TOM TORLAKSON State Superintendent of Public Instruction E-rate for California Beginner Applicants Beginner’s Presentation I 2013 California Department of Education 1 General Information about E-rate E-rate Organization TOM TORLAKSON State Superintendent of Public Instruction • Federal Communications Commission (FCC), an independent U.S. government agency, oversees the E-rate program – Universal Service Administrative Company (USAC), a not-for-profit, administers the Erate program along with three other programs • Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-rate Beginner’s Presentation I 2013 California Department of Education 2 General Information about E-rate E-rate Rules TOM TORLAKSON State Superintendent of Public Instruction • The FCC sets rules and policies through orders – Policies are defined in the text of orders • USAC/SLD develops procedures for specific actions, such as how to process applications – USAC submits its procedures to the FCC for approval each year Beginner’s Presentation I 2013 California Department of Education 3 General Information about E-rate E-rate Timeline TOM TORLAKSON State Superintendent of Public Instruction • Commitments for E-rate are made by funding year (FY), which runs from July 1 through the following June 30 • USAC refers to the funding year as the year in which most services will begin – e.g., FY2013 is July 1, 2013 – June 30, 2014 Beginner’s Presentation I 2013 California Department of Education 4 General Information about E-rate E-rate Budget TOM TORLAKSON State Superintendent of Public Instruction • Commitments were capped at $2.25 billion for each funding year. • This cap started to be adjusted for inflation starting in FY2010, currently set for FY 2013 at $2.38 billion. • Once each year, FCC can roll over unused funds from previous funding years into the current funding year Beginner’s Presentation I 2013 California Department of Education 5 General Information about E-rate The role of CA Dept of Ed and State Library TOM TORLAKSON State Superintendent of Public Instruction CDE & State Library have no statutory authority to administer the federal E-rate program CDE & State Library only provide general information about the E-rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources Beginner’s Presentation I 2013 California Department of Education 6 General Information about E-rate TOM TORLAKSON State Superintendent of Public Instruction A Self-Certifying Program • Every form in the E-rate program contains specific certifications – Become familiar with these – Certify the form(s) ONLY if you can truthfully state you are in compliance with the certifications Beginner’s Presentation I 2013 California Department of Education 7 General Information about E-rate Navigating the Website TOM TORLAKSON State Superintendent of Public Instruction • E-rate website: www.usac.org/sl – The Process – The Forms and Instructions – Eligible Services List – Reference Area – Apply Online Beginner’s Presentation I 2013 California Department of Education 8 What is the NPRM & its Purpose TOM TORLAKSON State Superintendent of Public Instruction • NPRM = Notice of Proposed Rulemaking • Purpose: To give applicants and the public an opportunity to provide input to the E-rate program. “How to Improve it” • Why: First Catalyst: Program does not have enough funds for P2, and may have challenges with P1 • Time Line: Initial Comments were due Sept 16th, and Reply Comments were due Oct 16th. However, you can always send comments via the Ex Parte Process • More on E-rate 2.0 at the Intermediate Advance Training Beginner’s Presentation I 2013 California Department of Education 9 TOM TORLAKSON State Superintendent of Public Instruction Who Qualifies for the E-rate Program? Beginner’s Presentation I 2013 California Department of Education 10 E-rate Eligibility Schools TOM TORLAKSON State Superintendent of Public Instruction 1. Schools must provide elementary or secondary education as determined under state law. 2. Schools may be public or private institutional day or residential schools, or public charter schools. 3. Schools must operate as non-profit businesses. 4. Schools cannot have an endowment exceeding $50 million. Beginner’s Presentation I 2013 California Department of Education 11 E-rate Eligibility Pre-K and Adult Ed TOM TORLAKSON State Superintendent of Public Instruction 1. State law, in conjunction with E-rate rules, determines eligibility of Pre-K (i.e. Head Start), Adult Ed and Juvenile Justice 2. Reference the following for California eligibility: http://www.usac.org/sl/applicants/step01/n on-traditional-k-12/k-12-eligibilitytable.aspx Beginner’s Presentation I 2013 California Department of Education 12 E-rate Eligibility TOM TORLAKSON State Superintendent of Public Instruction Libraries 1. Libraries must be eligible for assistance from the California State Library administrative agency under the LSTA (Library Services & Technology Act) 2. Libraries must have budgets completely separate from any schools (including, but not limited to, elementary and secondary schools, colleges and universities). 