitive bidding process
  • Identifies and describes types and quantities of
    services and equipment that you need
  • Be as detailed as possible
  • Notifies potential bidders that you are seeking
    proposals for the listed services/equipment
  • RFPs may be used to describe specific needs and
    circumstances, but arent required
  • What is considered an RFP?
  • Must be available when 470 is posted
  • Descriptions cannot be manufacturer-specific
  • Disqualification factors must be listed in Item
    13 or RFP

Step 2 Posting the Form 470
  • Filed by entity that will be negotiating with
  • File online at http//www.sl.universalservice.org/
  • All 470s posted on SLD web site for vendors to
  • Deadline Form 470 must be posted online at
    least 29 days before the Form 471 window close
    (example March 18 close Feb 18 deadline)
  • Dont wait this long
  • File 470 by Thanksgiving, if possible

When Must a Form 470 be Used?
  • Every year, unless a multi-year contract was
  • Must be posted before any contract is signed
  • Even if no competition in your area or if bidding
    under state law
  • Bidding via E-rate does not exempt you from
    bidding under state law, but can be done
  • Only exception for an applicant to NOT file a
    Form 470 is if another entity posted a 470 on
    their behalf
  • consortium application
  • May file single or multiple 470s, its up to you
  • Hint File all services under single 470

Important Reminder!
  • Be sure to tell everyone at your school or
    library involved with procurement that they cant
    sign contracts for E-rate eligible services
    without first posting a Form 470!

Competitive Bidding
  • After the Form 470 has been posted online,
    vendors submit proposals to the school or library
  • Proposals must be accepted for a minimum of 28
    calendar days, but applicants may accept
    proposals after this date
  • Vendors will contact you if they need additional
  • When contacted by a vendor, you must indicate
    your willingness to receive a proposal for
    services listed on Form 470
  • Do NOT say you are just going to stay with your
    current vendor

Competitive Bidding Rules
  • You are allowed to....
  • change your mind and not purchase a service that
    is listed on Form 470
  • have pre-Form 470 discussions with vendors as
    long as that doesnt lead to one bidder having
    inside information
  • attend product demonstrations
  • encourage and seek vendors to bid
  • do research to determine what cost-effective
    solutions are available
  • You are not allowed to...
  • Have a relationship with service providers that
    would unfairly influence the outcome of the
  • Furnish service providers with inside competitive
  • Provide information to only some bidders
  • Have ownership interest in a service providers
    company competing for services
  • Violate gifts rules

Competitive Bidding Rules
  • You are not required to...
  • meet with any vendor during or after the 470
    bidding period
  • respond to generic or spam e-mails such as
    I saw your 470, please call me to discuss your
  • respond to inquiries for services you did not
  • Lets discuss Form 470 Download/Vendor Spam

Service Providers Cannot...
  • Help prepare the Form 470
  • Help write or provide a RFP to applicant
  • Be a contact person on Form 470
  • Sign any applicant forms
  • Be involved with bid evaluation in any way
  • Provide funding for the applicant's non-discount
    portion or waive the applicant's non-discount
  • Coerce or pressure the applicant to use a
    specific service provider
  • Provide gifts to applicants that violate the gift

Service Providers Can...
  • Offer neutral technical assistance on development
    of technology plan
  • Cannot exert undue influence on applicant's
    ability to conduct a fair and open competitive
  • Answer general questions about the products and
    services they sell in response to applicant
  • Provide information to applicants to assist with
    responding to USAC questions regarding their
  • Provide assistance with service substitutions and
    other post-commitment activities

Gift Restrictions
  • All gifts from service providers to applicants
    are prohibited except for
  • (1) Modest refreshments that are not offered as
    part of meal (e.g., coffee and donuts provided at
    a meeting) and items with little intrinsic value
    intended for presentation (e.g., certificates and
    plaques) and
  • (2) Items that are worth 20 or less (e.g.,
    pencils, pens, hats, t-shirts, and other items
    worth less than 20, including meals), as long as
    those items do not exceed 50 per employee from
    any one source per funding year

