1 E-Rate Year 2011 Opportunities for Kansas Schools and Libraries Don Dietrich BTU Consultants, LLC (Includes content from October, 2010 SLD Seminars,

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E-Rate Year 2011Opportunities

forKansas Schools and Libraries

Don Dietrich

BTU Consultants, LLC

(Includes content from October, 2010 SLD Seminars, with permission)

"Make everything as simple as possible, but not simpler."

Albert Einstein

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E-Rate 2010 Agenda9:00am - Morning Session

E-Rate and Kan-edPreparing for E-Rate 2011 Tech Plans, CIPA & Budgets Priorities , Categories and Eligible ItemsApplying for E-Rate 2011

Forms 470, 471, Item 21 Attachments

12:00 – 1:00pm Lunch

1:00pm - Afternoon SessionE-Rate Approval and Acceptance Process PIA Review Process Forms 486, 500, 472 BEARS vs Discounts Contract Extensions & Service Substitutions SPIN ChangesRecord Keeping, Appeals & Audits

What’s new for 2011!

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E-Rate & Kan-ed

Kan-ed receives E-Rate funding for Telecom and Internet Services only. Funding is based on membership of “eligible entities”

Kan-ed Members must sign LOA (Letter of Agency) in order for Kan-ed to receive funding

Kan-ed E-Rate has no effect on individual school or library E-Rate applications

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E-Rate and Kan-ed

From SLD Website

“…for consortium applications, the consortium lead member must either collect Letters of Agency from each consortium member or be able to provide some other proof that each consortium member knew it was represented on the application…NOTE that the Letter of Agency must be certified BEFORE the filing of the Form 471.”

E-Rate Annual Cycle - 7/1/xx through 6/30/xx

Plan & File Form 470 September –

October Review / Update / Approve Technology Plan

Free & Reduced Lunch Counts

Competitive RFPs Developed (if required) October - November

Vendor Conference(s) October - November

Vendor Responses Received Early December

System / Vendor Selection Mid December

Contract Negotiation December - January

Forms Submission to SLD (Form 471) Feb (March ‘11?)

Implementation (Form 486 / 500 / 472) July – June

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USAC E-Rate Information

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

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E-Rate Program Rules – Basic Requirements

• NEW FOR 2011 – For E-Rate purposes you need a Tech Plan only if applying for Priority 2 services.

• Competitive Process – requests must be posted for 28 calendar (not business) days

• All funds must be used for• eligible goods and services• installed at eligible facilities • provided by eligible service providers

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Before Filing…

Everything must be documented

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Technology Plan – Kansas K12 Schools

KSDE will continue to support the Federal requirement that districts have an approved Technology Plan, as currently dictated by NCLB—Enhancing Education

Through Technology aka Title IID.

Contact Melinda Stanley ( [email protected] )

http://www.ksde.org/Default.aspx?tabid=2745

E-Rate Technology Plan – 5 Requirements

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E-Rate Technology Plan – 5 Elements

You may need CIPA compliance for E-Rate

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• CIPA (Children’s Internet Protection Act) compliance is only required if you are applying for Internet or Internal Connections

• If you don’t want to mess with CIPA…you should still file E-Rate for Telecom

Before Filing…

CIPA Requirements

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• Must have an Acceptable Use Policy or Internet Safety Policy that contains specific elements

• Must have a public hearing and public notice

• Must have technology protection (filtering) software in place to protect minors.

• All documentation supporting compliance with CIPA rules is maintained in E-rate binder.

Acceptable Use Policy Requirements

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• Access by minors to inappropriate matter on the Internet and World Wide Web.

• The safety and security of minors when using electronic mail, chat rooms, and other forms of direct electronic communications.

• Unauthorized access including "hacking" and other unlawful activities by minors online.

• Unauthorized disclosure, use, and dissemination of personal information regarding minors.

• Measures designed to restrict minors' access to materials harmful to minors.