3. Libraries cannot operate as for-profit businesses. Beginner’s Presentation I 2013 California Department of Education 13 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation E-rate Timeline Beginner’s Presentation I 2013 California Department of Education 14 E-rate Timeline: July 1 – June 30 TOM TORLAKSON State Superintendent of Public Instruction *These dates are estimates. In order to derive the Form 470 deadline, applicants must count backwards from the Form 471 deadline. **FCC announces Form 471 filing deadlines each Fall. Beginner’s Presentation I 2013 California Department of Education 15 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation E-rate Technology Planning Beginner’s Presentation I 2013 California Department of Education 16 Technology Planning Technology Planning TOM TORLAKSON State Superintendent of Public Instruction FCC Form 470 & RNL Competitive Bidding FCC Form 471 & RAL Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 17 Technology Planning Acronyms and Terms TOM TORLAKSON State Superintendent of Public Instruction • Four elements: the four required elements you must address in your technology plan starting in FY2013 (July 1, 2013) when applying for priority 2 services • Technology Plan Approver (TPA): the agency/person certified by USAC that approves your technology plan Beginner’s Presentation I 2013 California Department of Education 18 Technology Planning Purpose of the Tech Plan TOM TORLAKSON State Superintendent of Public Instruction • Tech plans ensure that schools and libraries are prepared to effectively use the requested services to integrate telecommunications and internet access into the educational program or library services that they provide to students. • Tech plans should support and validate all E-rate services applied for, especially Priority 2 services, Internal Connections (IC) and Basic Maintenance of Internal Connections (BMIC). Beginner’s Presentation I 2013 California Department of Education 19 Technology Plan Overview 1. FFC rules require an “approved” technology plan when receiving E-rate discounts for Priority 2 services. 2. Find your public charter, district or COE Tech Plan status at: http://://www.cde.ca.gov/ls/et/rs/ap/county.asp 3. Tech Plan must be “written” prior to posting Form 470. 4. DOCUMENT the existence of this “Written Plan” – i.e., Letter/E-mail from Cabinet, screen print of file name and date, and physical copy of plan. 5. Must cover all 12 months of the funding year (July 1 – June 30). 6. E-rate plans should not cover more than 3 years; tech plans that meet Erate requirements can cover 5 years with progress review during 3rd year. 7. Tech plans must include all services (both current and future) for which E-rate discounts are sought. 8. Must be approved by a “Certified Technology Plan Approver” See the Technology Plan approver locator tool on the USAC website: http://www.sl.universalservice.org/reference/tech/default.asp 10. Leverage the technology expertise of your CTAP regional assistance: CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation I 2013 California Department of Education 20 4 Required Elements of a Technology Plan Used for E-rate 1. Clear statement of goals and realistic strategy for using telecommunications and information technology to improve education or library services. 2. Professional Development strategy to ensure staff understands how to use technologies to improve education or library services. 3. Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services. 4. Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise. TOM TORLAKSON State Superintendent of Public Instruction Budget: No longer required in the tech plan but USAC will likely request this information during PIA or other application reviews. Best practice would be to put a budget with appropriate fund sources highlighted in your E-rate related documentation files. Beginner’s Presentation I 2013 California Department of Education 21 Technology Planning Tech Plan Submittal Dates TOM TORLAKSON State Superintendent of Public Instruction • The plans may be submitted for approval anytime but no later than: 1. Cycle A: November 30, 2013 2. Cycle B: May 31, 2014 Beginner’s Presentation I 2013 California Department of Education 22 Technology Planning “Must Do” Reminders 1. Must be “Written” prior to posting Form 470: – It must be documented that it is written before the posting of the form 470! (Applicant must document the existence of this plan, i.e., e-mail with plan attached, memo from cabinet level about the plan being written, including the date. “DATE STAMP.”) 2. Must include a sufficient level of detail and cover all services (priority 2) for which E-rate discounts are being sought on the Form 470(s) and subsequent Form 471(s). 3. Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier. 4. E-rate plans must be approved by a “USAC Certified Technology Plan Approver” see USAC link: http://www.usac.org/sl/tools/reference/tech/default.asp 5. Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp 6. Must include all four required elements. TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation I 2013 California Department of Education 23 Technology Planning Additional reminders TOM TORLAKSON State Superintendent of Public Instruction • Service Providers may not act as technology plan approvers, write/create, or assist in the tech plan in any capacity • Remember to include in your tech plan all the services that you apply for on Form 470/471, required for Priority 2 - internal connections, and basic maintenance Beginner’s Presentation I 2013 California Department of Education 24 Who to Contact? TOM TORLAKSON State Superintendent of Public Instruction • State Library: Rushton Brandis, (916) 653-5471 Rushton.Brandis@library.ca.gov • CDE/Tech Plans: Doris Stephen, 916-324-9943 dstephen@cde.ca.gov • K-12 HSN/Butte COE: Russ Selken 530-532-5678 rselken@bcoe.org Resources • CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp • CTAP Tech Plan Builder: http://myctap.org/index.php/techplan/tpb • Libraries: Rushton Brandis, Rushton.Brandis@library.ca.gov, 916-653-5471 Beginner’s Presentation I 2013 California Department of Education 25 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Discounts Beginner’s Presentation I 2013 California Department of Education 26 Discounts Determining Your Discount Percentage TOM TORLAKSON State Superintendent of Public Instruction • How large are the discounts on eligible products and services? – Discounts: 20% to 90% of eligible costs • Discount level for a school or library depends on: 1) Percentage of students who are eligible for National School Lunch Program (NSLP) in: → (for a school) the school → (for a library) the school district in which the library is located 2) Urban or rural location of the school or library Beginner’s Presentation I 2013 California Department of Education 27 Calculations TOM TORLAKSON State Superintendent of Public Instruction Discounts • Based on two factors: 1. Percentage of students eligible for free and reduced lunch under the National School Lunch Program (NSLP): http://www.usac.org/sl/applicants/step05/discount-matrix.aspx or an alternate method: http://www.universalservice.org/sl/applicants/step05/alternativediscount-mechanisms.aspx 2. Urban or Rural status (Matrix) http://www.usac.org/sl/applicants/step05/discount-matrix.aspx. - To verify your Urban or Rural Status status:http://www.usac.org/sl/applicants/step05/urban-rural/ - Census Tract Look-up Tool http://www.ffiec.gov/Geocode/default.aspx Beginner’s Presentation I 2013 California Department of Education 28 Discounts Discount Matrix: TOM TORLAKSON State Superintendent of Public Instruction INCOME Measured by % of students eligible for NSLP URBAN LOCATION Discount RURAL LOCATION Discount If the % of students in your school that qualifies for the NSLP... ...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% Beginner’s Presentation I 2013 California Department of Education 29 Discounts Types of Facilities TOM TORLAKSON State Superintendent of Public Instruction • Instructional Facilities have a discount that comes from the NSLP free and reduced lunch data and the Urban/Rural Matrix • Non-Instructional Facilities and libraries will use a weighted average Beginner’s Presentation I 2013 California Department of Education 30 Discounts Basis for determining – National School Lunch Program (NSLP) TOM TORLAKSON State Superintendent of Public Instruction • NSLP data is reported to CDE for October of each year: http://www.cde.ca.gov/ds/sh/cw/filesafdc.asp • This posted NSLP data comes from Page 48 of the Consolidated Application (Con App) • Program Integrity Assurance (PIA) uses this CDE NSLP data. Starting in FY2012, applicants must use this October NSLP data reported to CDE to calculate the discount • Important: Keep all establishing NSLP data used on Form 471 to calculate the discount in your E-rate file for future USAC Inquiries Beginner’s Presentation I 2013 California Department of Education 31 Discounts Sample District TOM TORLAKSON State Superintendent of Public Instruction District Students Enrolled # Free and Reduced Lunches % Free and Reduced Lunches % E-Rate Subsidy Weighted Average for District Sample School District Sample School 1 19 14 73.68% 80% 15.2 Sample School 2 836 323 38.64% 60% 501.6 Sample School 3 188 54 28.72% 50% 94 Sample School 4 121 65 53.72% 80% 96.8 Sample School 5 158 36 22.78% 50% 79 Sample School 6 1050 204 19.43% 40% 420 TOTALS FOR DISTRICT 2372 696 WEIGHTED AVERAGE Beginner’s Presentation I 2013 California Department of Education 1206.6 50.87% 32 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Eligible Services List Beginner’s Presentation I 2013 California Department of Education 33 Eligible Services List Basic Concepts • Find it online at: TOM TORLAKSON State Superintendent of Public Instruction http://www.usac.org/_res/documents/sl/pdf/ESL_archive/EligibleServices List-2013.pdf – This List is updated Annually • Priority 1 (P1) – Telecommunications – Telecommunications Services – Internet Access • Priority 2 (P2) – Internal Connections – Basic Maintenance on Eligible Internal Connections • Note: End-user devices and content generally not eligible – PCs/PDAs -Printers -Television – Laptops – Phones - VCRs • Services must be used for “Educational Purpose” http://www.sl.universalservice.org/reference/educational_purposes.asp Beginner’s Presentation I 2013 California Department of Education 34 Eligible Services List