E-Rate for California Beginner Applicants

JACK O’CONNELLState Superintendent of Public Instruction

E-Rate for CaliforniaE-Rate for CaliforniaBeginner Applicants


E-Rate AcronymsE-Rate Acronyms

BEN – Billed Entity NumberCIPA – Children's Internet Protection ActFCDL – Funding Commitment Decision Letter FRN – Funding Request NumberSPIN – Service Provider Identification NumberSSD – Service Start DateRAL – Receipt Acknowledgement Letter (Form 471)RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch ProgramNIF – Non-Instructional FacilityPIA – Program Integrity AssuranceUSAC Link:

http://www.usac.org/sl/tools/reference-area.aspx

BEN – Billed Entity NumberCIPA – Children's Internet Protection ActFCDL – Funding Commitment Decision Letter FRN – Funding Request NumberSPIN – Service Provider Identification NumberSSD – Service Start DateRAL – Receipt Acknowledgement Letter (Form 471)RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch ProgramNIF – Non-Instructional FacilityPIA – Program Integrity AssuranceUSAC Link:


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E-Rate OrganizationE-Rate Organization

• 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 the E-rate program along with three other programs

• Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-rate

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E-Rate RulesE-Rate Rules

•The FCC sets rules and policies through orders– Policies are defined in the text of orders

•USAC/SLD develops procedures for specific actions, such as how to process applications

– USAC submits its procedures to the FCC for approval each year

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E-Rate BudgetE-Rate Budget

•Commitments are capped at $2.25 billion for each funding year

•This cap will be adjusted for inflation starting in FY2010

•Once each year, FCC can roll over unused funds from previous funding years into the current funding year

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California Department of Education (CDE)California Department of Education (CDE)& State Library & State Library Do NotDo Not Administer Administer

the Federal E-Rate program.the Federal E-Rate program.CDE & State Library have no statutory authority to administer the federal E-Rate program

CDE & State Library only provide general information about the E-Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources

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Eligibility - SchoolsEligibility - Schools• Schools must provide elementary or secondary

education as determined under state law. • Schools may be public or private institutional

day or residential schools, or public charter schools.

• Schools must operate as non-profit businesses. • Schools cannot have an endowment exceeding

$50 million.

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Pre-K and Adult EdPre-K and Adult Ed

• State law, in conjunction with E-Rate rules, determines eligibility of Pre-K (Head Start), Adult Ed and Juvenile Justice

• Reference the following for California eligibility: http://www.usac.org/sl/applicants/step01/non-traditional-k-12/k-12-eligibility-table.aspx

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http://www.usac.org/sl/applicants/step01/non-traditional-k-12/k-12-eligibility-table.aspx




Eligibility – LibrariesEligibility – Libraries• Libraries must be eligible for assistance

from the California state library administrative agency under the LSTA (Library Services & Technology Act)

• Libraries must have budgets completely separate from any schools (including, but not limited to, elementary and secondary schools, colleges and universities).

• Libraries cannot operate as for-profit businesses.

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E-Rate Identification E-Rate Identification NumbersNumbers

• Billed Entity Number – BEN: organization that pays the bills

– http://www.sl.universalservice.org/Utilities/BilledEntitySearch_Public.asp

• Entity Number: schools and other locations receiving service

• Service Provider Identification Number - SPIN

– http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp

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http://www.sl.universalservice.org/Utilities/BilledEntitySearch_Public.asp

http://www.sl.universalservice.org/Utilities/BilledEntitySearch_Public.asp

http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp




Types of Applicants/Billed Types of Applicants/Billed EntitiesEntities

USAC identifies the following eligible entities/types of applicants:

•Individual school

•School district or school system

•Library

•Consortium

•Statewide application

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Recipients of ServiceRecipients of ServiceStarting with FY 2011, applicants must designate the following recipients of service on forms

Public School Private School

Charter School Tribal School

Head Start State Agency

Library

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Recipients of Service, contRecipients of Service, contForm 471 will also ask for further designation of the following entities:

Pre-kindergarten Head Start

Adult Education Dormitory

Juvenile Justice

Educational Service Agency (i.e. COEs)

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Non-Instructional Facilities Non-Instructional Facilities (NIFs)(NIFs)

ExamplesSCHOOLS: LIBRARIES:• Administrative

buildings• Administrative

buildings

• School bus barns and garages

• Cafeteria offices• Facilities

associated with athletic activities

• Bookmobile garages• Interlibrary loan

facilities• Library technology

centers

• Cafeteria offices14


Educational PurposeEducational Purpose• 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 educational purposes.

• http://www.sl.universalservice.org/reference/educational_purposes.asp

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http://www.sl.universalservice.org/reference/educational_purposes.asp

http://www.sl.universalservice.org/reference/educational_purposes.asp


Eligible Services – Eligible Services – Basic ConceptsBasic Concepts

Priority 1 (P1)• Telecommunications• Internet Access

Priority 2 (P2)• Internal Connections• Basic Maintenance on Eligible

Internal Connections• Note: End-user devices and content generally not

eligible– PCs/PDAs -Printers -Television– Laptops -Phones -VCRs

Key reference: Eligible Services List (updated annually) – http://www.usac.org/sl/tools/eligible-services-list.aspx

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http://www.usac.org/sl/tools/eligible-services-list.aspx


E-Rate CycleE-Rate Cycle

• Funding Year is July 1 – June 30

• Funding commitments are made by funding year (services starting on or after July 1 and ending on or before the following June 30)

• The Window

– Form 471 application window –Opens mid to late fall and closes February

– This year Funding Cycle July 1, 2011 to June 30, 2012 (AKA Funding Year 14 or FY 2011)

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E-Rate ProcessE-Rate Process1. CIPA Compliance2. E-rate Technology Planning – What are my

goals?3. Form 470 – Start Application Process 4. Competitive Bidding & Selecting your

vendors5. Form 471 – Request for Funding 6. PIA (Program Integrity Assurance) Review 7. Funding Commitment8. Form 486 Receipt of Services Confirmation9. Form 472 – BEAR and Form 474 – SPI –

Invoicing “Getting the Money” 10. Other Forms as needed

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E-Rate Timeline: July 1st – June 30thE-Rate Timeline: July 1st – June 30th

*These dates are estimates. In order to derive the Form 470 deadline, applicants must count backwards from the Form 471 deadline.**FCC announces Form 471 filing deadlines each Fall.

