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ARKANSAS
Work Group (AEWG)
WELCOME
This will be a quick overview of the E-rate activity for the summer followed by
an overview of the last 14 FCC’s General Resolution Orders
Year 10 (2007-2008)
• If you HAVE been funded….
• File 486 within 120 days after FCDL date.– Cannot file 486 until an FRN has been
funded.
• Contact vendors if you would like to receive discounted bills.
• Appeal within 60 days of FCDL date if you disagree with a decision.
Year 10 (2007-2008)
• BEAR deadline is October 28, 2007!– For recurring services – (Jan 28, 2008 for nonrecurring services)
• File Invoice Deadline Extension Request within 30 days if you missed deadline.
• Submit SPIN change requests by October 28.– Approval of SPIN change will give you an automatic
invoice deadline extension of 120 days.– Submit SPIN changes using “Submit a Question” on SLD
website.
• File Form 500 to release funding or cancel FRN
SPIN CHANGE• Corrective SPIN CHANGE
– A corrective SPIN change is a notification to USAC that the SPIN associated with a Funding Request Number (FRN) is not correct. This occurs when (1) either the applicant or USAC made a data entry error or (2) a change occurred that was not initiated by the applicant. Corrective SPIN changes include the following:
– Data entry errors made by the applicant or USAC when the Form 471 was submitted on paper or by the applicant when the Form 471 was submitted online. This includes entering the wrong SPIN on the Form 471 because you entered the SPIN for another provider or entering the wrong SPIN because your provider has multiple SPINs and you chose the wrong one.
– The original service provider has merged with, or been acquired by, another company and the SPIN indicated on the FRN has changed.
– Other instances when the SPIN indicated on the Form 471 changed when such change was not initiated by the applicant.
SPIN CHANGE
• OPERATIONAL SPIN CHANGE– An Operational SPIN change is a request to
change the service provider associated with an FRN. The change in service providers is the result of a deliberate decision by the applicant to change the service provider supplying the services for an FRN.
Split FRNs
• When service on single FRN is provided by two different companies in a single funding year.
• Accomplished by submitting Operational SPIN Change to SLD.– Must state beginning date and ending date for
each provider– Also include how much $ should be allotted to
each provider.
• 486 required for BOTH FRNs.
Data Retrieval Tool
• Most data on SLD website, using DRT• Download by state, by SPIN, by entity, etc• Updated nightly• Shows:
– Entity info / 471# / FRN # / 470 # / SPIN– if FRN funded– whether 486 was submitted– last date to invoice– original requested amount & committed amount– discount– invoice paid and by what mode– etc.
2 in 5 Rule for IC
• Determined on an entity basis (ie each school, library or NIF)
• 2006 is the second year for the rule• All entities on a Block 4 worksheet that received
a positive commitment for IC, are counted as taking a year– Can “erase” year if funding not used and Form 500
submitted to cancel FRN.
• If a school or library building received IC funding in 2005 and 2006, that school or library is not eligible again until 2010.
Document Retention
Documentation retention – five years from last date of service
• Training Material• Eligible Services List• Copies of:
– All forms– ALL bids and quotes – Contracts and agreements– Invoices– Payment record– All correspondence between applicant & service provider
• Service Provider selection process
FCC’s Notice of Proposed Rulemaking
• Released Notice of Proposed Rule Making (NPRM)– Asks for comments on sweeping changes
• Formula to Schools/Libraries?• What forms could be eliminated?• What else should be changed?
– Comments were due Oct. 18, 2005 with Reply Comments due Dec. 19, 2005http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
Enter “02-6” in the Proceeding to view all comments
• No action to-date
Recent FCC Decisions
We note that the primary jobs of most of the people filling out these forms include school administrators, technology coordinators and teachers, as opposed to staff dedicated to pursuing federal grants, especially in small school districts. Even when a school official becomes adept at the application process, unforeseen events or emergencies may delay
filings in the event there is no other person proficient enough to complete the forms
BISHOP PERRY
• The FCC recognized three types of errors that should not be cause for outright rejection of an application: – (1) immaterial clerical errors, – (2) ministerial errors, and – (3) procedural errors. Below are examples of
these all from the FCC decisions. The first three are general, followed by more specific examples
BISHOP PERRY• Failure to comply with minimum processing standards. • Failure to file a Form 470 or 471 in a timely manner. • Failure to timely file certifications related to a Form 470. • Clerical errors on the part of applicants who inadvertently left portions of the Form 470 or Form
471 blank or made minor errors while completing the form. • Technical problems, either with applicant's equipment or while interfacing with the SLD's online
filing system, and thus failed to properly file electronically. • Rules and instructions for filing a Form 470 or Form 471 are vague and unclear. • Denial for filing outside the Form 471 filing window when applicant maintains they submitted the
relevant information on time and it is difficult to determine whether the error was the fault of the applicant, USAC or a third party.