Exceptions to Gift Restrictions
  • Exception for charitable contributions
  • Service providers can continue making charitable
    donations to E-rate eligible entities in the
    support of schools including, for example,
    literacy programs, scholarships, and capital
    improvements as long as such contributions are
    not directly or indirectly related to E-rate
    procurement activities or decisions
  • Exception for personal gifts
  • There is an exception for gifts to family and
    personal friends when those gifts are made using
    personal funds of the donor (without
    reimbursement from an employer) and are not
    related to a business transaction or business

Who is Subject toGift Restrictions?
  • Service providers
  • All service providers with current or possible
    future E-rate relationship to applicant
  • All individuals who are on the governing boards
    of such an entity (such as members of the board
    of directors) and
  • All employees, officers, representatives, agents,
    or independent contractors of such entities

Who is Subject toGift Restrictions?
  • Applicants
  • All individuals who are on the governing boards
    of such entities (such as members of a school
  • All employees, officers, representatives, agents,
    consultants or independent contractors of such
    entities involved on behalf of such school,
    library, or consortium with E-rate
  • Individuals whose work in any way relates to
    E-rate forms and technology plans
  • Individuals who prepare bids, communicate or work
    with E-rate service providers, E-rate
    consultants, or with USAC and
  • Any staff of such entities responsible for
    monitoring compliance with the E-rate Program

Other Gift Rule Details
  • Aggregate value of all gifts to an E-rate
    applicant, from any employee, officer,
    representative, agent, independent contractor, or
    director of the service provider, is considered
    when computing the 50 annual limit
  • Rules are always applicable, not just during the
    time period when the competitive bidding process
    is taking place
  • State and local restrictions regarding gifts also
    still apply
  • If more stringent than federal requirements,
    violation of state or local provision constitutes
    a violation of the FCC rule

Lets Look at the Form 470...
Get 470 Information Immediately!
  • Posted 470 available immediately on SLD web site
    to view
  • Online 470 shows
  • Posting date of application
  • Earliest date that your contract can be signed
    and thus 471 submitted
  • Date that certification page was received at the
  • SLD also sends this info in Receipt Notification

Questions about the Form 470, Competitive bidding
or gift rules Issues?
Step 3 Bid Evaluation
Step 3 Bid Evaluation
  • After 470 is posted for at least 28 days, billed
    entity must review all bids received for all
  • Keep documentation of criteria used to select
  • Keep all winning and losing bids
  • Keep bid evaluation matrix
  • Retain all correspondence between applicant and
    all vendors (winning and losing)
  • Price of eligible services/equipment MUST be the
    most heavily weighted factor during bid
  • Create Bid Evaluation Matrix

Bid Evaluation
  • Applicants can consider other criteria besides
    price in bid evaluation. Examples
  • History with vendor
  • Quality of proposed solution
  • Cost of ineligible items
  • New vendors cell phones
  • Cost to switch vendors
  • References
  • Cannot consider free services
  • Ill give you 5 free months of service if you
    sign a contract with me.

Bid Evaluation Matrix Example
What Should You Do IfYou Receive No Bids?
  • Document via an email or file memo that no bids
    were received
  • Existing Services can continue to receive
    services from existing service provider
  • New Services/Procurement Solicit bid from
    willing vendor (who is not your brother-in-law)
  • Make sure price is cost-effective
  • Check marketplace options from other vendors in
    your area or nearby areas
  • Save research and information to justify buying
    service from this vendor

Vendor Selection
  • Vendor selection must be done before you submit
    Form 471
  • Be careful not to make any decisions, sign
    anything or file any forms during 28-day waiting
  • Contracts must be signed and dated by applicant
  • Unless receiving services on month-to-month basis
  • Cannot select 2 vendors to provide the same
  • USAC believes there should always be one bidder
    that is more cost effective than any other

Vendor Selection
  • List extensions and expiration date in contract
    (cannot be open-ended)
  • For example, 3-year contract, with two 1-year
    renewals is ok and will not require new 470
    unless the end of 5 years
  • 3 year contract that automatically renews is not
    ok and will require new 470 at the end of 3 years
  • Include out-clauses if you cant pay without
  • Have contracts begin July 1 and end June 30, 20XX
    to coincide with E-rate funding year