JACK O’CONNELLState Superintendent of Public Instruction 1. Childrens Internet 1. Childrens Internet

Protection Act (CIPA) and Protection Act (CIPA) and Protecting Children in the Protecting Children in the

2121stst Century Acts Century Acts

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CIPACIPA ComplianceCompliance• Public Notice & Public Hearing• Technology Protection Measure (Filter)• Internet Safety Policy (required elements)

– Access by minors to inappropriate matter on the Internet – Safety & security of minors when using electronic mail, chat

rooms, and other forms of direct electronic communications – Unauthorized access including "hacking“ & other unlawful

activities by minors online – Unauthorized disclosure, use, & dissemination of personal

information regarding minors – Measures designed to restrict minors' access to materials

harmful to minors

• CIPA affects every funding year from FY2001 going forward, so you must maintain proof of CIPA compliance on an ongoing basis

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Protecting Children in the 21Protecting Children in the 21stst Century ActCentury Act

• Enacted in Fall 2008 to address Internet Safety in schools, specifically cyberbullying awareness and response

• Before USAC can enforce new requirements the following must occur:– FCC will issue a Notice of Proposed

Rulemaking (NPRM) seeking comment on the Act

– FCC will draft new rules and the new rules must be voted by the FCC Commissioners

– FCC will release guidance to USAC in an Order

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2. E-Rate Technology 2. E-Rate Technology PlanningPlanning

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Recent Changes to E-rate Recent Changes to E-rate Technology Plan RequirementsTechnology Plan Requirements

• Beginning in FY2011, Tech plans are required for Priority 2 services ONLY (internal connections and basic maintenance of internal connections)

• The budget requirement for the Tech plans has been eliminated

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Technology Plan OverviewTechnology Plan Overview1. Tech Plan must be “written” prior to

posting Form 470 for priority 2 services.

2. DOCUMENT the existence of this “Written Plan” – i.e., Letter/E-mail from Cabinet, screen print of file name and date, and physical copy of plan.

3. FFC rules require an “approved” technology plan when receiving E-rate discounts for priority 2 services (internal connections: switches, routers, cabling and basic maintenance)

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Technology Plan OverviewTechnology Plan Overview1. Find your public charter, district or COE Tech Plan status at: http://

www.cde.ca.gov/ls/et/rs/techplan.asp

2. *Decision: Decide which tech plan to use: A) E-rate only, B) EETT technology plan (best practice approach because it also qualifies applicant for K12 Microsoft voucher funding) Note: Libraries leverage your master plan in developing your technology plan.

3. Service Providers and vendors are NOT allowed to assist in the technology planning process.

4. Must cover all 12 months of the funding year (July 1 – June 30).

5. E-rate only plans should not cover more than 3 years; EETT tech plans that meet E-rate requirements can cover 5 years with progress review during 3rd year.

6. Must be approved by a “Certified Technology Plan Approver” See the Technology Plan approver locator tool on the USAC website: http://www.sl.universalservice.org/reference/tech/default.asp

7. Use the technology plan builder and the expertise of your CTAP regional assistance: http://myctap.org/index.php/techplan/tpb

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http://www.cde.ca.gov/ls/et/rs/techplan.asp

http://www.cde.ca.gov/ls/et/rs/techplan.asp

http://www.sl.universalservice.org/reference/tech/default.asp

http://www.sl.universalservice.org/reference/tech/default.asp

http://myctap.org/index.php/techplan/tpb

http://myctap.org/index.php/techplan/tpb


44 Required Elements of a Required Elements of a Technology Plan Used for Technology Plan Used for

E-rateE-rate1. Clear statement of goals and realistic strategy for using

telecommunications and information technology to improve education or library services.

2. Professional Development strategy to ensure staff understands how to use technologies to improve education or library services

3. Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services

4. Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise.

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The “Two Tech Plans”The “Two Tech Plans”E-Rate Only Plan:

1. Goals2. Professional

Development3. Needs Assessment4. Evaluation Process

• Tech Plan Helpwww.usac.org/sl/applicants/step02/

Enhancing Education Through Technology (EETT):

• Executive Summary/Introduction

• Stakeholders• Curriculum • Professional Development • Infrastructure• Adult literacy • Research • Funding and Budget• Monitoring and Evaluation

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http://www.usac.org/sl/applicants/step02/




EETT Tech Plan Cycle EETT Tech Plan Cycle Dates:Dates:

The final dates to submit your EETT Tech Plan for approval are:

1. Cycle A: September 17, 2010

2. Cycle B: November 19, 2010

3. Cycle C: March 11, 2011

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Technology Plan “Must Technology Plan “Must Do” Reminders:Do” Reminders:

1. Must be “Written” prior to posting Form 470 for priority 2 services:– It must be documented that it is written before the posting of the form 470!

(Applicant must document the existence of this plan, i.e., e-mail with plan attached, memo from cabinet level about the plan being written, including the date. “DATE STAMP,” submit EETT tech plans during cycle A [final date November 19, 2010])

2. Must include a sufficient level of detail and cover all priority 2 services for which E-Rate discounts are being sought on the Form 470(s) and subsequent Form 471(s).

3. Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier for priority 2 services

4. E-rate only plans must be approved by a “USAC Certified Technology Plan Approver” see USAC link: http://www.usac.org/sl/tools/reference/tech/default.asp

5. Combination E-rate/EETT Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

6. Must include all four required elements regardless of the type of plan being used (E-rate only or EETT)

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Technology Plan HelpTechnology Plan Help• E-rate Plans: John Vardanega, [email protected],

916-323-2241

• EETT Plans: Doris Stephen, [email protected]

• CTAP:http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

• CTAP Tech Plan Builder: http://myctap.org/index.php/techplan/tpb

• Libraries: Rushton Brandis, [email protected] , 916-653-5471

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E-Rate Discount CalculationsE-Rate Discount Calculations

Calculated based on two factors:1. Percentage of students eligible for free and

reduced lunch under the National School Lunch Program (NSLP): http://www.usac.org/sl/applicants/step05/discount-matrix.aspx or an alternate method: http://www.universalservice.org/sl/applicants/step05/alternative-discount-mechanisms.aspx

2. Urban or Rural status (Matrix) http://www.usac.org/sl/applicants/step05/discount-matrix.aspx.

- To verify your Urban or Rural Status status:http://www.usac.org/sl/applicants/step05/urban-rural/

- Census Tract Look-up Toolhttp://www.ffiec.gov/Geocode/default.aspx

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Discount CalculationsDiscount Calculations

• Instructional Facilities (i.e. schools) have a discount that comes from the NSLP free and reduced lunch data and the Urban/Rural Matrix

• Non-Instructional Facilities and libraries will use a weighted average of all schools in the system (i.e. district)

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Urban/Rural Discount Matrix% Eligible Students

for NSLP Urban Rural

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%

E-Rate Discount MatrixE-Rate Discount Matrix

(i.e. individual school calculations)(i.e. individual school calculations)

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DistrictStudents Enrolled

# Free and Reduced Lunches

% Free and Reduced Lunches

% E-Rate

Subsidy

Weighted Average

for District

Sample School District

Sample School 1 19 14 73.68% 80% 15.2

Sample School 2 836 323 38.64% 60% 501.6

Sample School 3 188 54 28.72% 50% 94

Sample School 4 121 65 53.72% 80% 96.8

Sample School 5 158 36 22.78% 50% 79

Sample School 6 1050 204 19.43% 40% 420

TOTALS FOR DISTRICT 2372 696 1206.6

WEIGHTED AVERAGE 50.87%

Calculating a Weighted Average Calculating a Weighted Average for for District or Library SystemDistrict or Library System

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Free and Reduced Lunch Eligibility Free and Reduced Lunch Eligibility under (NSLP)under (NSLP)

• NSLP data is reported to CDE in October of each year. (This Con App (as shown on page 46) data is finalized/posted by CDE in the following Spring) http://www.cde.ca.gov/ds/sh/cw/filesafdc.asp

• This posted NSLP data comes from the Claim Reimbursement Form from Food Services Manager for month of October (online referred to as CNPS – Child Nutrition Information and Payment System)

• Program Integrity Assurance (PIA) looks at the NSLP data that is provided by CDE - so to avoid PIA discount issues use your latest Con App data on Form 471

• Keep all establishing NSLP data used on Form 471 in your records for future USAC Inquiries

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Con App ExampleCon App Example(Consolidated Application)(Consolidated Application)

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OR

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County District Code School Code Sub Code

1. Name Of Participant

Address

City

Zip Code

ZIP CODE

2. Month/Year STATE USE ONLY

/

3. a. Original Claim

b. Adjusted Claim

4 . A D JU S T M E N T C O D E 5. REASON CODE 6. Number Of Children Approved To Receive Free Meals Or Milk

7. Number Of Children Approved To Receive Reduced Price Meals

8. Number Of ½ Pints Of Fluid Milk Purchased This Month

9. Total Cost Of Fluid Milk Purchased This Month

PART I – MONTHLY REPORT MEAL SUPPLEMENT ELIGIBILITY DATA

Report items 12 through 16a monthly.

10. Number Of Children Approved For Free Meal Supplements

11. Number Of Children Approved For Reduced Price Meal Supplements

A. Authorized Sites Participating

B. Enrollment C. Number Of Operating Days

D. Paid Meals Or Special Milk

Served

E. Free Meals Or Special Milk Served

F. Reduced Price Meals Served

G. Total Meals Or Special Milk Served

12. National School Lunch (Program A)

13. Basic School Breakfast (Program B)

14. Especially Needy School Breakfast (Program C)

15. Special Milk (Program D) 16. Meal Supplements (Snacks) (Program E)

INCLUDE AREA ELIGIBLE COUNTS 16a. Area Eligible Meal Supplements (For Information Only)

PART II – REVENUE Report items 17 through 26 annually. Participants in School Lunch, Basic Breakfast, Especially Needy Breakfast, and/or Meal Supplement Programs must report annual revenue and costs on the June claim. All monetary figures entered on this claim must be rounded to the nearest whole dollar. Please refer to the claim instruction booklet for more detailed information. Yearly cost and revenue totals for the Summer Seamless Feeding Waiver sites must be included in the totals.

H. Daily Sales (Actual Receipts)

I. Federal Reimbursement

J. State Reimbursement

K. Needy Meal Tax/ Rev. Add-On

L. Other M. Total (Columns H Through L)

17. National School Lunch (Program A)

18. Basic School Breakfast (Program B) 19. Especially Needy School Breakfast (Program C) 20. Meal Supplements (Program E) 21. Miscellaneous Food Service 22. TOTAL (Lines 17 through 21)

PART III – COST INCURRED 23. Food

24. Labor

25. Other

26. Total Costs

Name Of Person Preparing Claim

Telephone Number Ext # ( )

E-mail Address

CERTIFICATION: I certify to the best of my knowledge this claim is true and correct in all aspects, that the records are available to support this claim, that this claim is in accordance with the terms of existing School Nutrition Program agreement(s), and that I have not received payment for this claim.

Original Signature Of Authorized Official Title Of Authorized Official

Date

All claims must be submitted with a copy.

Claim for Reimbursement School Nutrition Programs CNFS 71-5 (06/05) Return To: California Department Of Education Child Nutrition Fiscal Services 1430 N Street, Suite 2213 Sacramento, Ca 95814

Note: Please submit by the claim submission target date of the 10th of the month following the month claimed. All claims must be postmarked by the 20th day of the second month following the month claimed to be considered for payment.

