Funding Year 2013: Completing form 470

Funding Year 2013:
July 1, 2013-June 30, 2014
2013-14 School Year
Topics for today’s session
1. What online resources will assist me in Erate?
2. What is the purpose of form 470?
3. Form 470: Common errors made in filing
4. What’s new with the E-rate program in 2013?
5. Commonly asked questions
6. Form 470: We’ll walk through the online
Numbers to remember
• SLD Client Service Bureau
– 1-888-203-8100
• Pam Jacobs (schools and districts)
– 515-975-0071
– [email protected]
• Jay Peterson (public libraries)
– 515-281-4499
– [email protected]
Online resources
• Actual online filing:
• Funding commitments/disbursements:
• Iowa E-rate information
What is the purpose of form
What is the purpose of form 470?
• To open the competitive bidding process for
the E-rate services you seek.
• This form is required prior to filing form 471.
• There is a required 28-day “waiting period”
between form 470 filing and 471 filing.
E-rate Timelines
Complete an E-rate tech plan (required if applying for priority
2; not required if only filing for priority 1)
2. Form 470 (File any time between now until mid- January)
3. Develop a bid evaluation matrix and accept bids
4. Wait at least 28 days after filing form 470 to complete the
bid matrix and select service provider(s)
5. Select provider and sign contract (if applicable)
6. Form 471 (deadline is March 14 at 10:59 p.m. CT). Form 471
is often called “the application”
7. Answer questions/call from PIA (March-?)
8. Funding commitment decision letter
9. Form 486
10. No discounts on bills? File form 472/BEAR form
Do I file form 470 every year?
Do I have to file a form 470 every year?
Yes, if you are applying for month-to-month services,
you must file form 470 every year.
Yes, if you want to sign a new contract, you must file a
form 470.
No, if you have an existing multi-year contract that
meets certain conditions (more info is provided later
in this presentation)
Form 470: How many separate 470
forms to file?
Your choice!
• You may file one form 470
• You may file a separate form 470 for each type
of service
• Recommendation: If you are applying for
internal connections or basic maintenance, file
a separate form 470 for these priority 2
Common Errors in filing form 470
Form 470: Common errors made in
Error 1: Applicant doesn’t wait
the full 28 days before
choosing a service provider or
signing a new contract
FIX: Wait at least 28 days!
Form 470: Common errors made
in filing
• Error 2: Applicant does not properly keep
record of the bid evaluation process.
• Fix: (See the following slide for guidance).
Bid evaluation process
SLD is getting more particular about
documenting a fair and open bidding process
1. Have a written process for evaluating bids and criteria for
selection prior to selecting your provider and signing a
2. Keep a record of bids received!!! (not just the winning bid).
3. Complete your bid evaluation document, even if you just
received one bid. Be sure to wait at least 28 days after filing
form 470 to complete the bid evaluation process.
4. Date the completed bid evaluation document to show you
waited at least 28 days to make your vendor selection.
Competitive Bidding
Bid Evaluation Matrix (sample)
Points Available Vendor 1
Vendor 2 Vendor 3
Price of the ELIGIBLE goods
and services
Prior experience w/ vendor
Prices for ineligible services,
products and fees
Flexible Invoicing: 472 or 474
Environmental objectives
Local or in-state vendor
Must I accept the lowest bid?
• No, not according to e-rate rules…but cost must be
the primary consideration
• Other factors might be prior experience of vendor,
qualification of personnel, financial stability of the
company, service that meets the needs of your
school/library, in-state preference, willingness of the
vendor to give discounts on bills
May we sign a contract?
• Yes, but only after the “allowable
contract date” of 28 days following the
posting of form 470
• Include contingency language in case you
don’t get funded, especially for internal
What if we already have a contract for 1314 school year?
• Did you already file form 470 in a previous year “establishing”
this contract? (If you’re not sure your 470 qualifies to
“establish” a multi-year contract, contact me and I’ll check it
over with you).