Educational Purpose TOM TORLAKSON State Superintendent of Public Instruction • 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 educational purposes. Beginner’s Presentation I 2013 California Department of Education 35 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Form 470 Beginner’s Presentation I 2013 California Department of Education 36 Requesting Services Technology Planning TOM TORLAKSON State Superintendent of Public Instruction FCC Form 470 Competitive Bidding FCC Form 471 Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 37 Form 470 – Summary 1. WHO – Who is the applicant? E.g.: TOM TORLAKSON State Superintendent of Public Instruction • ABC School District • XYZ Library 2. WHAT – What Services are you seeking? E.g.: • Long Distance • Digital Transmission Services, etc. 3. WHEN – When do I submit the Form 470/RFP? • Once Form 470/RFP is/are posted, then Applicant & potential Service Providers know ACD 4. WHY – If you want E-rate funding you must post a Form 470 to competitively bid those 5. HOW – How many/what quantity/what speed, etc., of the services you are seeking Beginner’s Presentation I 2013 California Department of Education 38 Form 470 – Purpose 1. Begins “Competitive Bidding” process 2. Identify and describe the: TOM TORLAKSON State Superintendent of Public Instruction a) categories of services (e.g., Priority 1, Telecommunications, etc) and function of services you are seeking. b) Describe scope of your needs (e.g., a single school building, library system, state network, etc.) c) Notify potential bidders (service providers) of types and quantities of services you need for upcoming year. *Note* RFPs (in addition to Form 470) are not required by the E-rate program but may be required by your local procurement policies. Discussed more in “Competitive Bidding” section. Beginner’s Presentation I 2013 California Department of Education 39 Where Do I Find the Form 470? TOM TORLAKSON State Superintendent of Public Instruction Helpful link • Download the form: – http://www.usac.org/_res/documents/sl/p df/forms/470.pdf *Tips:* • Determine what new services you will need to add next year. • Determine which contracts expire on or before 6/30/2014. • So that….you will know what services you are seeking to include on Form 470. Beginner’s Presentation I 2013 California Department of Education 40 Form 470 Allowable Contract Date (ACD) TOM TORLAKSON State Superintendent of Public Instruction • Allowable Contract Date (ACD): THE date 28 days after the Form 470 is posted to the USAC website – Contracts with Service Providers cannot be signed until on or after the ACD. – If an RFP is issued in conjunction with the Form 470, whichever document (RFP or Form 470) is posted last, determines the actual ACD. Beginner’s Presentation I 2013 California Department of Education 41 Form 470 Identifying Sites TOM TORLAKSON State Superintendent of Public Instruction • Block 1, 5c: – Number of eligible entities for which services are sought. Beginner’s Presentation I 2013 California Department of Education 42 Identifying Sites Instructional Facilities TOM TORLAKSON State Superintendent of Public Instruction • USAC assigns a unique identifying number to each eligible entity that participates in the Schools and Libraries Program. – Individual school – Library outlet/branch – Bookmobile • http://www.usac.org/sl/applicants/beforey oubegin/entity-number.aspx Beginner’s Presentation I 2013 California Department of Education 43 Identifying Sites Non-Instructional Facility (NIF) TOM TORLAKSON State Superintendent of Public Instruction SCHOOLS: • 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 • See http://www.usac.org/sl/applicants/beforeyoubegin/entitynumber.aspx for more in-depth direction on Entities Beginner’s Presentation I 2013 California Department of Education 44 Overview of Form 470 The KEY section is Block 2 of Form 470 • Block 2, Items 8 – 9 TOM TORLAKSON State Superintendent of Public Instruction – Describe services you are seeking from Eligible Services List • Use Eligible Services list as you would a textbook/reference material • You must fill out Block 2 even if you also issue an RFP • Identify correct category of services you are seeking, i.e., Telecommunications, Telecommunications Services, Internet Access, etc. – Service Provider uses information you enter in Block 2 to decide if they qualify to bid Beginner’s Presentation I 2013 California Department of Education 45 Form 470 – Submit and Certify 1. Once Form 470 is submitted, you must: TOM TORLAKSON State Superintendent of Public Instruction a) Certify online using your assigned PIN, or b) Print certification page, sign and mail this form ASAP-- “certified mail” 2. Print Form 470 for your files, and make sure you know what the Allowable Contract Date (ACD) actually is. • ACD is also displayed on Receipt Acknowledgement Letter (RAL) NOTE: Do not award contract before ACD. Beginner’s Presentation I 2013 California Department of Education 46 Form 470 – Roadmap to Success TOM TORLAKSON State Superintendent of Public Instruction 1. Submit your Form 470 early (Form 470 filing Deadline will be determined once Form 471 filing deadline is announced): a) Do submit your Form 470 sometime between now & December 1. b) Do not wait until last minute to post your Form 470! 