California Department Of Education Fiscal And Administrative Services Division

If label is not available, type or print agreement number (county, district, school, and sub codes), name, and address in the space provided.

STATE USE ONLY

Refer to the claim instruction booklet for detailed instructions.

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CNIPCNIP SNP Sponsor Claim For ReimbursementSNP Sponsor Claim For Reimbursement

40


Claim for Reimbursement Claim for Reimbursement Reconciliation DetailsReconciliation Details

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2. Form 470: Starting the 2. Form 470: Starting the Application ProcessApplication Process

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Prepare For The E-Rate CyclePrepare For The E-Rate Cycle

• Technology Plan MUST be Written for Priority 2 services

• Review existing network structure, both telecommunications and data

• Expected growth in telecommunication and hardware needs

• Preparing for the Bidding/Procurement Process • Number of classrooms and computers with

phone/internet access• NSLP data for discount percentage• Ensure (CIPA) Compliance, implementation and

board approval.43


Manage the Cycle - Manage the Cycle - TeamworkTeamwork

• Authorized signer (Legally Authorized Signer)

• Designated contact person (Will receive E-rate calls, e-mail, faxes)

• Organize paper trail

– Written Technology Plan for Priority 2 services

– Assessment of existing Contracts, with signatures and dates (expiring contracts, etc)

– Prior year’s submitted applications

– Correspondence from SLD, Service Providers, etc.

– All bids received and evaluation documents

– Calendar of Deadlines

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Form 470 – Form 470 – Contract IssuesContract Issues

• Block 2, Item 7

• Know what type of contract/service you are seeking bids for

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Form 470Form 470• Block 2, Items 8 – 9

• Block 2, Item 1 MUST be filled out regardless of an available RFP

• If no RFP, must provide sufficient detail of services. Do not use laundry list. Must be specific.

46


Form 470 Block 3• Technology Resources

– Not eligible for discount but required in order to receive E-Rate funding

47


Form 470 Block 4• Recipients of services

– Number listed should be sufficient to include all possible entities.

– Including Non-Instructional Facilities

• Do you anticipate growth?

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Form 470 Block 5• Certification and Signatures

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Submit and Certify Submit and Certify Form 470Form 470

• Once the Form 470 is submitted you must

1.Certify online using a PIN, or

2.Print the certification page, sign and mail this form ASAP-- “certified mail”

• Print the Form 470 for your records, and note the Allowable Contract Date (ACD)

– Also provided in the Receipt Acknowledgement Letter (RAL)

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Form 470 RemindersForm 470 Reminders• Allow adequate time for the following to be

completed:– Do your Form 470 NOW – Do not wait– Competitive Bidding – minimum of 28 days before

selecting service provider and contract signing– Local Procurement– Board Approval– Signing Contracts

• Understand– Your existing services and contracts– Products and services you will need in the coming

year– Eligible entities receiving services

• Identify E-rate category for each product and service, P1 or P2 51


Form 470 RemindersForm 470 RemindersFrom SLD’s Tip SheetsFrom SLD’s Tip Sheets

• DO list your requested services on your Form 470 — and your RFP if you have one.

• DO give adequate description of services requested. DON’T give a laundry list.

• DO list your requested services in the correct categories of service (Telecommunications, Internet Access, Internal Connections, or Basic Maintenance of Internal Connections).

• DO mark the correct boxes in Block 2 for multi-year contracts and/or voluntary extensions.

• DO certify your Form 470 prior to the close of the Form 471 application window.

• DON’T allow a service provider that may bid on your services to fill out your Form 470.

• DON’T wait until the Form 471 window opens to file your Form 470.

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Receipt Notification Letter Receipt Notification Letter (RNL)(RNL)

• An opportunity to review application and correct minor errors (contact name, number of eligible entities, billed entity number)

– Review immediately to determine if you need to file a new Form 470

53


3 & 4. Competitive 3 & 4. Competitive Bidding/ProcurementBidding/Procurement

54


Cornerstone of E-RateCornerstone of E-Rate• All expiring and new contracts must be

competitively bid/procured to receive E-rate funding

• Posting of the Form 470/RFP (whichever is later) starts the procurement process with a minimum of 28 days to receive proposals

• Must respond to ALL vendors– If you choose not to, you MUST have

a good reason, i.e., Spam

55


Competitive Procurement Competitive Procurement and Program Complianceand Program Compliance

– Keep copies of all bids/proposals, winning and losing

– Keep documentation on the award process and bid/proposal evaluation criteria for your award

• Keep all correspondence related to the procurement process

• Evaluation Criteria needs to be established BEFORE you release the RFP/Form 470

– Complete copies of all related contracts

FOLLOW LOCAL/STATE PROCUREMENT POLICIES- This is a critical element in audits

http://www.sl.universalservice.org/reference/BestPractices.asp56


Program ComplianceProgram Compliance• Best Practice: Use standard evaluation

process for all bids/proposals. Keep evaluation documentation for each bid.

• If you get NO bids/proposals – document this for audit purposes

–Same is true if you get only ONE bid/proposal

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EvaluationEvaluation CriteriaCriteria• Price must be the most heavily weighted

factor, but it may not be the only factor– Check your local procurement guidelines,

sometimes the lowest price must be the only factor

• Can choose most responsive and responsible bid/proposal using factors other than price alone, but must DOCUMENT the choice and process

• Have District official SIGN and DATE the completed evaluation rubric as acknowledgement at the time of the decision by the district

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Vendor A Vendor B

Raw Weighted Raw Weighted

Selection Criteria

Weight* (%) Score** Score*** Score Score

Prices/Charges 40% 1 0.4 2 0.8

Understanding of Needs 15% 2 0.3 1 0.15

Prior E-Rate Experience 10% 2 0.2 1 0.1

Prior District/Service Prov experience

10% 2 0.2 1 0.1

Completeness of Response 15% 2 0.3 1 0.15

References 10% 2 0.2 1 0.1

Overall Ranking 100% 1.6 1.4

SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE

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Form 470 Form 470 Multi-Year ContractsMulti-Year Contracts

• You may not need to file a new Form 470 if the originating Form 470 meets the criteria below:

– The language on the originating Form 470/RFP covered all services on the contract AND

– The applicant indicated on the originating Form 470 that a contract was being sought AND

– The applicant indicated on the originating Form 470/RFP that a multi-year contract was being sought (perhaps w/voluntary extensions)

• Note: Determine if you entered on previous year Form 471 that applicable FRN was on contract 60


Competitive Procurement Competitive Procurement RemindersReminders

• DO ensure a fair and open competitive procurement process. All service providers must be treated equally and cannot be given biased or privileged knowledge of the procurement process.

