E-Rate requires ongoing attention

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E-Rate Update
Fall/Winter 2013
Rex Miller
Introduction
E-Rate requires ongoing attention
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Today’s session is focused on the E-Rate filing window and approval
process
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Seek out experienced assistance
• Some errors are still difficult to correct
• Contradiction leads to denial
• Get it right the first time
Filing season is near – key items to note:
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Deadline – just set this week – March 26, 2014
Q&A
• At the end of the presentation
• ENA is available at your convenience
ENA Background
Customer service and education focus
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K-12 customized service
E-Rate expertise
• E-Rate Program Service Provider since Year 1 (1998)
Experienced E-Rate team
• Rex Miller, April Scott, Kris Vivrette, Madeline Dusenberry, Ward
Chaffin
E-Rate Service Provider Leader
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A Top-10 E-Rate Service Provider
Over $500M in E-Rate funded
$130M+ in 2013 E-Rate filings
E-Rate in a Slide
$2.3 Billion Technology Matching Program
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Run by FCC and its “agent” SLD
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Paid for by Universal Service Fees – not by Congress
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Administered differently than other education programs – more like IRS audit
Eligible service to eligible sites for eligible users
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Priority 1 – Telephone and Internet
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Priority 2 – Internal Connections/Basic Maintenance
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Schools, Libraries and Admin Sites can be eligible
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Typically K-12 students, teachers and admin
Annual application process
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Technology Plan may be required as starting point if P2 funds requested
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Open procurement run by state/local
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Annual funding form (471) listing amount, vendor and matching %
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Matching % based on Free/Reduced Lunch info
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Detailed forms and deadlines required every step of the way
Funds Flow – reimbursement (BEAR) or vendor discount (SPI)
Documentation – if not kept, funds can be denied or revoked/recovered
E-Rate Annual Timeline - Recurring
Fall
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Winter
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Spring
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Update Technology Plan (if needed)
Do procurements for new services if needed (form 470)
FCC updates Eligible Services List
FCC sets application deadline
Complete Funding Application (471) by deadline – March 2014
Begin responding to Application questions (PIA)
Get Tech Plan Approval Letter (if needed)
Receive Funding Commitment (FCDL)
File Service Start and CIPA Compliance Form (486)
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Required before vendor can bill SLD
Summer
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Complete installation of new services
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Begin receiving bills for services – continuing
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Begin filing reimbursement forms (BEAR 472) if applicable
E-Rate News
Window dates have been set
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Opening January 9, 2014
Closing March 26, 2014
Similar to last year
Growth in Priority 1 funding requests
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Rising above funding cap
Funding reforms/ConnectED/E-Rate 2.0/NPRM
 Lots of ideas – unlikely to impact ’14-15
Still enough funds for P1 – but getting tight
P2 funding unlikely to be available – or only 90%
Eligible Services List issued for ’14-15
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Very little change from ’13-14
Web hosting – eligibility of ancillary components
Dark vs. lit fiber – construction charge eligibility
SLD Training Topics
FCC Appeal Order related to RFPs:
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Relates to 470s that do not have an RFP (box not checked)
If any additional information is made available only to entities that contact the
applicant, the FCC may deem that to be an “RFP”
If you have an “RFP” and do not check the RFP box on the 470, you will be denied
funding
This is a difficult area for many districts as “RFP” typically has a very specific meaning
in local/state procurement law
Best practice: consider the term “RFP” on the 470 to mean any written information
describing services to be procured that is not included on the 470
 If you are providing interested vendors with additional information – via your
website or a written document – check the RFP box to protect yourself
 If you only have conversations with those that call or e-mail, you are likely OK
Use of multiple providers – application of cost-effective rule
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Applicants cannot award an RFP to multiple providers for the same service at different
costs
SLD has indicated that using multiple providers for services such as web hosting or
cell phone service might be considered ineligible
E-Rate Tips and Notes
E-Rate requires ongoing attention
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Consider the cost/benefit of how your district does E-Rate filings
• Do you have an internal expert on E-Rate? Is it the right person?
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E-Rate is only as good as the foundation
• Must follow rules for tech plan and 470/procurement to get funding
• If a procurement is canceled, cannot reuse original 470
• Need a new one!
