Www.usac.org How Do I Navigate PIA Review? Back to the New Basics Schools and Libraries Division Washington, DC Orlando Boston New Orleans Cleveland San.

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How Do I Navigate PIA Review?

Back to the New Basics

Schools and Libraries Division

Washington, DC • Orlando • Boston • New Orleans • Cleveland • San Francisco • Phoenix

September/October 2007

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Overview

PIA Review - What Is It?

Types of PIA Review

Frequently Asked PIA Questions

Responding to PIA Questions

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PIA Review

What is PIA?

Program

Integrity

Assurance

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PIA Review

What is the purpose of PIA Review?A. To educate applicants about E-rate jargon

(e.g., FCDL, tariffed, SPAC, etc.,)

B. To ensure that Universal Service Fund support is committed only for eligible products and services as well as eligible uses by eligible entities.

C. To annoy applicants by asking for the same documents multiple times.

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PIA Review

Answer is B.

Each application is reviewed to ensure that Universal Service Fund support is committed only for eligible products and services as well as eligible uses by eligible entities.

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Types of PIA Reviews

Regular PIA Review

All Form 471 applications are reviewed for:–Entity Eligibility

–Discount Accuracy

- Eligible Products & Services

- Compliance with Program Rules

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Heightened Scrutiny PIA Reviews– Generally includes all applications associated

with the BEN. – This is a targeted review of one or more of

the following areas:• competitive bidding and evaluation process, • budget, • technology plan, • necessary resources (e.g., professional development,

software, hardware, maintenance); and • products/services pricing and use

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Types of Heightened Scrutiny Reviews

– Selective Review

– Pattern Analysis

– Special Compliance

– Cost Effectiveness

10% of Form 471 applications receive heightened scrutiny reviews

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Levels of PIA Review

Initial Review, Final Review, QA 1, QA 2 Applications always start in Initial Review Initial Reviewer from regular and/or heightened

scrutiny team contacts the applicant with questions If a more senior reviewer finds an issue with the

review of the application, it will be returned to the initial reviewer and then have to move back up again.

Real time application status – 471 Application Status Tool

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PIA Questions

What do you do when PIA contacts you?

A. Resign immediately and don’t leave forwarding information.

B. Hide under your desk.

C. Respond to the questions.

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PIA QuestionsAnswer is C. Respond to the questions. If you are unsure what the PIA Reviewer is

asking, use the contact information provided to ask the PIA Reviewer to clarify the question.

Ask to speak with a Manager if you are still unsure what the reviewer is requesting.

14% of all FY2006 FRNs were denied because the applicant never responded or submitted insufficient information.

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PIA Questions

What is PIA really asking me?

Third Party Documentation

PIA Question: “If you do not agree with our eligibility assessment … then you may provide third party supporting documentation.”

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PIA Questions

Translation: – PIA needs additional details about the

service to determine eligibility• Vendor product description• Vendor invoice or bill• Contract, service agreement, statement of work

– PIA needs the information from an official source (e.g., State Department of Education)

• Validating entity eligibility• Validating discount percent, student count

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PIA Questions Contract CertificationPIA Question: “Please provide supporting

documentation to demonstrate that a signed contract was in place at the time of the submission of the FCC Form 471 certification. Also, please certify that your contract meets your state or local procurement regulations or rules.”

Translation: The contract did not have an applicant signature and/or a date. Because the signature and/or date is missing, PIA needs to confirm that the contract meets state/local procurement rules. PIA will ask you to complete the contract certification.

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PIA Questions Contract Certification Example

I certify that I am authorized to make the representations set forth below on behalf of <enter entity name>, the entity represented on this letter, and am the most knowledgeable person with regard to the information set forth herein. I certify that for Funding Request Number(s) (FRNs) ____________, the Contract Award Date (CAD) is <mm/dd/yyyy> as reflected on the supporting documentation for this contract. I am correcting the CAD provided on the FCC Form 471 submitted for the above listed FRNs. I acknowledge that false statements can be punished by fine or forfeiture under the Communications Act, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C. § 1001 and civil violations of the False Claims Act. I acknowledge that FCC rules provide that persons who have been convicted of criminal violations or held civilly liable for certain acts arising from their participation in the schools and libraries support mechanism are subject to suspension and debarment from the program.