Before Filing…

Protecting Children in the 21st Century Act (New)

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• Enacted in Fall 2008 to address Internet Safety in schools, specifically cyber-bullying 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

Before Filing…

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CIPA Resources

American Library Association website: http://staging.ala.org/ala/aboutala/offices/wo/woissues/civilliberties/cipaweb/cipa.cfm

CIPA Rules from FCC http://www.fcc.gov/cgb/consumerfacts/cipa.html

CIPA Rules from SLD http://www.universalservice.org/sl/applicants/step10/cipa.aspx

CIPA Rules from IMLS (Inst of Museum & Libr Svcs) http://www.imls.gov/about/cipa.shtm

E-Rate Eligible – 2 Priorities / 4 Categories

• Priority 1 (to the building) – always funded

• Telecommunications Services Category

• Internet Access Category

• Priority 2 – (within the building) - awarded to poorest

applicants first, until all funds are exhausted

• Internal Connections Category (only available 2 out of 5 years)

• Basic Maintenance of Internal Connections Category

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Before Filing…

What’s Covered ?Priority 1 (to the building)

• Local and long distance telephone usage, Cellular and Paging

• Internet access costs, Web Hosting, Email Service

Priority 2 (within the building)• Cabling and hardware (switches, routers, racks, UPS…)

• Network Servers for Internet access and E-mail

• Telephone systems (PBX’s) including VoIP and VoiceMail

• Maintenance charges

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Before Filing…

What’s Not Covered ?

• Computers, Telephone instruments, Video Cameras

• Power infrastructure

• Physical security or construction

• Application Software

• Consulting Services, Training, Personnel Costs

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Before Filing…

Eligible Services List – Changes FY2011

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• Dark Fiber is now eligible from any provider (not just Telecom companies) under a new category of “Telecommunications”

•Expanded coverage for Web Hosting (added chat rooms & blogs)

•Maintenance Fees – SLD wants to pay only for ‘break fix’ activities actually performed. Still under discussion.

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21http://www.usac.org/sl/

http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-09-105A2.pdf

Eligible Services List (ESL)

Take some time to Review the ESL

Put a Check Mark in the margins of the items that you are sure you will need

Put a question mark in the margins of the items that you have questions about

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Before Filing…

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E-Rate Eligible Locations

All K-12 Schools, Libraries and most NIFs (Non-Instructional Facilities)

Definition of Educational Purposes• Activities that occur on library or school property are presumed to be

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

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

Step 6: Educational Purposes - Applicants - Schools and Libraries - USAC

24SCHOOLS:• Administrative buildings• School bus barns and garages• Cafeteria offices• Facilities associated with athletic

activities

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

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• Examples of Non-Instructional Facilities (NIFs) that can receive Priority 1 services

E-Rate Eligibility

E-Rate Eligible Locations – Priority 2Be Careful

Priority 2 services for administrative sites are NOT eligible unless those services are “essential for the effective transport of information to a library”.

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Before Filing…

E-Rate Eligible Locations – start your own list

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1. What locations (entities) are you responsible for ?

1. Which will you want to include on E-Rate Form 470 ?

1. Assume all locations are in need of Priority 1

1. Are some (all) locations in need of Priority 2 ?

Before Filing…

Priority 1 On-Premise Equipment – Be Careful

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“My Internet Provider wants to ‘give’ me a router.”

“My Phone Company wants to sell me a phone system under E-Rate Priority One”

Be CAREFUL – you must satisfy SLD’s Strict Requirements

Before Filing…

Priority 1 On-Premise Equipment – Example 1

This leased router may be eligible for P1 funding if all conditions are met. Single demarcation – if the router is removed, the LAN would continue to function

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Before Filing…

Priority 1 On-Premise Equipment – Example 2

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Leased VoIP and PBX equipment are NOT eligible for Priority One funding.By removing the VoIP PBX equipment, the local voice network will cease to function. This equipment is eligible ONLY as Internal Connections.

Before Filing…

Web Hosting – What is it and What’s Eligible

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Source: http://www.usac.org/sl/about/training-presentations/training-presentations-archive/training-2009/fall/materials.aspx

(Advanced Eligible Services)

• Provides a means for a library to display content on the Internet.

• Generally includes:– provision of web site traffic (bandwidth)– provision of disk space for storing applicant provided

content– provision of File Transfer Protocol (FTP) transfer or a

Web interface to upload files

Before Filing…

Web Hosting – Not Eligible

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Before Filing…

E-Rate Discounts depend on…

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• The percentage of students eligible for the National School Lunch Program (NSLP) or an equivalent measure of poverty

http://www.ksde.org/Default.aspx?tabid=1870

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

http://www.usac.org/sl/applicants/step05/urban-rural/

Before Filing…

E-Rate Discounts are Based on Poverty Level

INCOME URBAN LOCATION RURAL LOCATION

Measured by % of students eligible for the National School

Lunch Program

Discount Discount

If the % of students in your school that

qualifies for the National School Lunch

Program is…

…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%

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Before Filing…

Calculating Discounts - Libraries

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• Single Library Outlet or Branch– use discount for the School District in which the library or

branch is located• Library System & Consortia

– calculate discount for each individual entity– calculate simple average discount

(total discounts/total entities)• New Construction

– use discount for the School District in which the library is located

Before Filing…

Should I file for Priority 1, Priority 2 or Both?