2. Allow enough time to accomplish: a) your competitive bidding; b) evaluate and compare bids & bidders; c) review any potential contracts you are planning to sign; and a) get all resulting contracts signed. Beginner’s Presentation I 2013 California Department of Education 47 Form 470 – MUST DOs Before you submit your Form 470 for upcoming year: • Understand: – Your existing services & contracts TOM TORLAKSON State Superintendent of Public Instruction – Contract expiration dates on or before 6/30/2014 for services eligible for E-rate discount – Any new Products & Services, additional locations you will need service for in the coming year • Identify correct E-rate category for each product & service you are seeking: Priority 1 or Priority 2 – You may have to submit for services in multiple categories, e.g., VOIP • may be either leased Priority 1Telecom or Internet, or it could be: • Priority 2 Internal Connections category if you want to own the equipment and if E-rate funding for Priority 2 services might be approved for your school or library. Beginner’s Presentation I 2013 California Department of Education 48 Form 470 – Other Tips TOM TORLAKSON 1. DON’T allow potential service provider(s) for your school or library to fill out your Form 470. State Superintendent of Public Instruction 2. DON’T wait until Form 471 filing window opens before you post your Form 470. 3. Additional tips on SLD website. Look for FCC Form 470: How to File Online @http://www.sl.universalservice.org/menu.asp 4. DO certify your Form 470 before Form 471 Filing Deadline http://www.usac.org/sl/about/outreach/online-learning.aspx Beginner’s Presentation I 2013 California Department of Education 49 Form 470 is Submitted – Now What? Receipt Notification Letter (RNL) TOM TORLAKSON State Superintendent of Public Instruction • Issued by USAC, sent to applicant to summarize information entered on YOUR Form 470. • Review RNL that SLD sends you; it is • Your GOLDEN Opportunity is to review RNL to review what you entered on your Form 470 application and correct minor errors • RNL is color coded to designate which Erate Year (Yr 2013/2014 is Goldenrod) • Sample RNL http://www.usac.org/_res/documents/sl/pdf/samples/470R NL.pdf Beginner’s Presentation I 2013 California Department of Education 50 Form 470 – How Frequently must I Submit a Form 470? TOM TORLAKSON Must I issue a Form 470 every year? State Superintendent of Public Instruction Applicants must file a new Form 470 each funding year for requests for • tariffed • month-to-month services • new contractual services. • HOWEVER ....…. Beginner’s Presentation I 2013 California Department of Education 51 Form 470 – How Frequently must I Submit a Form 470? (continued) TOM TORLAKSON State Superintendent of Public Instruction You may not need to file Form 470 every year if: • Language on originating Form 470/RFP covered all services on the contract AND • Applicant indicated on the Form 470 that a contract was being sought AND • Applicant indicated on originating Form 470/RFP that a multi-year contract was being sought (perhaps w/voluntary extensions) • Determine if Form 471, FRN from previous year (s) referenced a multi-year contract Beginner’s Presentation I 2013 California Department of Education 52 E-rate Program New FCC Forms 470 and 471 Proposed Changes New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 53 Overview Proposed changes to FCC Form 470, Description of Services Requested and Certification Form – Consolidated telecommunications and Internet access services into one field for Priority One Services in Block 2 – Clarifying text in Block 2 regarding Request For Proposal (RFP) services – Additional text in the certification regarding document retention in Block 5 New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 54 New FCC Forms 470 and 471 Proposed FCC Form 470 Updates New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 55 Proposed FCC Form 470 Updates Consolidated the Telecommunications and Internet access categories of service into the field Priority One Services Applicants must still distinguish services between Telecommunications and Internet access on the FCC Form 471 New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 56 Proposed FCC Form 470 Updates Block 2, item 8a, 10a and 11a text addition – 8a, 10a, 11a. YES, I have released or intend to release an RFP for one or more of these services. It is available or will become available on the Internet at: New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 57 Proposed FCC Form 470 Updates Document retention certification Block 5, Item 19 update – “I certify that I will retain required documents for a period of at least five years (or whatever retention period is required by the rules in effect at the time of this certification) after the last day of service delivered.” New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 58 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Competitive Bidding Beginner’s Presentation I 2013 California Department of Education 59 Competitive Bidding Technology Planning TOM TORLAKSON State