Questions about Bid Evaluation or Vendor
Step 4 Filing the Form 471
Step 4 Filing the 471
  • Purpose of the Form 471
  • Formally requests E-rate funding commitments from
  • Shows discount calculations (Block 4)
  • Lists which 470 was used to bid services,
    provides contract signing dates, contract amounts
    (Block 5), and specifics of services
  • Filed by entity that actually pays the bills (the
    billed entity)
  • Can file a single 471 for all P1 requests
  • Multiple Priority 1 471s are ok
  • Priority 2 requests should be placed on a new
    471, one for each discount
  • Deadline Must be filed by close of 471 filing
    window (likely will be mid-March)
  • Do NOT miss this deadline!

What is My E-rate Discount?
  • Discount level for a school or library depends
  • 1) Percentage of students who are eligible for
    National School Lunch Program (NSLP) in
  • ? (for a school) the school
  • ? (for a library) the school district in which
    the library is located
  • Doesnt matter if school serves lunch or
    participates in NSLP
  • AVTS and nonpublic schools use their own
    students data, not sending schools data
  • October NSLP data on PA E-rate website by mid
  • 2) Urban or rural location of the school or
  • List in binder and on pa e-rate website under
    discount calculations

Discount Matrix for Single School
INCOME Measured by of students eligible for NSLP URBAN LOCATION Discount RURAL LOCATION Discount
If the of students in your school that qualifies for the NSLP... ...and you are in an URBAN area, your discount will be... ...and you are in a RURAL area, your discount will be...
Less than 1 20 25
1 to 19 40 50
20 to 34 50 60
35 to 49 60 70
50 to 74 80 80
75 to 100 90 90
Discount Calculations by Entity
  • Schools
  • Use straight matrix discount
  • Districts
  • Use weighted average of schools individual
  • Library
  • Take the total number of students eligible for
    NSLP in the school district in which the library
    is located, divided by the total number of
    students in that school district. Then use
    straight matrix discount
  • Library System
  • Use simple average of member libraries discounts
  • Consortium
  • Use simple average of members discounts

School Building Discounts
  • Individual School uses Discount from Matrix

School District Discounts
  • Weighted Average of Individual School Discounts
  • Note NIFs use the weighted average discount

Library Branches
Use discount information for school district in
which library is located
Consortium Discounts
  • Simple Average of All Entity Members

Alternative Measures to NSLP
  • Participation in these programs also qualifies
  • Medicaid
  • Food Stamps
  • Supplementary Security Income (based on income)
  • Federal public housing assistance (section 8)
  • Low Income Home Energy Assistance (LIHEAP)
  • Not acceptable - Title 1, feeder schools method,
    principals estimate

Alternative Measures to NSLP
  • Can conduct family survey even if your school
    participates in NSLP
  • Must survey all families in the school
  • Can do single school buildings
  • If 50 of surveys are returned, survey is
    considered valid and results may be extrapolated
    for entire school
  • NSLP application forms are not considered surveys
  • Keep careful documentation
  • Beneficial for both public and nonpublic schools
    seeking P2 funding
  • Dont let consultants talk you into conducting

IU Discount Calculations
  • Method of calculating discounts depends on what
    purpose the services are being used
  • School Use NSLP data of students attending
  • IU Admin Services Weighted average of discounts
    in all buildings within IU territory (act as
    large admin building)
  • Consortium Lead Simple average of consortium
    members discounts

Questions about Discount Calculations?
Funding Requests FRNs
  • Provide information related to your funding
    requests in Block 5 of Form 471
  • Vendor/SPIN
  • Category of Service
  • Form 470 Number
  • T/MTM or Contracted Service
  • Signing dates/expiration dates for contracted
  • Pre-discount amount must be based on bill,
    contract, quote, etc.
  • Which entities receiving service
  • Broadband speeds and of lines
  • All services listed on 471 must have been listed
    on a 470

Item 21 Attachments
  • Item 21 attachments provide descriptions of
    actual services
  • No space on actual Form 471, so Item 21
    attachments must be filed separately
  • Either online or on paper (online preferred)
  • Must have separate Item 21 attachment for each
    FRN (funding request/Block 5)
  • Details services/equipment with associated prices
    that add up to funding request
  • List of lines, speed, and description of
  • Are considered part of the Form 471 and must be
    filed by the Form 471 deadline
  • Usually a 2-week grace period after 471 deadline