• DO select the most cost-effective service provider, with price as the primary factor.

• DO keep ALL records relating to the bid/proposal evaluation process (correspondence with potential vendors, winning and losing bids, worksheets, evaluation criteria, contract, etc.). Note in a memo if one (or no) bids are received.

• DO remember that contracts must be signed and dated by the applicant and service provider before filing the Form 471.

• Remember to sign a contract after waiting at least 28 days after the posting of the Form 470/RFP

• Gifting and Procurement rules have been significantly clarified. We will discuss in a later section.

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CONTRACT REMINDERSCONTRACT REMINDERS

• Contract Reviews: Do not wait until the last minute – Allow time for board approval processes

and signatures– Know what constitutes a fully executed

contract, i.e., Board Approval, etc.

• Some contracts may require 2 or more signatures/dates to be fully executed

• Note: Specifics requirements to CalNet 2 addressed in a later section.

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JACK O’CONNELLState Superintendent of Public Instruction 5. Form 5. Form 471471: Application : Application

for Fundingfor Funding

63


Form 471Form 471Your Application for FundingYour Application for Funding

• Detailed information on services, service providers selected, and contracts

• Discount calculation information

• Must be filed every funding year –(even on multi-year contracts)

• Contains certifications of compliance• Includes one or more funding requests

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Organize Your Paperwork Organize Your Paperwork BEFORE Starting Form 471BEFORE Starting Form 471

• Block 2: Impact of services description (bandwidth information and population served)

• Block 4: Entity numbers for all locations receiving service

• Block 4: NSLP and enrollment data, Urban or Rural designation

• Block 5: SPINs for selected service providers• Block 5: Copies of SIGNED contracts (with

award date and end date) and estimated costs (recurring and non recurring)

• Block 6: Budget Information 65


Recurring vs. Recurring vs. Non-recurring CostsNon-recurring Costs

• Separate Recurring from Non-recurring costs in Block 5 of the Form 471(Note: A funding year starts on July 1 and ends on June 30)

–Recurring services must ALWAYS be received by June 30

–Non-recurring services have an extended deadline to be completed by September 30 following the close of the funding year.

• Check Contract dates to align with deadline

• Deadline can be extended for certain circumstances 66


Form 471 DeadlineForm 471 Deadline• Best Practice (File it EARLY!):

– File Online (Application Window changes every application year)

– Do not combine Priority 1 and Priority 2 services on the same Form 471

– Submit BEFORE close of window– Certify BEFORE close of window

•Online if using PIN•By trackable mail if you do not use your PIN

** Bishop Perry Order – 15 day grace period for certifications made after the deadline http://www.usac.org/_res/documents/sl/pdf/List-of-Correctable-Ministerial-and-Clerical-Errors.pdf

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Item 21 AttachmentsItem 21 Attachments• Used to prove your request

–Substantiating documentation that proves the pre-discount cost of services or products

–Should be clear and concise

• Samples available on USAC website– http://www.sl.universalservice.org/reference/

Form471item21Attachments.asp

68


Item 21 AttachmentItem 21 Attachment• Identify and remove ineligible costs

• Work with service provider(s) to create your Item 21 attachment(s)

• Include your Item 21 with your application

• Ensure that your Item 21 and Form 471 totals match

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Missed Deadline?Missed Deadline?

• Form 471 is not submitted before the close of “the window” or is not certified within the grace period:

– The application will not be considered for funding

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Revised Form 471Revised Form 471

Form 471 ‐ Overview• Block 1: Billed Entity Address and

Information– FCC Registration Number added– Type of application and Recipient(s) of

services added– Consultant information added• Block 2: Impact of Services Ordered– Collection of broadband services data

added• Block 3: [reserved]

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Revised Form 471Revised Form 471ContinuedContinued

Form 471 ‐ Overview• Block 4: Discount Calculation Worksheet– Libraries must now provide urban/rural and

student count information on the worksheet– Certain entity‐level data added or

requested in a different format• Block 6: Certifications and Signature– Some certification language changed– Consultant as authorized person checkbox

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• Item 3b – FCC Registration Number (FCC RN) added– Persons and entities doing business with the

FCC must obtain an FCC RN and supply it when doing business with the FCC (Form 471 Block 1 entities only)

– If you do not already have an FCC RN, you can visit: https://fjallfoss.fcc.gov/coresWeb/publicHome.do

• Items 5a and 5b – Type of application/Recipient(s) of service added

• Item 6g – Consultant information added

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Block 2: Impact of Services Ordered• BEFORE ORDER column removed

• “AFTER ORDER” columns to complete:– Individual schools and school districts complete

the “Schools” column– Libraries and library consortia complete

the “Libraries” column– Consortia complete one or both as

appropriate depending on the consortium members

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Block 2: Impact of Services Ordered Items 7a through 7g• Number of students (schools) or patrons

(libraries)• Number of (class)rooms with telephone service• Number of drops (direct Internet connections)• Number of (class)rooms with Internet access• Number of computers or other devices with

Internetaccess

• Number of dial‐up (<56K) Internet connections• Direct broadband services (next slide)

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Block 2: Impact of Services Ordered – Item 7g• Direct broadband services: Number of buildings

served at the following speeds:

< 200 kbps 10 – 25 mbps 200 kbps – 1.5 mbps 25 – 50 mbps 1.5 – 3 mbps 50 – 100 mbps