• Applicants' staff made a mistake that prevented them from filing on time or inadvertently failed to file the application forms in a timely manner.
• Applicants had an emergency situation and were unable to comply with the filing deadline due to staff illness or relatives of staff members who were ill.
• Failure to file a Form 471 in a timely manner due to circumstances beyond the applicant's control, such as school reorganizations or inclement weather.
• Denial of funding for applications because their FCC Forms 470 were not certified or not certified before the close of the filing window.
• Hardship or impact on the applicant's) should be considered when analyzing whether a given application should be funded or rejected
Recent FCC Decisions
ORDER COMMONNAME
DATE TOPIC
FCC 06-54 Bishop Perry 05/19/06 Clerical & Ministerial Errors
FCC 06-55 Pattern Analysis 05/19/06 Form 470 Similarities
DA 06-1642 Academia Discipulos 08/15/06 Bid Assessments
DA 06-1871 Alaska Gateway 09/14/06 Form 486 Deadline
DA 06-1907 Academia Claret 09/21/06 Discount Rate Justification
DA 07-1180 Academy for Academic Excellence
03/09/07 Form 471 Filing Deadline
Recent FCC Decisions
ORDER COMMONNAME
DATE TOPIC
FCC 07-35 Adams County 03/28/07 Contracts
FCC 07-36 Alpaugh Unified 0328/07 PIA Responses
FCC 07-37 Brownsville 03/28/07 Technology Plans
FCC 07-60 Academy of Excellence
05/08/07 Required Resources
FCC 07-61 Aiken County Public Schools
05/08/07 30% Rule
FCC 07-62 Bootheel Consortium 05/08/07 Ineligible Entities
FCC 07-63 Aberdeen School District
05/08/07 28-Day Posting
DA 07-2111 Brewster Academy 05/18/07 Eligible Telecom Provider
FCC Office of Inspector General Issues Report
• Technology Plans– Beneficiary did not have an approved technology
plan, technology plan was outdated, etc.
• Ineligible Items– Beneficiary was reimbursed for ineligible products or
services.
• FCC Form 500– Beneficiary did not submit a Form 500 to USAC when
the commitment was not fully utilized.
FCC Office of Inspector General Issues Report
• FCC Form 472/474 Items– Errors in amounts for reimbursement,
inadequate support, etc.
• Children’s Internet Protection Act– Beneficiary did not comply with the Children’s
Internet Protection Act.
FCC Office of Inspector General Issues Report
• Technology Budget– The beneficiary did not have proper approval for its
budget or an adequate amount budgeted for its share of the non-discounted costs.
• Equipment– Equipment missing, not installed, no asset lining
maintained, etc.• Discount Calculation
– Beneficiary incorrectly calculated its discount percentage, could not support the discount, or could not provide documentation to verify information on the FCC Form 471.
FCC Office of Inspector General Issues Report
• Service Provider Billing– Bills not properly prepared or inaccurate.
• Document Retention– Beneficiary did not maintain the required
documentation or documentation was non-existent.
RESOURCES
• Schools and Libraries / USAC web site
• Client Service Bureau
• Use the “Submit a Question” link on the web site
• Fax toll-free at 1-888-276-8736
• Telephone toll-free at 1-888-203-8100
• Form instructions
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RESOURCES
AEWG E-rate website: www.asl.lib.ar.us/arerate/index.htm
AEWG E-rate list serve: http://list.state.ar.us/mailman/listinfo/e_rate
orsend a message with the word `help’ in it to the request address, [email protected]
Arkansas ContactsWilma Toombs, ADE –501) 682-1286 or [email protected] Becky Rains, DIS – 501.682.4003 [email protected]
Questions?
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