Lets Look at the Form 471...
Must keep Form 471 Security Code in order to
access the Online Item 21 Attachment System
471 Receipt AcknowledgmentLetter (RAL)
  • SLD mails to applicants
  • Confirms receipt of Form 471
  • Verifies Block 5 information
  • Service provider receives similar letter when
    they are listed as SPIN on 471
  • Can use to make corrections for ministerial and
    clerical errors

Ministerial and Clerical Errors
  • The applicant can amend its forms to correct
    clerical and ministerial errors on their FCC
    Forms 470, FCC Form 471 applications, or
    associated documentation until an FCDL is issued.
    Such errors include only the kinds of errors that
    a typist might make when entering data from one
    list to another, such as mistyping a number,
    using the wrong name or phone number, failing to
    enter an item from the source list onto the
    application, or making an arithmetic error.(FCC

M/C Error Examples
  • Using wrong Form 470 number or wrong billed
    entity number
  • Using wrong name or service provider
    identification number (SPIN)
  • Using wrong expiration date for a contract
  • Requesting recurring service when the service is
    one time charge
  • Requesting one time service when the service is
  • Inaccurately reporting the prediscount amount on
    Block 5
  • Leaving off a building from Block 4
  • Referring to wrong Block 4 worksheet for a
    funding request
  • Listing wrong service category in Block 5
  • Simple math errors
  • Failing to enter an item from the source list
    (e.g., NSLP data, uploading Block 4 data, FRN,

Requesting a MC Correction
  • PIA will ask if this is a ministerial/clerical
  • Explain how the error occurred
  • Provide a reasonable explanation
  • Provide documentation that was in existence as of
    the date of submission of Form 470 or Form 471
  • Explain that the error occurred when consulting
    source list
  • PIA must approve the explanation before the
    change will be made

Examples of Source Documentation
  • Contract, Service Agreement
  • Vendor quote, bill, invoice, etc.
  • RFP, Newspaper listing
  • NSLP documentation or student enrollment data
  • Board Minutes, Resolutions
  • Budget
  • Any other documentation in existence as of date
    of submission of Form 470 or Form 471 to prove
    error was ministerial/clerical

Questions on Form 471, Item 21 Attachments, M/C
Step 5 Application Review
Step 5 PIA Review
  • Program Integrity Assurance (PIA) Review
  • Checks for rule compliance
  • eligible services
  • eligible entities
  • appropriate discount
  • Almost everyone receives a PIA contact
  • Applicants have 2-weeks to respond
  • If they are going to deny an FRN, they will tell
    you so and give you 1 more chance to submit new
  • Ask Julie if you are unsure of your answers
  • Check application status on SLD website
  • Under Form 471 Column of apply online page

Next SLD Mails FCDL
  • FCDL Funding Commitment Decision Letter
  • Tells you which funding requests (block 5s) of
    Form 471 are approved or denied
  • Provides information for the next form - Form 486
  • Can appeal if you dont agree with your decision
  • Must do so within 60 days
  • Appeal to SLD if they made an error
  • Can then appeal to the FCC if USAC denies
  • Apple to FCC for waivers and policy issues
  • Always appeal!

Step 6 Filing the Form 486
Step 6 Filing the Form 486
  • Purpose of Form
  • Signifies that its OK for SLD to pay any
    invoices for that FRN
  • Lists who approved tech plan
  • Certifies CIPA compliance
  • Deadline Must be postmarked no later than
  • 120 calendar days after the Service Start Date
    featured on the Form 486 or
  • 120 calendar days after the date of the Funding
    Commitment Decision Letter
  • whichever is later.
  • Submit online using info from FCDL
  • Use 07/01/2014 as service start date for FY 2014
    (Year 17)
  • USAC then mails Form 486 Approval Letter to
    vendor and applicant

CIPA Original Requirements
  • Any school or library receiving either Internal
    connections or Internet access must...
  • Filter all Internet access
  • Have an Internet Safety Policy that addresses
    required elements
  • Policy must have been adopted after public
  • Recipients only receiving telecommunications
    services are exempt from E-rate CIPA compliance
  • Consortium members submit Form 479 to consortium
    leader certifying compliance in order for
    consortium lead to submit Form 486