• Did the “establishing” form 470 accurately describe the
services and bandwidth for the contract?(especially important
if you plan to increase bandwidth for 2013-14 school year)
• Does the contract cover ALL of 13-14 school year?
If all above statements are true, you do not need to file form 470
for this service. You will have to file form 471 in order to get
Form 470: Common errors made in
Error 3: Not enough quantity and/or capacity
requested for telecommunications services
and/or Internet
FIX: Don’t limit your capacity. Use words like
“no less than 8 cellular phone lines” or
“minimum of 3 mbps”. Avoid using words
like “8 phone lines.”
Form 470: Common errors made in
Error 4: Form 471 requests services not listed on
form 470 (forgot some services on form 470)
FIX: You may file more than one form 470 (but
must wait 28 days before selecting a service
provider and signing a contract)
What’s new for E-rate funding
year 2013?
What’s new for E-rate funding year
New item 1: Have the form 471 deadlines been set?
• The form 471 “window” will open at noon (ET) on
Wednesday, December 12 and close on Thursday,
March 14 at 11:59 (ET).
• To meet the 28-day waiting period between filing
form 470 and filing form 471, it is recommended that
you file form 470 no later than mid-January
(although the absolute last day to file form 470 is
February 14).
What’s new with E-rate for the 2013
funding year?
New item 2:
– Priority One services are consolidated into one list.
– Priority One services are no longer separated by
regulatory category (Telecommunications Services,
Telecommunications, and Internet Access).
– On form 470, priority 1 services may be filed either
under “Telecommunications Services” or “Internet
Access” or in both categories.
Commonly asked questions
Commonly asked questions
• What are the requirements for the Children’s
Internet Protection Act (CIPA?)
• What about “off site” Internet access?
• What should we know about gifts and
donations from service providers?
• How can I correct errors on forms 470 or 471?
• What can I do to get ready for funding year
What are the requirements for the
Children’s Internet Protection Act?
Children’s Internet Protection Act
CIPA reminders: The following are already
required if requesting discounts on Internet
and/or internal connections:
1. Internet safety policy
2. Public notice of – and public meeting or
hearing on – the Internet safety policy
3. Technology protection measure (filter)
Children’s Internet Protection Act
CIPA (applies only to districts/schools/AEAs)
By July 1, 2012, you should have amended your
Internet safety policy to provide for monitoring of
online activities of minors and the education of
minors in appropriate online behavior, including
interacting with other individuals on social
networking sites and in chat rooms, cyberbullying
awareness and response.
CIPA change
Your school/district/AEA is not required to have
a new public notice and hearing for this policy
change (assuming you have record of previous
If you don’t have a record of the public notice
and hearing for the original establishment of
the Internet safety policy, it is recommended
that you refresh the record by posting public
notice and holding a public hearing.
CIPA reminders
Your school/district/AEA does not have to buy
an Internet safety student curriculum!
There are plenty of great/free online resources.
Also see Common Sense Media (requires free online
CIPA reminders
Local school and library authorities must
determine what matter is inappropriate for
Social networking sites are not automatically
considered harmful to minors.
Put into local policy how your school or library
locally interprets the requirements and make
sure your implementation aligns with the
policy. (Do what you say you’re going to do).
CIPA reminders
The following is not yet determined by FCC.
Public comment likely to be sought on the
following type of question:
Do CIPA requirements apply to the use of
portable devices owned by students and
library patrons when those devices are used in
a school or library to obtain Internet access
funded by E-rate?
CIPA reminders
Keep some sort of documentation to show
filtering/technology protection measure is in
place (e.g. bill from vendor of filtering
software; sample of a couple computer logs
showing filtering, etc.)
(Schools/districts/AEAs only): Keep some sort of
documentation that the education of minors
occurs (e.g. copy of the curriculum used;
sample lesson plan from teachers, etc.)