Superintendent of Public Instruction FCC Form 470 Competitive Bidding FCC Form 471 Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 60 Competitive Bidding Cornerstone of E-rate TOM TORLAKSON State Superintendent of Public Instruction • ALL SERVICES, including month-to-month, tariffed, and those contracts that expire by 6/30/2015 and contracts for new services must be competitively bid to receive E-rate funding • MUST follow ALL State, Local & E-rate bidding rules! • Become familiar with YOUR procurement policies – Business office/Procurement department – Legal counsel – Read your board policies on bids and contracts (the E-rate auditors will!) Beginner’s Presentation I 2013 California Department of Education 61 Competitive Bidding FCC Bidding Requirements TOM TORLAKSON State Superintendent of Public Instruction • All processes must be fair and open • Applicant must post a Form 470 describing services sought – an RFP is not required, but when used, must be indicated on Form 470 • A minimum 28-day bidding window is required; longer if there is a change in the scope of the procurement • Applicant cannot list a trade name for goods or services without allowing for equivalent • Disqualification factors must be listed on Form 470 or RFP • The price of E-rate eligible goods and services must be given the most weight in any award • Contracts must be signed and executed before filing of the Form 471 Beginner’s Presentation I 2013 California Department of Education 62 Competitive Bidding Requirements and Documentation TOM TORLAKSON State Superintendent of Public Instruction • You must ensure that the competitive bidding process is open and fair – You must keep all incoming bids and correspondence with bidders – Respond to ALL vendors. If you choose not to, you must have a good reason (i.e. Spam) and document it • All potential bidders have access to the information from your Form 470 and RFP (if required), and they can respond to your requests Beginner’s Presentation I 2013 California Department of Education 63 Competitive Bidding Examples of rule violations • Applicant has a relationship with a service provider that unfairly influences outcome of your competitive bidding process TOM TORLAKSON State Superintendent of Public Instruction • Someone other than applicant (or authorized representative of the applicant) prepares, signs, and submits Form 470 and certifications • Applicant signs contract before 28 day competitive bidding period comes to an end • A service provider representative is listed as the Form 470 contact person and that service provider is allowed to participate in competitive bidding process • Form 470 does not describe desired products and services with sufficient specificity to enable interested parties to submit bid responses Beginner’s Presentation I 2013 California Department of Education 64 Competitive Bidding Program Compliance TOM TORLAKSON State Superintendent of Public Instruction • http://www.sl.universalservice.org/reference/Best Practices.asp – At a minimum, keep (see last slide): Copies of all bids, winning and losing All documentation on the award process and bid evaluation criteria for your award All correspondence throughout the bidding process Complete copies of all related contracts • Evaluation Criteria (needs to be established BEFORE you release RFP/Form 470) AND • FOLLOW LOCAL PROCUREMENT POLICIES Beginner’s Presentation I 2013 California Department of Education 65 Competitive Bidding Bid Evalution Acronyms and Terms TOM TORLAKSON State Superintendent of Public Instruction • Bid – A service provider response to your Form 470 and/or RFP that contains services and prices and any other information you have requested • Price as the primary factor – In evaluating bids, the price of E-rate eligible products and services must be the most heavilyweighted factor in your evaluation of bids Beginner’s Presentation I 2013 California Department of Education 66 Competitive Bidding Choosing a Service Provider TOM TORLAKSON State Superintendent of Public Instruction • After you close the competitive bidding process for your services (on or after the Allowable Contract Date (ACD): 1. 2. 3. 4. You can evaluate bids received You can choose your service provider(s) You can sign a contract Get Board approval if Board approval is required 5. You can post Form 471 Beginner’s Presentation I 2013 California Department of Education 67 Competitive Bidding Bid Evaluation Program Compliance TOM TORLAKSON State Superintendent of Public Instruction • Best Practices: – Use standard evaluation process for all bids. – Keep evaluation documentation for each bid. • If you get NO bids – document this for audit purposes – Same is true if you get only ONE bid – If you get only one bid, is it competitive? • You may need to be proactive in soliciting for bids; local procurement rules prevail Beginner’s Presentation I 2013 California Department of Education 68 Competitive Bidding Evaluation Criteria TOM TORLAKSON State Superintendent of Public Instruction • Price of E-rate eligible service(s) must be most heavily weighted factor • Can choose most responsive and responsible bid, but you must DOCUMENT the choice and process • Have District