New CIPA Requirements
  • Effective 7/1/2012
  • Schools (not libraries) Internet Safety Policies
    must 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."
  • This means that schools are required to teach
    online safety to students as a prerequisite to
    receiving E-rate funding
  • Local boards determine delivery of online
    safety/cyberbullying education
  • Cant be once every 3 years
  • Establish policy, follow policy and document

CIPA Documentation
  • Notice of public hearing or public meeting (such
    as school board meeting) where CIPA policy was
  • Agenda for meeting show opportunity for public
    input/comment before adoption of CIPA policy
  • Other documentation for opportunity for public
  • Filtering records, purchase order
  • Documentation of cyberbullying/appropriate online
    behavior education for all minors

Common Filtering Questions
  • Are we required to filter personal devices
    brought to school that use their own 3G/4G
  • Are we required to filter school devices used
  • The FCC considers both of these open questions
    at the current time.
  • We expect definitive answers in the E-rate 2.0
    reform proceeding
  • Regardless of whether CIPA applies, schools may
    want to have restrictions in their policies to
    ensure proper usage

Lets Look at the Form 486...
Questions on PIA Review, FCDLs, Form 486, CIPA?
Step 7 Getting Paid!
How and When Do You Actually Receive E-rate
  • Applicant has a choice
  • Discounts on bills (vendor invoices USAC)
  • or
  • Reimbursement process (applicant pays bills in
    full, then invoices USAC)
  • Must select one or the other for entire year
  • If you want discounted bills, call provider and
    file Form 486 as soon as you are funded
  • Vendors sometimes have additional forms to
    complete to proceed with discounted bills

Discounted Billing Method
  • Discounts appear on applicants bill
  • Service provider submits Form 474 to USAC after
    providing discounted bill
  • the Service Provider Invoice Form (SPIF)
  • Providers usually get reimbursed by USAC within
    30 days from date of submission
  • Applicants do nothing except make sure they are
    receiving the discounts they deserve on bills
  • Do the math!

Reimbursement Method - BEAR
  • Applicant pays bill in full
  • Applicant submits Form 472 BEAR Form for
  • Quarterly, semi-annually, or at end of year
  • Complete one BEAR for each SPIN
  • Calculated based on eligible charges on actual
  • Not AP register or amount committed
  • Subtract ineligible charges
  • Deadline
  • October 28 (following close of funding year) for
    recurring services
  • January 28 for non-recurring services/equipment
  • Can request extension if good cause exists

Reimbursement Method - BEAR
  • SLD approves BEAR and sends approval letter to
    vendor and copy of letter to applicant
  • SLD then sends check to vendor
  • Vendor must send check to applicant within 20
    business days of date on BEAR approval letter
  • Call SLD if you dont get a check in a timely
    manner after receiving approval letter

Online and Paper BEARs
  • Online (preferred)
  • Applicant and Vendor must have PINs to file
    online BEARs
  • Applicant completes BEAR Online
  • BEAR is electronically sent to vendor
  • Vendor certifies or denies
  • If approved, applicant receives e-mail and BEAR
    is automatically sent to USAC for payment
  • If denied, applicant receives e-mail and must
    refile the BEAR from scratch
  • Paper
  • Applicant completes pages 1 4 and faxes to
  • Vendor signs page 4 and returns to applicant
  • Applicant mails pages 1-4 to USAC
  • New Applicant must include check remittance
    information on page 4

Ineligible Charges on Bills
  • When determining the amount to list on a BEAR,
    create a quick spreadsheet showing each months
    total charges, and total ineligible charges
  • What are the ineligible charges?
  • Varies by vendor, but these are known to be
  • Universal Service Administrative Fee
  • USF fees themselves ARE eligible
  • Late payment or finance charges
  • USF Cost Recovery Fees, Property Tax Fees
  • Paper statement fees
  • Equipment charges (on P1 bills)
  • Directory listing fees, non-published phone
    number fees
  • Payphone service
  • Heres an example of what your spreadsheet may
    look like