• Your discount level determines whether or not you will be funded for Priority 2 goods and services:

• below 70% = low probability of Priority 2 funding

• 80% and above = high probability of Priority 2 funding

• cutoff level changes every funding year

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Before Filing…

Procurement Process

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Plan Procure Implement

Tech Plan

Requirements

Design

Detail Specifications

Internal Approvals

Competitive RFP (if required)

Vendor Selection

Award Contracts

Submit Specific Requests

Coordinate Vendors

Monitor Installation

Resolve Upsets

Audit Financial Documents

Assure Completion

Recommend Acceptance

E-Rate Forms

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Plan Procure Implement

Form 470

Notice of applicant’s intent to acquire goods and services (non-specific as to amounts or vendors)

Form 471

Specific request for goods and services by entity, category, detailed costs and vendor (requires signed contract with vendor)

Form 486

Notice of intent to accept funds awarded

Form 500

Change award amount or items

Form 472 (BEAR) – Recover discounts already paid to vendors for eligible goods and services.

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38http://www.usac.org/_res/documents/sl/pdf/application-process-flow-chart.pdf

E-Rate Form 470

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39Step 3: Form 470 Filing Information - Applicants - Schools and Libraries - USAC

E-Rate Form 470 is New for 2011

If it’s not available when you need it you

can use the old Form 470 but

CERTIFY as SOON AS YOU SUBMIT

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Filing your Form …

E-Rate Form 470 – What’s it for?

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• Filing Form 470 opens a competitive bidding process– can also issue a Request for Proposals (RFP)

• Applicants are responsible for ensuring an open and fair process and selecting the most cost-effective provider of the desired services

• RFP is not required under FCC rules• Even if you have an RFP, you must describe the services

you desire on your Form 470


E-Rate Form 470 – Gotcha’s

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• You must wait at least 28 days from the submission date before entering into a contract for services

• If filed online, the form will calculate this date for you• If you are under a multi-year contract from a previous

year, you do not need to file a Form 470 every year• If you are under Month-Month or Tariff rates, you must

file a Form 470 every year• Must indicate willingness for a multi-year contract or

contract with extensions if appropriate


E-Rate Form 470 – What you will need

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• File online – only use paper as a last resort• You will need to know how many entities you are applying

for and the area-code, prefix of each (going away in 2011)• You will need the general descriptions for each service that

you are requesting (See Example)• You will need a PIN # (automatically issued the first time

you file a paper form)


E-Rate Form 470 – Online

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44Training Website SLD Training Site


RFP Process – Issues in Competitive Bidding

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SLD is on the lookout for these common ‘problems’ • Must wait 28 days and ‘be accessible’• Must respond to all legitimate inquiries• Vendor cannot help you with Form 470 or be involved in

competitive process• Multi-tiered vendor selection must follow rules• NO ‘Sham’ Bidding (i.e. “I already know who I want”)• Cost to transfer to another provider alone is not by itself

a good enough reason to stay with incumbent• NO Gifts or ‘Free’ Services


(Issues In Competitive Bidding)

After Form 470…

Vendor Selection – if there’s not a formal RFP

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• You must document and retain your vendor selection process

• Use this template or one of your own to record Form 470 responses from vendors

• Keep logs of all vendor emails

Form 470 Response Log Spreadsheet

E-Rate Form 470 Service Provider Response and Selection LogUse this form to log all vendor contacts regarding non-RFP items on this Form 470. Document Service Provider Selection and assign FRN numbers only after the Allowable Contract

Date. Form 470 Items that are described by a formal RFP should be documented elsewhere.

Funding Year: 2010 Contact Name:Applicant Name: Your CA Library Latest Update: 1/5/2010BEN: 470 Posting Date: 12/4/2009

Form 470 No.: 963940000779355 470 Allowable Contract Date: 1/1/2010

470 Date Closed: 1/31/2010 470 Review/Selection Date: 2/8/2010

Form 470 Description: Priproty One services, no RFP.