I declare under penalty of perjury that the foregoing is true and correct. Executed on _____ day of ____________, 2007 at ____________ [city], ________[state].

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PIA Questions Incomplete Online & Paper Item 21 PIA Question: “the documentation provided is not

sufficient to determine the eligibility…”

Translation:– The product description was generic

• Server functionality is not specified (e.g., file, network, web)

– PIA needs specific functionality such as DHCP, DNS, Email, Proxy, etc.

• Missing or incomplete make/model information

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PIA Questions

Incomplete Online & Paper Item 21 cont’d – Miscellaneous charges

• PIA needs to know what the miscellaneous charges are

• Miscellaneous charges are often used to describe inside wiring jacks, faceplates

– Training requests• PIA needs the who/what/when details of the

training being requested

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PIA QuestionsIncomplete Online & Paper Item 21 cont’d

Common Omissions & Errors

– Ineligible components not identified

– Applicant sent both an online and paper Item 21

o Items, cost, ineligibles are different

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– Telecom serviceo Type of service is missing (local, long

distance or cellular service)o Line count missingo Speed of line (e.g., T-1, Frame Relay,

ISDN)

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– Internet accesso Bandwidth or speed missing (T-1, T-3,

broadband, etc.)o Web Hosting (third party documentation

needed)– Internal connections

o Type of equipment stored on rack/cabinet missing

o PBX component list missingo Make and model are missing

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PIA Questions Cost Allocation

PIA Question: “For FRN XXX, the documentation provided in the Item 21 Attachments indicates that the following ineligible XXX were included in your request... Please provide documentation identifying the charges associated with the ineligible XXX identified above.”

Translation:– “Save” the eligible portion of the FRN by removing the

ineligible items and costs– Providing the cost allocation may prevent the entire

FRN from being denied.

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PIA Questions Cost Allocation cont’d

– Cost allocations must be based on tangible criteria and reach a realistic result.

– PIA needs the cost associated with the ineligible service, entity, or location to:

1.Modify the FRN to remove ineligibles; or2.Split the FRN, creating a new FRN for the

ineligibles

Note: When 30% or more of the services are ineligible and the applicant does not agree to split the FRN, the FRN will be denied.

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PIA Questions Splitting FRNsPIA Question: “You may request to remove the

ineligible item(s) from this FRN and place this item(s) in a new FRN. Would you like to split the FRN? _____Yes or _____ No.”

Translation:– “We agree to disagree”– Maintaining the ineligible items & cost

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PIA Questions

Splitting FRNs (New Block 5 information)• PIA needs the (ineligible & eligible) costs, service

provider, contract and entities receiving service information for the “old” and “new” FRNs

• Use the Applicant Contact Template to complete the Block information for the new FRN

Splitting mixed-bucket request• Applicants have an opportunity to receive P1

(telecom, Internet access) funding without waiting until P2 threshold is determined

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PIA QuestionsEntity Number __________________________________ Applicant’s Form Identifier ________________________

Contact Person __________________________________ Phone Number _______________________

Block 5: Discount Funding Request(s) Instructions: Use one Block 5 page for EACH service (Funding Request Number) Block 5, page __ of __ which you are requesting discounts. Make as many copies of this page as needed, and number the completed pages to assure that they are all processed correctly.

10

If this is a duplicate Funding Request (e.g., of an FRN that is not yet approved, under appeal, etc.), check this box and enter the original FRN in the space provided:

11

Category of Service (only ONE category should be checked)

23 Calculations

PRIORITY 1 Telecommunications Service Internet Access

PRIORITY 2 Internal Connections Other than Basic Maintenance Basic Maintenance of Internal Connections

12 Form 470 Application Number

A. Monthly charges (total amount per month for service)

B. How much of the amount in A is ineligible?

13 SPIN – Service Provider Identification Number

C. Eligible monthly pre-discount amount (A minus B) 14 Service Provider Name

D. Number of months service provided in funding year

Recurring Charges

E. Annual pre-discount amount for eligible recurring charges (C x D)

15a Check this box if this Funding Request is for

non-contracted tariffed or month-to-month services.