Verizon Account 215-235-1232 Ineligible Directory Listing Fee Total Eligible Charges
July 200.10 2.75 197.35
Aug 200.20 2.75 197.45
Sept 200.30 2.75 197.55
Oct 200.20 2.75 197.45
Nov 201.30 2.75 198.55
Dec 203.30 2.75 200.55
Jan 202.20 2.75 199.45
Feb 201.30 2.75 198.55
Mar 200.30 2.75 197.55
Apr 203.20 2.75 200.45
May 200.10 2.75 197.35
June 203.50 2.75 200.75
 Total Charges 2,416.00 33.00 2,383.00
Ineligible Charges 33.00    
Eligible Charges 2,383.00    
E-rate Discount 65    
E-rate Reimb. 1,548.95    
Lets Look at the Form 472 BEAR
Quarterly Disbursement Reports
  • Sent only to applicants
  • Authorized person
  • Billed Entity (BEN) address
  • Contains all invoice (Form 472 and Form 474)
    payment authorization amounts for the Billed
    Entity approved during that quarter for all
    funding years
  • Review to ensure you agree with disbursements

Optional Form 500
  • File Form 500 to either
  • Change a service start date or a contract
    expiration date
  • Cancel or reduce a funding commitment
  • Notify USAC of equipment transfer (new)
  • Request service delivery deadline extension (new)
  • Warning reductions or cancellations of funding
    commitments are irreversible
  • Not required, but strongly suggested to file Form
    500 if FRN not needed, or large amount of
    commitment is not used

Questions on Form 472 Reimbursements, Discounted
Billing, Form 500?
FY 2014 (Year 17) Coming Soon!
  • FY 2014 is BLUE!
  • For services rendered 7/1/2014 - 6/30/2015
  • 471 application window slated to
  • OPEN early January 2014
  • CLOSE mid March 2014
  • Form 470s being accepted now!

FY 2013 (Year 16) Details
  • For services rendered 7/1/2013 - 6/30/2014
  • FY 2013 is PINK
  • 53 of PA Priority 1 FRNs funded as of 10/10/2013
  • USAC very behind other years
  • File the 486 after FCDL arrives
  • Request discounted bills from vendors, if desired
  • Watch PA E-rate Listserve closely
  • Is your Form 486 due? Check the list!

FY 2012 (Year 15) Not Over Yet!
  • Funding Year ended June 30, 2012 for recurring
  • FY 2012 was YELLOW
  • Deadline for submitting BEARs (Form 472s) is
    October 28, 2013 (extensions granted through Oct.
    28, 2014)
  • Deadline for submitting invoices for
    non-recurring services is January 28, 2014
    (extensions granted through Jan. 28, 2015)
  • Do you have funding remaining? Check the list!
  • File for extension if you havent submitted your

Questions about Funding Years and Whats Due When?
But wait!Theres more!
Changing Service Providers
  • Two types of SPIN changes
  • Corrective Mostly for data-entry errors
  • Can be done pre-and post-commitment
  • Operational When actually switching vendors
  • Can only be done post commitment and for
    legitimate reason
  • Can request to split an FRN
  • Allocate to 2 providers in same funding year
  • Dont forget to file 486 for new FRN

Allowable SPIN Changes
  • Can no longer switch vendors because of lower
  • Some vendors were abusing lax SPIN change rules
    and not bothering to participate in 470 bidding
  • Legitimate reasons include
  • Breach of contract
  • Service provider is unable to perform
  • Bankruptcy
  • Delayed provision of new service
  • Must select vendor that received the next highest
    point value in the original bid evaluation,
    assuming there was more than one bidder
  • USAC will require you to submit bid evaluation as

  • E-rate PINs can be used to file E-rate forms
  • PIN assigned to a person and is specific to that
    entity while employed at that entity
  • Not given to an entity
  • No way to request a PIN
  • Must sign a paper certification of a 470, 471 or
  • SLD will mail them a PIN in a small white mailer
  • Can still submit these forms online, but cert
    page must be signed and mailed to USAC
  • PIN then may be used to 470, 471, 486, and BEAR
  • HINT Dont make the BEAR Form the first one you
    sign as USAC will issue a BEAR-only PIN

Paying Your Share
  • Applicants are required to pay non-discounted
    portion of cost
  • Cannot be waived by the vendor
  • Vendor cannot provide a grant
  • Funding must be in budget or draft budget
  • Must keep all invoices and copies of cancelled
    checks for 5 years after last day to receive

Service Substitutions
  • SS required when a change is made to any service
    on your approved 471, Item 21 attachments
  • After FCDL issued
  • Applicant must seek SLD approval which meets
    certain conditions
  • Good idea to seek approval PRIOR to doing
    substitution in case its not approved by SLD.