CIPA resources
For a detailed discussion of CIPA requirements for Erate, see the following:
Children’s Internet Protection Act
Form 486 Instructions
Form 479 Instructions
What about E-rate supported
“off site” Internet access?
What about “off site” Internet
Question: May our district or school provide Erate supported Internet access for students to
use at home? (e.g. wireless access)
Answer: No. If you provide E-rate supported
Internet access “off site,” then the cost of the
service must be pro-rated in your E-rate funding
4-pronged test for E-rate Eligibility
Requirements for eligibility:
– Must be an eligible product or service
– Used by an eligible entity
– Used at an eligible location
– Used for an eligible purpose
What should we know about gifts
and donations from service
Gifts and Donations
• Receipt or solicitation of gifts by applicants
from service providers (and vice versa) and
potential service providers is a competitive
bidding violation.
• Service providers may not offer or provide any
gifts or thing of value to applicants personnel
involved in E-rate.
Gifts and Donations
• Gift rules apply to everyone participating in
the E-rate program, whether public or private,
and whether operating at the local or regional
• Gift prohibitions are applicable year-round,
not just during the competitive bidding
Gifts and Donations
• Gifts or prizes received at conferences are
exempt from the gift rules only when such
conferences are open to the public (for free)
or meet narrowly-defined conditions as
“widely attended events.”
E-rate applicants who are not yet concerned about the gift rules might do well to
reflect on a recent FCC filing on behalf of the East Central Board of Cooperative
Educational Services (“ECBOCES”) which included the following point: ECBOCES
believes that it is because ECBOCES employees accepted gratuities that total no
more than $674 over a five-year period, USAC rescinded funding for FY2006,
FY2007 and FY2008, and denied funding for FY2009 and FY2010 in the aggregate
amount of $3,370,018.77.
Gifts and Donations
See the following for more details
• Federal Gift Rules - 5 C.F.R. § 2635.201-205
• USAC training slides on program compliance (slides 41-66)
How can I correct errors on forms
470 or 471?
Ministerial and clerical errors
What if I make a mistake on a form?
• Error on form 470? If you discover the error early (like in
November, December, January), file a new form 470 and
ignore the one filed in error. Remember to wait 28 days after
filing the new/replacement to select vendor(s).
• Corrections to 470 and 471 can be submitted until the funding
commitment decision letter is issued (if you discover the error
after application window closes)
• If you made an error and your PIA review has already started,
tell your reviewer right away that you made an error
More on ministerial and clerical
If you find you made an error and need
assistance to get it corrected, contact Pam
(schools/districts/AEAs) or Jay (libraries)
What can I do to get ready for
funding year 2013?
What can I do to get ready for
funding year 2013?
• Do you have/will you have new buildings?
• Have you closed any buildings? Will you have
buildings closing in 2013-14 school year?
• Are buildings changing their purpose? (e.g. once
were attendance centers and now are for purposes
such as admin offices)
• Have you reorganized with another district? (or will
you reorganize for 2013-14?)
• Have you formed a “system” (non-publics)?
Names of school buildings
Want to speed up your 2013 application review?
• Take a look at the Iowa Educational Directory for the
2012-13 school year Note the names of your
buildings (and district/system) in the Directory
• If changes need to be made for 2013-14 school year,
notify USAC.
• Notify me of changes as well ([email protected])
Contact USAC
Call the USAC Client Service Bureau to notify
them of changes to building names, contact
person information, corrections to building
addresses, etc.
They may request the information in writing on
school/district/library letterhead
Completing the form 470
Form 470: What’s eligible for funding?