Use Item Descriptions from Form 470 Date Vendor Name / SPIN

Mode of Contact

Notes, Comments and Actions Taken FRN

Telecommunications

Local Voice Tel Services Approx 430 Centrex Lines to 14 Locations. Provided by Verizon North on a tariff basis.

incumbent Verizon NorthMost cost effective since no new equipment required - only solution

that will run over existing WAN.1984425

12/4/2010 Calltower emailRec'd proposal for VoIP - requires new equipment (Cisco VoIP) and new

phones. Also would require upgrade to WAN beyond DS1s.

12/7/2010 Trumpet Networks email

Rec'd requiest for information but no pricing. Trumpet provides both WAN and VoIP services. This vendor would require new equipment (VoIP PBXs) and new phones. Also would require upgrade to WAN

beyond DS1s.

incumbent Verizon NorthMost cost effective solution - other two offerors do not match specs and

would require new equipment.1984427

12/7/2010 Trumpet Networks emailRec'd requiest for information but no pricing. Trumpet provides both

WAN and VoIP services as P1.

1/11/2010 Comcast emailProposed Fiber WAN and 50mb Internet. Does not match specs, would

require new equipment and higher cost.

incumbent Qwest No responses received - remaining with incumbent provider. 1984430

incumbent Verizon Wireless No responses received - remaining with incumbent provider. 1984435

incumbent Verizon Wireless No responses received - remaining with incumbent provider. 1984435

After Form 470…

Vendor Selection – if there is a formal RFP

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47..\Training Presentation Fall 2010\samples-checklist-vendor-selection-worksheet.pdf

After Form 470…

CompetitiveProcessTip Sheet

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48http://www.usac.org/_res/documents/sl/pdf/tip-sheets/competitive-bidding-process.pdf

E-Rate Form 471 – Do You Need a Contract?

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

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

Step 4: Contract Guidance - Schools and Libraries - USAC

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ContractsTip Sheet

..\Training Presentation Fall 2010\Tip Sheets\Tip Sheet contracts.pdf

E-Rate Form - 471

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E-Rate Form - 471

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• Provides specific information on services, service providers selected, and contracts

• Provides discount calculation information

• Must be filed for each funding year

• Contains certifications of compliance

• Includes one or more funding requests

• Each FRN must reference a specific Form 470

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E-Rate Form - 471

Form 471 Block 1 & 3

• Block 1 - Billed Entity Information

• Block 2 – Impact of Services Ordered for Schools

• Block 3 - Impact of Services Ordered for Libraries

• Block 4 - Discount Information

• Block 5 - Detailed Funding Requests

• Block 6 - Certifications and Signature

E-Rate Form – 471 - Deadline

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• Must be filed online or postmarked on or before the close of the Form 471 application filing window.

• Forms 471 filed after the close of the window will be considered after all Forms 471 filed in-window.

• Certifications for associated Forms 470 also must be filed online or postmarked before the close of the window.

E-Rate Form 471 – Online

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55Training Website SLD Training SiteExample Abilene 2009

E-Rate Form 471 – Gotcha’s

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• Don’t combine Priority 1 and Priority 2 requests on the same Form 471.

– review of Priority 2 requests may hold up Priority 1 commitments.

• If filing for more than one discount rate – use separate Form 471 applications.

• For 2011 you will need an FCC Registration # avail at: https://fjallfoss.fcc.gov/coresWeb/publicHome.do

E-Rate Form 471 - TIps

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• Remove ineligible costs from funding requests• Document ineligible costs carefully• 30% rule – if 30% or more of the dollar value of the

request is for ineligible products and services, the entire request will be denied

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

• File Item 21 Attachments online

Training Website SLD Training Site

Form 471 Project Tracking Spreadsheet

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58(Sample Project Tracking Spreadsheet )

E-Rate Form 471 – Item 21s

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• You must attach a description of goods and services• Include breakdown of components, costs,

manufacturer, make and model• Examples on SLD website• Clarity and completeness will prevent PIA questions• Use Online version if possible

Form – 471 – Item 21 - Example

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Step 7: Item 21 Attachments for Form 471 - Applicants - Schools and Libraries - USAC

Form – 471 – Item 21 – Online Example

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61Training Website SLD Training Site

SLD E-Rate Resources – When you need help…

• User Hotline (1-888-203-8100) • Online “Submit a Question” www.slforms.universalservice.org• Email Questions to: [email protected]• Search Reference Area: Reference Area - USAC• SLD Newsbriefs: News-briefs - Schools & Libraries – USAC• Training Website: SLD Training Site • One Page Guidelines: SLD TIP Sheets • SLD Training Presentations

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

• E-Rate Central Newsletter (example)• http://www.e-ratecentral.com/subscribe.asp

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PIA Review – What is it ?