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Don’t let your district be an island
• Seek out experienced assistance
• Some errors are still difficult to correct
• Contradiction leads to denial
• Get it right the first time
E-Rate Tips 2014
Open eligibility items
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Free devices with purchase of eligible service
 Cell phone is eligible if offered for free to public
 VoIP phone, laptop, handheld device, etc. – not currently eligible
 Separate NPRM issued – FCC intends to close this loophole
beginning ’14-15
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Wireless access points
 On-premise managed wireless access points currently ineligible
• Under further FCC review
• Mentioned heavily in NPRM
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Use of different technologies for same purpose creating E-Rate
inconsistency
E-Rate Tips 2014
Form 470
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New FCC guidance – applicants will no longer be penalized for choosing the wrong
Priority 1 category on their 470
 470 Form is changing
 Still need to select the right category on the 471 – Telecom or Internet Access
Flexibility is valuable – consider both P1 categories
If you want a multi-year contract, consistency is key
 Make sure your 470, RFP or other bid documents and contract are consistent
 Cannot add renewal options after initial 470/contract process
FCC Order – “and equivalents”
 Cannot list a brand name but can list “brand name and equivalents”
PIA review
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Remember to answer their specific questions
 Providing extra information creates more work for all parties
 The SLD must review everything you send them
Communicate in writing with PIA
 Phone calls have no record and can result in misunderstandings with SLD
E-Rate Rulebook Break
NPRM – Modernizing E-Rate
FCC issued very extensive NPRM with hundreds of topics about modernizing
the program
• Newly appointed FCC Chairman Wheeler is a new element to this process
Topics included:
• Broadband goals and measurement
• How to lower cost of service – with a presumption perhaps that schools
can’t
• Potential reset of priority system
• Potential development of separate fund to promote fiber ownership
• Consideration of eliminating E-Rate for voice service or traditional voice
service
• How to get more funding for internal connectivity to devices used at
schools – wireless access points, switches, etc.
• Program funding levels
• Discount matrix
• Streamlining program administration
• And many more minute details
NPRM – Modernizing E-Rate
FCC received over 1,000 different sets of comments and reply comments
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Many were one-pagers supporting increased funding or web hosting
Differing opinions on many levels in the comments
Some comments seemed to have universal support including:
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Delivery of BEAR payments direct to applicant
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Moving more E-Rate forms and information online
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Consideration of multi-year contract 471
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Streamline E-Rate processes to issue funding decisions quicker
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Retain flexibility of the applicant to select their provider
Given that the FCC has released the ESL for ’14-15, we do not expect the
NPRM to impact ’14-15
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Be alert for potentially dramatic changes for ’15-16
New Forms – 470 & 471
Changes to 470 and 471 are pending review by OMB
Form 470 – Combines Telecom and IA into one category
Form 471 – Block 2 data moved to Block 5 and focuses on broadband
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Information consistent with Item 21 Attachment
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Work with your service provider as needed to fill that information out
correctly
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Likely to be used like Item 21 Attachment in testing invoices
Form 471 – formally establishing that Item 21 Attachment is due by filing
deadline
FCC
Streamlining and Simplifying
Technology Plans
• New requirements apply for FY 2011 and beyond
• No longer required for:
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Still required for:
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Priority 1 (Telecom and Internet Access)
Priority 2 services (Internal Connections and Basic Maintenance of Internal
Connections)
ENA comment: make sure you keep your Tech Plan and Approval Letters
from prior years in case you are audited
Tips to Eliminate E-Rate Surprises
Make sure you have a solid E-Rate team – internal/external
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Staffing changes are key
 Make sure documentation is transferred
Consider an E-Rate update report with deadlines and plans – perhaps quarterly
E-Rate information requests – PIA, audits and other – develop consistent
process to evaluate, understand and reply with the district’s best answer
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Recognize that SLD role is to prevent ANY inappropriate release of E-Rate funding
Their role is not to help you get or use the E-Rate funds – different than other
programs
Gift rules tracking and compliance
Stay updated on approval status each year
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Don’t get surprised by a funding denial after the start of the service year
Procurement – make sure you are comfortable that the process is simple and
compliant and be ready for an audit
Documentation – make sure the files are complete and up to date
E-Rate rule updates need to be tracked and implemented in a timely manner
471 Timing
E-Rate Timing Soapbox
E-Rate continues the trend of the later closing of filing window in
March
Strongly encourage applicants who want to get approved before
July 1 to file their 471s as soon as possible
• Target mid-February at the latest
PIA will likely start for you before the 471 filing window is closed, so
be ready
Advantages
• Earlier approval
• No last-minute rush to file
• If you have an error, you can file another 471 before filing deadline
and cancel initial incorrect filing – probably easier than using RAL
process
Resources
Contact ENA
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Rex Miller – [email protected]
April Scott – [email protected]
Kris Vivrette – [email protected]
Ward Chaffin – [email protected]
Madeline Dusenberry – [email protected]
SLD News Brief – make sure your are signed up for these e-mails
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Go to the SLD website’s training section to sign up
Key info provided during E-Rate window and throughout the year
Websites
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SLD – main E-Rate rule site – training/WebEx
2013 fall training materials are available and valuable
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http://www.universalservice.org/about/tools/TrainingArchive/Default.aspx?div=3
www.universalservice.org/sl/
Happy Holidays & Happy E-Rate
Season!
Contact ENA Today
Rex Miller
[email protected] - 615.312.6000
www.ena.com
@ENAconnects ⎜ facebook.com/ENAconnects
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