3 – 10 mbps > 100 mbps

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Block 3: [Reserved]

Block 3 is marked “reserved” to maintain the numbering of subsequent blocks

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Block 4: Discount Calculation Worksheet• Schools and libraries must provide

urban/rural status, student counts, and certain specific information– Total number of students– Number of students eligible for National

School Lunch Program (NSLP)– New construction– Administrative entity or non‐instructional

facility (NIF)– Alternative discount mechanism

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Block 4: Discount Calculation Worksheet (continued)

• Schools must also include the following information if applicable (more than one may apply):– Pre‐kindergarten– Head Start– Adult Education– Juvenile Justice– Educational Service Agency (ESA)– Dormitory

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Block 4: Discount Calculation Worksheet(continued)• School Districts and Libraries must create worksheet

listing all eligible entities in order to calculate the shared discount for the district or system

This allows USAC to verify the calculation for• New school or library construction when the student

population is not known• Eligible discount for non‐instructional facilities NIFs)

such as administration buildings

This worksheet will not affect Two‐in‐Five status unless it is cited in Item 22 of a funding request

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• Block 5: Discount Funding Request(s)

No Changes

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Block 6: Certifications and Signature• Item 26 – Technology plan certification• Item 27 – I certify that (if applicable) I

posted my Form 470 and (if applicable) made any related RFP available for at least 28 days…

• Item 29 – Educational purposes certification

Signature page• Checkbox for consultant as authorized

person

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Receipt Acknowledgement Letter “RAL”

• This is a GOLDEN Opportunity to correct your Form 471 and your ONLY opportunity.

– You can increase the funding request during RAL (but no other time), change discount amount, change contract date, etc.

• If you need a correction, do this during the 15-DAY RAL period. (You may be able to make some corrections during PIA, but DO NOT RELY on PIA process)

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Form 471 RemindersForm 471 Reminders• DO ensure that you have adequate time in your

process to award contracts and have them approved by the Board and signed prior to filing the Form 471.

• DO be organized and have all documentation ready such as NSLP, contracts, SPINs, and budget prior to starting the Form 471.

• DO file separate Form 471 applications for Priority 1 services and Priority 2 services.

• DO split out requests of questionable eligibility into separate Funding Request Numbers (FRNs).

• DO file electronically and DO certify online before the close of the window.

• DO review the RAL carefully and make allowable corrections within the 15-DAY timeline.

• DO make sure that every location that is going to receive services, including NIF’s, that are listed on block 4

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66. PIA (Program Integrity . PIA (Program Integrity Assurance) ReviewAssurance) Review

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RAL ProcessRAL Process

Applicants should carefully review the Form 471 RAL and must notify USAC of any data entry errors within 15 DAYS of the postmark date of the RAL. http://www.usac.org/_res/documents/sl/pdf/sampleletters/471RAL.pdf

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Program Integrity Assurance Program Integrity Assurance (PIA)(PIA)

• Applications are reviewed for compliance with program rules concerning areas such as:

–Properly executed contracts–Discount calculation–Establishing Form 470–Eligibility of services being requested–Eligibility of entities requesting discounted

services–Proper completion of all of blocks/Item 21

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Item 21 and PIAItem 21 and PIA

• Read PIA carefully; do not ignore it or your application will be denied

• 15 days to respond. Don’t wait till the last day!

• Take action! • Involve Service Providers when possible

TAKE ACTION!

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Be ResponsiveBe Responsive

• Respond promptly, answer questions in their entirety (you are given 15 days initially)

• Document communication with PIA, – e-mail is preferred (acknowledgement of

receipt)• Ask for more time if you need it

– May delay your application• Don’t assume that Reviewer has your original

Item 21 attachment• The PIA person can help clarify their questions• Establish a working relationship• Contact your service provider immediately when

you need response information from them• Contact the CDE for site validations, etc.

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7. Funding Commitment7. Funding Commitment

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What Happens After PIA What Happens After PIA Review?Review?

• A Decision – Funding Commitment Decision Letter (FCDL)

–Funded–Not Funded–As Yet Unfunded (Priority 2 requests)–Cancelled

• IMPORTANT – Check all entries in the FCDL carefully to make sure there are no data entry errors.

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Funding Funding Commitment Commitment Decision LetterDecision LetterFCDLFCDL•Should be your “trigger” to file subsequent forms both for USAC and Service Providers•Starts deadline clock for appeal on denial(s) – 60 Days


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JACK O’CONNELLState Superintendent of Public Instruction 8. Form 4868. Form 486

Receipt of Services Receipt of Services ConfirmationConfirmation

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Purpose of 486Purpose of 486

• Notifies USAC that services have started or are scheduled to start and invoices can be paid

• Certifies that Tech Plan for Priority 2 services is approved and meets program requirements

• Certifies CIPA compliance

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CIPA Certification ItemsCIPA Certification Items

• Certifies the status of Children’s Internet Protection Act (CIPA) compliance by:– Technology Protection Measure

• Test and Document that Filtering is working on an annual basis

– Internet Safety Policy– Public Notice & Hearing

• Board Approval in minutes

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What is the 486 deadline?What is the 486 deadline?

• Filed AFTER receipt of FCDL– Form 486 must be filed online or postmarked

no later than• 120 days after the Service Start Date OR

• 120 days after the date of the FCDL

– Whichever is later

Grace period from USAC – letter giving additional 20 days to file 486 – (Alaska Gateway order)

• Take this letter seriously! Do NOT miss the 486 deadline for your district

– http://www.universalservice.org/sl/applicants/step10/form486-filing-information.aspx 96


Missed deadline?Missed deadline?

• If the Form 486 is late, your Service Start Date will be adjusted to 120 days prior to the online submission or 120 days prior to the postmark.