Can You Request Extensions?
  • Depends on the form and requirement
  • Form 470 no
  • Form 471 no
  • Form 486 no
  • but they will send a reminder letter and you can
    then file if you missed the original deadline
  • Form 472 BEAR yes
  • Service delivery recurring services no
  • Services must be delivered between July 1 June
  • Service delivery non-recurring services yes
  • Installations and equipment purchases have until
    Sept 30
  • If applicant needs more time, they must request
    extension prior to Sept 30
  • PIA inquiries conditional

Letters of Agency
  • Consortium
  • Name of consortium leader, consortium member
    name, type of service, signature, date and title
    of people signing document
  • Sample LOA available on SLD website
  • Must be signed/dated before filing of Form 471
  • Consultant
  • Must be signed by applicant before the consultant
    does ANY work on behalf of the applicant

Data Retrieval Tool
  • Most data on SLD website, using DRT
  • Download by state, by SPIN, by entity, etc
  • Updated nightly
  • Shows
  • Entity info / 471 / FRN / 470 / SPIN
  • Whether FRN funded
  • Whether 486 was submitted
  • Last date to invoice
  • Original requested amount committed amount
  • Discount
  • Invoice paid and by what mode
  • etc.
  • E-rate Central Database Tool

Community Use of Services
  • Schools may now permit general public to use the
    schools Internet access during non-operating
    hours at the school
  • Usage is permitted only during a schools
    non-operating hours or summer 
  • School may not request E-rate funding for a
    higher level of service than would be required
    for educational purposes
  • Schools may not charge for the use of the
    Internet access, but may charge reasonable fees
    to cover overhead costs from individuals that use
    the schools' services and facilities
  • Organizations using a schools' services are
    permitted to recover related costs (e.g.,
    curriculum development and presentation costs)
    from attendees

Community Use of Services
  • School not required to open facilities
  • Internet filtering rules must remain intact
    during use
  • Rule in no way permits schools to share their
    bandwidth with other ineligible entities, such as
    an off-site after-school program at the YMCA or
    community center
  • Also does not permit partially eligible entities,
    such as a Diocesan office that provides services
    to both schools and the church, to stop cost
    allocating the ineligible portion of Internet
    used during school hours

What Should Always Be On Your Mind?
Audits and Document Retention
  • Rules require applicants to retain ALL E-rate and
    related documents for 5 years from last day of
    service in a particular funding year
  • If auditor visits in 4 years, and documents are
    missing, it could be the basis to recover all
    funding from that funding year
  • Document and keep everything remotely related to
  • Like what?

Documents to Retain
  • Tech plan and approval letter
  • Consultant agreements
  • RFP and proof of publication date
  • All vendor correspondence
  • Winning and losing bids
  • Professional development records
  • Bid evaluation documentation
  • Proof of authorization to sign E-rate forms
  • Filtering records and payments
  • NSLP forms
  • AUP and proof of public meeting
  • Proof of online safety training
  • Signed contracts
  • NSLP documentation
  • Budgets
  • Purchase orders
  • Packing slips
  • Asset or inventory records
  • Installation records
  • All Invoices
  • Front and back of checks as proof of payment to
    vendor (non-discounted share)
  • Proof of receipt of payment from vendor (BEAR

E-rate Help
  • SLD
  • Client Service Bureau (CSB)
  • E-rate Help Desk where applicant service
    providers can get answers to questions
  • Accessed via 888-203-8100
  • Submit a Question on SLD website
  • PA E-rate Coordinator
  • E-mail jtschell_at_comcast.net
  • www.e-ratepa.org

  • The end!
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