official SIGN and DATE the completed rubric as acknowledgement at time of the decision by the district Beginner’s Presentation I 2013 California Department of Education 69 Competitive Bidding Sample Bid Evaluation Matrix TOM TORLAKSON State Superintendent of Public Instruction Factor Points Available 30 Vendor 1 Vendor 2 Vendor 3 15 30 25 20 20 0 20 25 20 15 25 15 0 15 15 5 5 3 2 Local or in state vendor 5 5 5 5 Total 100 65 68 92 Price of ELIGIBLE goods and services Prior experience w/ vendor Prices for ineligible services, products & Fees Flexible Invoicing: 472 or 474 Environmental objectives Beginner’s Presentation I 2013 California Department of Education 70 Competitive Bidding Reminders TOM TORLAKSON State Superintendent of Public Instruction • DO ensure a fair and open competitive bidding process. All service providers must be treated equally and cannot be given biased or privileged knowledge of the bid. • DO select most cost-effective service provider, with price as the primary factor. • DO keep ALL records relating to bid evaluation process (correspondence with potential vendors, winning and losing bids, worksheets, evaluation criteria, contract, etc.). Note in a memo if one (or no) bids are received. • DO remember that contracts must be signed and dated by applicant/Board and service provider before filing the Form 471. • DON’T sign a contract until after Form 470 has been posted for a minimum of 28 days. Beginner’s Presentation I 2013 California Department of Education 71 Competitive Bidding Contract reminders TOM TORLAKSON State Superintendent of Public Instruction • Contract Reviews: Do not wait until the last minute – Leave time for board approval processes and signatures – Know what constitutes a fully executed contract, i.e., Board Approval, etc. • Some contracts may require 2 or more signatures/dates to be fully executed Beginner’s Presentation I 2013 California Department of Education 72 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Form 471 Beginner’s Presentation I 2013 California Department of Education 73 Ordering Services FCC Form 470 Competitive Bidding Technology Planning TOM TORLAKSON State Superintendent of Public Instruction FCC Form 471 Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 74 Form 471 Your application for funds TOM TORLAKSON State Superintendent of Public Instruction • Detailed information on services being requested, service providers selected, and contracts • Must be filed every funding year – even on multi-year contracts • Includes one or more funding requests Beginner’s Presentation I 2013 California Department of Education 75 Form 471 Purpose of the form TOM TORLAKSON State Superintendent of Public Instruction • Identify eligible schools and libraries that will receive services (Block 4) • Include your discount calculation information (Block 4) • Provide specifics on selected service providers and eligible services (Block 5) – Itemize costs associated with services you are requesting E-rate funding for (Item 21 Attachment) – Item 21 Attachment form can be filed online • Certify your compliance with program rules (Block 6) Beginner’s Presentation I 2013 California Department of Education 76 Form 471 Recurring vs. Non-Recurring TOM TORLAKSON State Superintendent of Public Instruction • Monthly Recurring Charges (MRC) = charges incurred monthly, e.g., bills for ongoing phone lines, monthly LD, etc. • Non Recurring Charges (NRC) = one-time charges, e.g., purchase of E-rate eligible equipment • Separate MRC from NRC in Form 471, Block 5 – Services that include recurring costs must ALWAYS be received by June 30 – Services that include NRC must be received by September 30 following the Funding Year (deadline can be extended for certain circumstances) Beginner’s Presentation I 2013 California Department of Education 77 Form 471 Item 21 attachment TOM TORLAKSON State Superintendent of Public Instruction • This document itemizes the dollar amount(s) of your funding request – Substantiating documentation that proves the pre-discount cost of services or products – Should be clear and concise – Must match the $ amount on the associated funding request number on Block 5. – Can be filed online • Sample formats available on USAC website – http://www.usac.org/sl/applicants/step04/item-21.aspx Beginner’s Presentation I 2013 California Department of Education 78 Form 471 Item 21 attachment, cont’d TOM TORLAKSON State Superintendent of Public Instruction • Identify and remove ineligible costs from Requested Amounts • Work with service provider(s) to create your Item 21 attachment(s) • Item 21’s must be filed by Form 471 deadline • Verify that each Item 21’s total $ amount matches the corresponding funding request’s $ amount on the Form 471 Block 5 Beginner’s Presentation I 2013 California Department of Education 79 Form 471 Sample Form 471 TOM TORLAKSON State Superintendent of Public Instruction • Tip – download and review the form prior to filing online. http://www.usac.org/sl/tools/forms.aspx Beginner’s Presentation I 2013 California Department of Education 80 Form 471 Best Practices TOM TORLAKSON State Superintendent of Public Instruction – File Online – Do not combine Priority 1 and