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Forms 471 are reviewed by Program Integrity Assurance (PIA) for compliance with program rules concerning areas such as:

• Competitive bidding process• Contracts• Discount Calculation• Sufficient Budget• Establishing Form 470• Technology Plan & CIPA

PIA Review (Changes 2010)

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Initial & Final Review• Applications always start in Initial Review• Initial Reviewer from regular and/or heightened scrutiny team contacts

the applicant with questions• Final Reviewer reviews the Initial Reviewer applications. If the Final

Reviewer finds an issue with the review of the application, the application is returned to the Initial Reviewer to make corrections.

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

PIA Review (Changes 2010)

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(Pre-Commitment Corrections)Examples:• Entered the incorrect amount (i.e., data

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

on the Form 471• Selected the wrong category of service• Submitted an unsigned contract to PIA• Omitted an FRN

Clerical Corrections

PIA Review – Know Your Rights

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• At the end of the review, your reviewer must give you an opportunity to respond to any reductions or denials

• Applicants can cancel or reduce funding requests as a result of PIA-detected errors

• Applicants can “split out” services or entities into separate (new) funding requests.

E-Rate – PIA Review

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

information requests• Make sure your answers respond completely to the

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

Check the 471 Application Status Tool (SLD website)

Form 471 Status Check Selection Criteria

PIA Review – If you don’t comply – you will be denied.

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68SLD Training Presentations FY2010

DenialsTip Sheet

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69http://www.usac.org/_res/documents/sl/pdf/tip-sheets/common-applicant-errors.pdf

E-Rate Approval & Acceptance!

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• You will receive an FCDL (Funding Commitment Decision Letter)

– cover page of important reminders– reports status of individual funding requests:

o fundedo not fundedo as yet unfunded (Priority 2 requests)o cancelled

– may receive more than one FCDL

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E-Rate Approval & Acceptance

ALWAYS Appeal a decision you don’t agree with

Call Hotline for assistance

E-Rate Form 486

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E-Rate Form 486 – Certifications Required

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

• Certifies that Tech Plan (if required) is in force and meets program requirements.

• Certifies that CIPA is in force and meets requirements.

E-Rate Form 486 Deadline

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• 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 FCDLwhichever is later.

• If the Form 486 is late, the date 120 days before the Form 486 online filing or postmark date will become the start date for discounted services and funding may be reduced.

E-Rate Implementation Deadlines

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Service delivery deadlines• Recurring Services (June 30)• Non-recurring Services (September 30)

For Priority 2 - you can request extensions – but must be requested before deadline.

KANED 486 2008

E-Rate Reimbursements

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Don’t Stop Here – you have to ask for the money• Applicants must use SPI (Service Provider

Invoicing) or BEAR (Billed Entity Application for Reimbursement) process to actually GET THE MONEY.

• Contact your vendor

BEARs vs Discounts

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• BEAR (Billed Entity Applicant Reimbursement) Form 472 is filed by the applicant and certified by the service provider after the applicant receives services and pays for the services in full.

• DISCOUNTS (SPI Service Provider Invoice) Form 474 is filed by the service provider after providing services and billing the applicant for its non-discount share.

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

• 120 days after the last date to receive service OR• 120 days after the date of the 486 NL

INVOICE DEADLINE IS 10/28/2010

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• If you need more time to invoice, file an invoice deadline extension request

– Requests for extensions must be postmarked or received by USAC as soon as possible after the last date to invoice

– USAC provides for the extension of invoice deadlines under certain conditions, such as

• Authorized service provider changes • Authorized service substitutions • USAC errors (for example, in data entry) that

ultimately result in a late invoice • Circumstances beyond the service provider’s control

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KS Unclaimed Funds as of 10/27/10

Unclaimed Commitments can still be recovered!