15b Contract Number

F. Annual non-recurring charges

15c

15d

Check this box if this Funding Request is covered under a master contract (a contract negotiated by a third party, the terms and conditions of which are then made available to an eligible entity that purchases directly from the service provider). Check this box if this Funding Request is a continuation of an FRN from a previous funding year based on a multi-year contract. If so, provide that FRN here:

G. How much of the amount in F is ineligible?

16b

Check this box if there are multiple Billing Account Numbers and attach a complete list of those numbers to this page.

17

Allowable Vendor Selection/Contract Date (mm/dd/yyyy)

(based on Form 470 filing)

Non-Recurring Charges

H. Annual eligible pre-discount amount for non-recurring charges (F minus G)

18 Contract Award Date (mm/dd/yyyy) Total I. Total funding year pre-discount amount (E + H)

Sample Block 5 Template

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PIA Questions

Establishing Form 470PIA Question: “…you indicated that Form 470

XXX is the establishing Form 470 for the services requested. Is this Form 470 the establishing Form 470…?”

Translation: The Form 470 provided does not support the category of service on the Form 471. PIA needs the Form 470 that was posted for at least 28 days for the services requested on the Form 471.

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PIA Questions

Establishing Form 470 cont’d

PIA Question: “… please provide the 15-digit Form 470 that established the bidding for the contract extension.”

Translation: PIA needs the Form 470 which demonstrates the applicant requested a contract extension or the current funding year Form 470.

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PIA Questions

Alternative Discount Calculation

PIA Question: “On your Form 471 application #, you stated that you used an alternative discount mechanism to calculate the number of students eligible for NSLP, for the following entity (ies): XX. Please provide a complete description of the methodology used to calculate the number of students eligible for NSLP.”

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PIA Questions

Alternative Discount Calculation

Translation:– PIA needs to verify what method the applicant used to

derive the discount. – Surveys are the most common method.– NSLP forms are not acceptable as surveys.– SSI, Section 8, Food Stamps are acceptable

alternative mechanisms – Income Survey template is available on USAC’s

website

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PIA Questions Additional explanation

PIA Question: “If you do not agree with the cost allocation that we have produced, you must provide an alternative cost allocation identifying the cost(s) for the ineligible item(s).”

Translation: PIA provided a cost allocation to remove ineligibles. The applicant can provide an alternate cost allocation if he or she disagrees with PIA. Make sure the alternate cost allocation is supported by third party documentation.

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Applicants Responses

15 Day Rule

– Applicants have 15 calendar days to respond to PIA questions

– PIA will send a reminder on or near the 7th day

– The state E-rate coordinator will be cc’ed on the reminder

– Applicants may request extensions

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Why are you asking me that again?

Modifications and Denials– PIA will confirm the original response when

the FRN is modified or denied.

– PIA will tell you the denial reason. This is an opportunity to correct a mistake and/or omission.

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Asking Again Success

Few FRNs were denied in FY 2007 for 30% Rule.

30% Rule StatsFY 2006 977 FRNs deniedFY 2007 46 FRNs denied (as of 8/2007)

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Why are you asking for the same document again?

Different reviews– Regular review v. Selective review

Previous document may be missing key information – Contract missing date or signature– Unexplainable cost increase

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Why are you asking for the same document again?

Applicant’s funding request changed from FY to FY– Applicant added entities – Applicant requested additional services

PIA Resources

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Tips to eliminate repeat questions

Indicate multi-year or state master contract on Form 471 and contract number

Provide the application number and FRN associated with the documents previously submitted

Respond timely to PIA request

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Tips to eliminate repeat questions cont’d

Answer all the questions

When you ask to increase discount percentage and/or FRN amounts, provide third party documentation

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Tips to eliminate repeat questions cont’d

Provide PIA with the telephone bill summary page. If miscellaneous charges are listed in the summary, state what they are in your Item 21 Attachment.

“Final Answer”

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Questions?

Www.usac.org How Do I Navigate PIA Review? Back to the New Basics Schools and Libraries Division Washington, DC Orlando Boston New Orleans Cleveland San.

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