• WILL affect telecommunications and internet access

– Funding will more than likely be reduced

• MAY affect internal connections

– Depends on installation date compared to service start date

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Form 486 Form 486 NotificationNotification Letter (486NL)Letter (486NL)

• Letter received after filing of Form 486– Verify that ALL FRNs are on Funding

Commitment Decision Letter– Verify service start dates for each FRN

• USAC is now ready to begin receiving invoices for payment on these FRNs

– Form 472 – filed by Applicant OR– Form 474 – filed by Service Provider

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Form 486 RemindersForm 486 Reminders

• DO file within 120 days of the service start date (July 1 for recurring services) or FCDL date, WHICHEVER IS LATER.

• DO understand early filing rules if filing BEFORE July 1.

• DO review the Form 486 Notification Letter to verify all FRNs were included.

• DO maintain open communication with your service provider regarding non-recurring services. They can not invoice USAC until the Form 486 is filed.

• DON’T wait until the last minute. • DON’T ignore a Form 486 Reminder Letter.

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9. 9. INVOICINGINVOICING“Getting the Money”“Getting the Money”

Form 472 – BEARForm 472 – BEAR(Billed Entity Applicant Reimbursement)(Billed Entity Applicant Reimbursement)

Form 474 – SPIForm 474 – SPI (Service Provider Invoice)(Service Provider Invoice)

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October Important October Important DeadlinesDeadlines

• Complete your BEAR for 09-10 prior to Oct 28th, 2010

• Pay attention to 486 deadlines, Due 120 days after FCDL (Note: this is due Oct 28th if you received your FCDL for 10-11 on or prior to July 1st)

• Have your tech plan written for Priority 2 services PRIOR to posting your Form 470 for 11-12 if it expires June 30th 2011 or sooner

• File your Form 470 for 11-12 NOW!

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Receipt of FundsReceipt of Funds• One of two ways:

1. Applicant pays entire bill up-front and gets reimbursed

• Form 472, “ BEAR” – filed by Applicant(Note: Form 472 amount must represent actual eligible

costs)

2. Service Provider applies discounts to bills and submits to USAC for reimbursement

• Form 474, or SPI – filed by Service Provider

– Note: Telecommunications Services & Internet Access that are eligible for CTF Discounts must use SPI process

– You cannot file BOTH a BEAR and SPI on the same FRN.

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• Use actual eligible expenses to determine “Total Reimbursement Amount” – Block 1, line 8 and Block 2.– You must be able to demonstrate that you removed

any ineligible costs in a BEAR review or subsequent examination

• Use Block 2, Item 12 for recurring services• Use Block 2, Item 13 for non-recurring services• Create one BEAR for each service provider.

• Can put multiple FRNs on one BEAR, as long as the service provider is the same.

Form 472-BEARForm 472-BEAR

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Form 472-BEARForm 472-BEAR• Once form is filled out, it must be signed by

– Applicant– Service ProviderNote: BEAR can be done online

• Form is then mailed to SLD (unless certified online)

– SLD reviews the form– BEAR Notification is sent to both

Applicant and Service Provider• Check is sent to Service Provider• From the date Service Provider

receives funds from USAC, they have 20 days to reimburse Applicant.

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Form 474 - SPIForm 474 - SPI• Used by Service Providers (SP)

– Allows SP to apply discounts to the bill AFTER funding commitment has been issued and all relevant forms are submitted

– Allows applicant to eventually pay only their non-discounted portion

– Service provider Forms such as “Grid” and “Data Gathering Form” MUST be submitted

• Every service provider has their own process and suggested deadline

• Follow up with Service Provider to ensure receipt of funds

• Helps your district/library’s CASH FLOW ! RETURN GRIDS/Data Gathering information to Service Providers ASAP to start discounts!

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Invoice Deadline Invoice Deadline Extension RequestExtension Request

• USAC provides for the extension of invoice deadlines under certain conditions http://www.usac.org/sl/applicants/step11/invoice-deadlines-extension-requests.aspx

• The CDE will submit a request for a global extension of deadlines for FRNs that also receive the CTF discount. (CTF is discussed later)

– Upon approval, you may receive notification from the SLD that your deadline has been extended.

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Invoicing RemindersInvoicing Reminders

• DO ensure your Form 486 is filed in a timely manner. Invoicing cannot occur until Form 486 is filed and certified.

• DO, if using the SPI method, ensure that all service provider forms are completed and returned in a timely manner.

• DO work with your service provider to verify discounts posted on your invoices.

• DO file the BEAR form prior to the Invoice Deadline.• DO document your BEAR form calculations and retain

for audit purposes.• DO file an Invoice Deadline Extension Request if your

FRN does not show any or incomplete disbursement of funding by the invoicing deadline.

• DON’T assume the discounts posted are correct.• DON’T include ineligible costs in your BEAR form

amount.107


Audits, Appeals, and Other Reviews

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How To Prepare for an Audit How To Prepare for an Audit or ANY Type of Review or ANY Type of Review

• Follow All E-rate Rules• Document, Document, Document!

• You can’t prove that you abided by the rules if you don’t document your processes

• Plan ahead for an audit or review by documenting every step of the process

• Create E-Rate binders for EACH funding year

• Retain – Retain – Retain – Lessen your pain!! Retain ALL E-rate related documents

• Contact your service providers • USAC Compliance Documentation Checklist for

audits• http://www.usac.org/_res/documents/sl/pdf/

CompDocChecklist.pdf 109


Document Retention Document Retention RequirementsRequirements

• Keep for 5 years after last date of service– Be aware of contract dates and extensions – All USAC correspondence, including Quarterly

Disbursement Reports• Make sure all departments understand

documentation retention requirements for E-Rate• Align Board policies with E-rate requirements• Per 5th Report and Order: if applicant can’t prove

compliance with rules through documentation, they must assume that you didn’t follow the rules

• No documentation = Recovery of Funds(Applicant may have to pay back the SLD for E-rate

discounts they already received)

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Examples of Rule Violations that Examples of Rule Violations that Warrant Potential Recovery of FundsWarrant Potential Recovery of Funds• Insufficient documentation of the competitive

bidding/procurement process (Applicant did not follow local & state procurement rules)

• Lack of necessary resources – equipment not fully utilized

• Service substitutions not meeting criteria established in the rules

• Failure to pay (or show proof of payment) of non-discounted share

• Poor asset tracking – equipment could not be located

• Discount calculation violation

• Technology Plan not approved and/or not containing required elements and requested services

• More specific examples located on USAC Audit training slides located at:

http://www.universalservice.org/sl/about/training-presentations/training-presentations-archive/training-2008/fall/materials.aspx

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Beneficiary and Contributor Beneficiary and Contributor Audit Program (BCAP)Audit Program (BCAP)

• Audits have been revamped – USAC listened!