KS Unclaimed Funds

471 Application

Number FRN BENApplication

Type

Service Provider

NameLast Date to

Invoice

Orig Category of

Service

Cmtd Commitment

RequestInvoicing

ModeTotal Auth

DisbursementPercent

Disbursed671008 1831458 137625 DISTRICT Blue Valley Tele-Communications, Inc.10/28/2010 INTERNET ACCESS $7,613.08 NOT SET $0.00 0%662915 1835808 137862 DISTRICT Southwestern Bell Telephone Company10/28/2010 TELCOMM SERVICES$7,524.00 BEAR $0.00 0%666784 1820501 137740 DISTRICT Kansas Number 15 Limited Partnership dba U.S. Cellular10/28/2010 TELCOMM SERVICES$1,213.63 NOT SET $0.00 0%666784 1820511 137740 DISTRICT Craw-Kan Telephone Cooperative, Inc.10/28/2010 INTERNET ACCESS $1,125.18 NOT SET $0.00 0%666784 1820485 137740 DISTRICT Craw-Kan Telephone Cooperative, Inc.10/28/2010 TELCOMM SERVICES$13,859.33 NOT SET $0.00 0%668213 1824314 225144 DISTRICT Embarq - United Telephone Co of Kansas FKA Sprint10/28/2010 TELCOMM SERVICES$16,376.31 NOT SET $0.00 0%656336 1815806 137609 LIBRARY Embarq - United Telephone Co. - Eastern Kansas FKA Sprint10/28/2010 INTERNET ACCESS $3,600.00 NOT SET $0.00 0%656336 1796741 137609 LIBRARY Embarq - United Telephone Co. - Eastern Kansas FKA Sprint10/28/2010 TELCOMM SERVICES $485.93 NOT SET $0.00 0%670681 1830417 147420 LIBRARY Embarq - United Telephone Co. - Eastern Kansas FKA Sprint10/28/2010 TELCOMM SERVICES $298.58 NOT SET $0.00 0%661988 1852220 138202 LIBRARY The Pioneer Telephone Association, Inc.10/28/2010 INTERNET ACCESS $1,045.92 SPI $81.60 8%694394 1905993 137671 LIBRARY Twin Valley Telephone, Inc.10/28/2010 INTERNET ACCESS $411.12 BEAR $32.24 8%680919 1861713 138107 DISTRICT Wilson Telephone Company, Inc.10/28/2010 TELCOMM SERVICES$5,133.74 SPI $1,238.45 24%658715 1853438 138025 DISTRICT Twotrees Technologies10/28/2010 INTERNET ACCESS $7,776.00 BEAR $1,944.00 25%661348 1845230 138058 LIBRARY The Golden Belt Telephone Association, Inc10/28/2010 TELCOMM SERVICES $597.24 SPI $288.48 48%694394 1905996 137671 LIBRARY Verizon Wireless10/28/2010 TELCOMM SERVICES $561.41 BEAR $274.56 49%654409 1792932 137904 DISTRICT SKT, Inc. 10/28/2010 INTERNET ACCESS $14,364.00 BEAR $7,182.00 50%

E-Rate Form 472 - BEAR

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E-Rate Changes – Form 500

• Change FRN Start Date

• Contract Extensions

• FRN Reductions

• FRN Cancellations (Unused Funds)

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E-Rate Changes Form 500

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• Required to make changes to Funding Requests• Service Start Date• Contract Expiration Date• Amount of Funding (reductions only)

• No ONLINE version (yet) – must print / fill out / mail

E-Rate Changes – Stuff Happens…

• You must notify SLD of any changes in the services that have been approved• FRN Implementation Extensions – you need more time

to implement a Priority 2 project• Service Substitutions – you change your Internet from

a DSL line to a T1 line• SPIN Changes – your ISP goes out of business and you

need a new provider• There are standard SLD processes for all of

these (and more)• Examples and assistance at SLD website or ask

for help.

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Service Substitutions

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• Use if you change (buy) anything that varies from what you described on your 471 & Item 21

• No FORM, just follow instructions • File Online using “Submit a Question” • Depending on specifics, may not need to wait for approval

Service Substitutions - Schools and Libraries - USAC

SPIN (Service Provider ID Number) Changes

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• If you change Vendors from your 471• CORRECTIVE vs OPERATIONAL• No FORM, just follow instructions• File online using “Sumbit a Question”• Usually approved in a few weeks• Vendors will be notified

Much Tighter Rules in 2011

(SPIN) Change Guidance - Schools and Libraries - USAC

Record Retention – “if it isn’t written down it didn’t happen”

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• Setup an electronic and paper file for each funding year

• Make a checklist of included items

• Make a spreadsheet across years

• Monitor at least monthly

• Build an E-Rate Binder

Record Retention – USAC Guidance

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– Downloadable Table of Contents Guide– Downloadable Table of Contents (Word

document preformatted for Avery© Ready Index 10)

– Located in USAC web site Reference Area

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

E-Rate Binder Electronic - Example

Appeals

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• USAC decisions can be appealed to USAC or to the FCC.• Generally, appeal first to USAC.• Can appeal to the FCC if USAC denies.