See the 2013 Eligible Services List at
Examples of Priority 1 services
Local telephone services
Long distance telephone service
Cell phone service
Text messaging on cell phone
Cellular data service/Internet access
(Smartphone type service)
More examples of P1 services
• Centrex
• Leased circuits (e.g. data circuit to connect
your elementary school to the high school)
• E-911 and 911 lines
• Voicemail service
• Leased dark fiber
More examples of P1 services
• Internet access
• Wireless Internet access (via wireless
• Domain Name Service (DNS) registration
• Webhosting (usually not entirely E-rate
• Firewall service if included as a part of
bundled Internet service (not purchase of
firewall software)
What about Priority 2 services?
• NOTE: Internal connections is the only
category where items may be purchased by
• NOTE: Tech plan is required for all priority 2
• 2 in 5 rule applies for internal connections (an
eligible location may only receive E-rate
funding every 2 years out of 5)
Examples of P2 internal
Network servers
Wireless LANs/wireless access points
PBX (private branch exchange)
See ESL for more examples and details
Priority 2 Internal connections
Internal connections examples
Basic maintenance of internal
• Should I apply? Yes, if you plan to have a
third party provide maintenance of
internal connections
• 2 in 5 rule does NOT apply for
maintenance (even though this is priority
Basic maintenance of internal
• Support for basic maintenance of eligible
internal connections (BMIC)
• Such as:
– Repair and upkeep of hardware
– Wire and cable maintenance
– Basic tech support
– Configuration Changes
Basic maintenance of internal
• Agreements or contracts must state the
eligible components covered, make, model
and location
• Service must be delivered within the July 1st to
June 30th timeframe
Basic maintenance of internal
• Applicants may make estimates based on:
– Hours per year of maintenance
– History of needed repairs and upkeep
– Age of eligible internal connections
• Applicants using the factors listed above must
submit a bona fide request
• It is not reasonable to estimate an amount
that would cover the full cost of every piece of
eligible equipment.
Check out e-rate applications from
previous years
• Dig out last year’s 470 and 471 forms
• Don’t limit yourself in bandwidth and
services (think ahead)
Form 470: Block 1
– Item 5c: “Number of Eligible Entities for which
services are sought” (How many buildings,
including locations like bus barns, that will receive
any E-rate services?)
– Item 7: Do not attempt to complete this. This
item is only completed by a paid consultant who is
filing on your behalf.
Discount Matrix
Percent of
Eligible Students
Less than 1%
1% - 19%
20% - 34%
35% - 49%
50% -74%
75% -100%
Iowa counties which are urban:
Black Hawk
Online filing
Should I e-certify?
• E-certify an option only if
– Your principal/supt/authorized person filed a
signed and data entered 471 and/or 486 in
previous year(s)
– Call SLD’s Client Service Bureau if you need a pin
number (888-203-8100)
– Special Pins for BEARs-only (online BEAR
What if we can’t/don’t want to ecertify?
• Print certification/signature page (as directed
on form 470)
• Have supt/director/authorized person sign
• Still recommend you use blue ink
• Mail certification/signature page with return
If you don’t e-certify
• Use the certification page from
the online filing
• DON’T just copy the cert page of
the mail-in version
Final steps:
• Print and/or electronically save a copy of the
completed 470 for your files
• Photocopy your cert page (if paper cert)
• Keep the completed copy in e-rate
notebook/files (electronic copies are fine)
• Check to see if
your form really was posted
How do I know my 470 was filed?
• 2 ways to check
– You will receive a receipt in the mail! Keep
the receipt letter (on pink paper for 2013)
Why should I check about filing?
• To check the “allowable contract
date”…this is the earliest date you may
file form 471!
• Don’t pick a service provider before the
28 days is up!
Are you on the helpful E-rate
• [email protected] (primarily for
schools/districts and libraries). Send
Debbie Wineland a message
[email protected][email protected] (primarily for
libraries). Sign up at the url or
contact Jay Peterson.
Numbers to remember
• SLD Client Service Bureau
– 1-888-203-8100
• Pam Jacobs
– 515-975-0071
– [email protected]
• Jay Peterson
– 515-281-4499
– [email protected]