• No audits during last 2 weeks of window. Auditors more flexible in accommodating applicants’ schedules

• USAC Engagement lead – more visibility and oversight of audit firms

• Auditors will spend more time on planning and review of materials and less time on site

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Who Should Be AvailableWho Should Be AvailableDuring Audits?During Audits?

• Person(s) who – filed the E-rate forms (such as consultant)– managed the bidding and award process– reviewed and approved invoices– prepared E-rate invoices– is responsible for budget (CBO)– is responsible for NSLP documentation– is knowledgeable about the network and the

location of equipment– provided service (if needed)

• Appoint a single contact person who can manage interactions between auditors and staff members

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Audit “Gotchas”Audit “Gotchas”• No documentation of a “draft” technology plan

at time of Form 470 filing (FY 2005 onward)• No record of reconciliation of service provider

invoices• No record of CIPA compliance – Public

meeting and notice• Internal Control deficiencies

• Asset Management• Accounts Payable procedures• Understanding procurement rules and

State guidelines114


Other Levels of ScrutinyOther Levels of Scrutiny• H.A.T.S Visits

•Helping Applicants To Succeed

• Primarily for applicants that have had funding issues in the past

• Welcome the help…do not be afraid• Special Compliance Reviews

• Typically during PIA• Item 25 Selective Review• Cost Effectiveness Review• CIPA Compliance and Competitive Bidding

Selective Reviews

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Payment Quality Assurance Payment Quality Assurance (PQA)(PQA)

• Started in August of 2010• Randomly selected USAC invoices are now being

audited on a monthly basis– CHALLENGE: USAC invoice SLC # may not directly

reference any service providers invoices the applicant has received

• Since USAC invoice selected may be a SPI (Service Provider Invoice) you may need to contact your service provider for assistance in securing information requested

• Following page lists examples of what is requested during PQA

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BENEFICIARY DOCUMENTATION REQUESTED1. A document that indicates the beneficiary’s non-profit or government

subdivision/unit status. Examples include: most recent audited financial statement (stating the type of entity, or requiring compliance with Single audit procedures), business license, IRS not- for- profit determination letter.

2. For schools, libraries, and members of a consortium: A document that indicates status as a primary/secondary school/district, or library eligible under Library Services and Technology Act (LSTA). Examples include: items from request 1, website, other published or official document.

3. For schools only: list of endowments over $50 million relating to funding year, or confirmation that none exist.

4. For libraries only: Budget relating to funding year.5. List of all entities that received goods and /or services associated to

the BEN identified on the notification letter; not applicable if identified on Service Provider Bill.

6. Service Provider bill(s) associated to the Funding Request Number (FRN) identified on the notification letter. Please indicate on the bill:

a. The FRN and the goods or services provided under the FRN with a sufficiently detailed description (produce description, quantity, serial number and/or service description) to support a test of eligibility of goods and/or services.

b. The dollar amount of the bill that was paid by USAC, or to be paid by USAC.

7. The Technology Plan Approval Letter for the FRN identified on the notification letter, except for requests for Voice Over Internet Protocol (VOIP) or basic telephone services.

8. For Consortia only: Letters of Agency for entities listed on the Form 471 for the funding year identified on the notification letter. If your consortium does not require Documentation/LOAs as a result of laws governing the mandatory participation of all schools and/or libraries in your consortium, provide a copy of the state statute or regulation in regards to the mandatory participation of the consortium member entities.

9. Printed and signed Confirmation Letter.117


AppealsAppeals• Submitted to USAC if you disagree with a decision (denial) -

approved in very limited circumstances.• Appeals to USAC must be submitted within 60 days of the

denial letter• When the appeal makes it clear that USAC erred in its initial

review• When the applicant provides USAC with information it did not

provide when the original request was made• When USAC obtains policy clarification or new policies that

impact the original decision• Submitted to FCC if you are questioning the existing program

rules or if USAC denies the initial appeal• Appeals must be submitted within 60 days of a USAC

denial

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RemindersReminders

• After Posting the Form 470–WAIT AT LEAST 29 DAYS BEFORE:

• Selecting a service provider• Signing a contract• Signing and dating the Form 471• Submitting the Form 471

• MUST OCCUR IN THIS ORDER• Both Applicant and Service Provider must

sign and date all contracts.• Work with Telecom to consolidate their

bills• Form 471 must be filed before filing

window closes119


RemindersReminders•Create YOUR OWN timeline of E-Rate deadlines

–Opening and closing of the Form 471–Form 486 deadline based on FCDL

•Be aware of timelines and adhere to them•Share this information with others at your site (keep administration informed)•Have a backup person (succession planning)•Keep E-Rate files organized•Print and retain copies of everything

–USAC Link to Document Retention: http://www.usac.org/sl/about/audits/e-rate-binder.aspx.

•Additional 2009 USAC Training Audit Information: http://www.usac.org/sl/about/training-presentations/training-presentations-archive/training-2009/fall/materials.aspx

•Get on the CDE E-rate list Serv Today !!http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp

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Contact InformationContact Information• State Library: Rushton Brandis,

(916) 653-5471, [email protected]• CDE/E-rate: John Vardanega,

(916) 323-2241,

[email protected]• CDE/EETT: Tech Plans: Doris Stephen,

916-324-9943

[email protected]• K-12 HSN/Butte COE: Russ Selken,

530-532-5678

[email protected]

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E-Rate for California Beginner Applicants

Documents