• Can be filed electronically or on paper.• Must be filed within 60 days of the USAC decision.• Requests for waivers of rules must be filed with the FCC.

File an Appeal - Schools and Libraries - USAC

89

Appeals Checklist

http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-appeals-checklist.pdf 89

Audits – Why me?

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• Applicants and service providers certify and agree to be audited for up to five years – from end of service.

• Some are random.• Some are not (whistle-blower complaints).• You will receive advance notice of the audit• Auditors can be from USAC, the FCC or external

auditors

Understanding Beneficiary Audits - Schools and Libraries - USAC

Changes for Year 2011

• More Focus on School Closings & Mergers• Changes to Audit and Review

• “Heightened Scrutiny Reviews”• PQA (Payment Quality Assurance) Audits• More detailed Compliance Audits• Cost Effectiveness Review

• Impact of Broadband Stimulus still not known

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Audit Results

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• Findings• An internal control or other observation that is not a

program rule violation.• Exceptions

• A program rule violation. This can result in reducing committed amount or return of funds.

• COMAD = Commitment Adjustment• RIDF = Recovery of Improperly Disbursed Funds

Any results can be appealed

Audit Results

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Non-compliant Process


(Audit Response)

• Entity is deemed Adverse (non-compliant) based on the auditors opinion of the applicants assertion that they complied with program rules

• USAC holds all pending funding & invoices• USAC issues letter to applicant requesting

revised procedures to mitigate audit findings• Applicant has 6 months to respond to letter

Audit Results

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Non-compliant Process


(Audit Response)• Applicant revises relevant procedures to ensure audit findings don’t recur

• USAC reviews response – Applicant responds and USAC accepts

revisions• USAC releases held funding

– Applicant fails to respond in time• Pending funding requests are denied• Pending invoices are denied

Audit Preparation

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• Make sure that your documentation is in order. See website for complete list of documents that you should have available to support your applications.

• Make sure that your physical inventory lists are in order so that you can quickly identify equipment

• Financial records – including cancelled checks - will be required

Final Tips

• Document everything• Email yourself• Build and retain an “E-Rate Binder”• Plan for eventual audit

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FY 2011 Window

471 Filing Window:

opens at noon (EST) on ????

closes at 11:59pm (EST) on ????

LAST DAY FOR Form 470 is ????

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More Resources

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EDLINC (Education & Library Networks Coalition): http://www.edlinc.org/

Funds for Learning: http://www.fundsforlearning.com/content/blogcategory/0/89/

E-Rate Central: http://www.eratecentral.com/

SLD Home Page: http://www.usac.org/sl/

99

Information & AssistanceKansas E-Rate Support Hotline

866-372-8302 Our Goal: Answer all questions – escalate or provide

references and contacts as required.

Resources include:SLD and affiliated agencies & hotlinesKan-ed: Jerry Huff ([email protected])Kan-ed: Don Brown ([email protected])Kansas State Dept of Ed: Melinda Stanley ([email protected])State Library of Kansas: Jeff Hixon ([email protected]) 99

100

Information & AssistanceE-Rate Support Hotline

We Can Provide Advice on: SLD forms 470, 471, att 21, 486, 472, 500 Eligibility of goods, services and locations

How to prepare a SPIN change letterHow to prepare a Service Substitution letterStrategy for writing an appealWhen to file an invoice extension request

We Cannot:Prepare, complete or submit FCC formsAct on behalf of an entity

100

Information & Assistance

BTU Consulting, LLC

Toll Free Support Hotline – 866-372-8302Website: http://www.btu-consultants.com/KS_Erate_Services.html

Email to:

Carol Underriner: [email protected]

Lori Thompson: [email protected]

Don Dietrich’s email: [email protected]

Don Dietrich’s Cell Phone: 314-378-1667

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Questions & Evaluation Oct

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