Priority 2 services on same Form 471 – Submit BEFORE Form 471 Filing Deadline Date (Deadline changes every application year) – Certify BEFORE close of window •Certify online, if using PIN •By track-able mail, if you do not use your PIN ** Bishop Perry Order – 15 day grace period for certifications made after the deadline http://www.usac.org/sl/applicants/step02/clerical-errors.aspx Beginner’s Presentation I 2013 California Department of Education 81 Form 471 Certifications TOM TORLAKSON State Superintendent of Public Instruction Block 6, 26 through 37: • Applicant is required to make a variety of certifications • Read each certification carefully and take them very seriously – Download form to read certifications at • http://www.usac.org/sl/tools/default.aspx Beginner’s Presentation I 2013 California Department of Education 82 Form 471 What if I miss the Form 471 deadline? TOM TORLAKSON State Superintendent of Public Instruction • Form 471 is not submitted before the close of “the window” or is not certified within the grace period: – The application will not be considered for funding Beginner’s Presentation I 2013 California Department of Education 83 Reminders TOM TORLAKSON State Superintendent of Public Instruction Form 471 • Do verify that services ordered match the category requested on the correct Form 470. • DO file separate Form 471 applications for Priority 1 services and Priority 2 services. • DO read Eligible Services List and request discounts only on eligible services. • DO complete and submit each Item 21 Attachment by Form 471 filing deadline. • DO split out requests of questionable eligibility into separate Funding Request Numbers (FRNs). • DO check your math. The Form 471 Block 5 amount and correlated Item 21 attachment totals should match. • DO file electronically and DO certify online before the close of the window. • DO keep a record of postmark or electronic submission. Beginner’s Presentation I 2013 California Department of Education 84 Form 471 Receipt Acknowledgement Letter (RAL) TOM TORLAKSON State Superintendent of Public Instruction Applicants should carefully review Form 471 RAL and submit corrected data entry errors before issuance of the Funding Commitment Decision Letter (FCDL). - Best Practice: Submit corrections within 3 weeks of the date on the RAL • http://www.usac.org/_res/documents/sl/pdf/samples/form471RAL-applicant.pdf Beginner’s Presentation I 2013 California Department of Education 85 New FCC Forms 470 and 471 Proposed FCC Form 471 Updates New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 86 Overview Proposed changes to the FCC Form 471, Description of Services Ordered and Certification Form – Removed Block 2 – Request for additional information regarding broadband connectivity on an FRN level New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 87 Proposed FCC Form 471 Updates Additional Block 5 reporting requirements – For Broadband and other connectivity services only • E.g. T-1, fiber, DSL, cable, cellular wireless hotspots, satellite – Does not apply to non-broadband or other connectivity services • E.g. Cellular service, web hosting and email service – Complete information for every applicable funding request New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 88 Proposed FCC Form 471 Updates Block 2 has been removed and a new data gathering section has been added to Block 5 New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 89 Proposed FCC Form 471 Updates If you are not requesting broadband or other connectivity services for the individual funding request, check the box New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 90 Proposed FCC Form 471 Updates If you are requesting broadband or other connectivity services, fill out Block 5, Item 24 For example, if you request one T-1, six fiber connections that average 150 Mbps and one gigabit connection: New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 91 Proposed FCC Form 471 Updates Item 25 b, 1 - For applicants if the Internet service is available to students or patrons in more than just a single location or office – If the access is provided by wired connections, approximately what percentage of the school classroom or public library rooms included in the Block 4 worksheet for this FRN will have access to wired drops? _____? New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 92 Proposed FCC Form 471 Updates Item 25 b, 2 - For applicants if the Internet service is available to students or patrons in more than just a single location or office – If the access is provided by Wi-Fi connections, approximately what percentage of the school classroom or public library rooms included in the Block 4 worksheet for this FRN will have access to wired drops? _____? New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 93 Proposed FCC Form 471 Updates Item 25 c - For consortia and statewide applications, do the connections in this FRN include the last mile connection to the school or library? Yes No – If no, are these connections only for backbone connections? Yes No New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 94 Proposed FCC Form 471 Updates Document retention certification Block 6, Item 33 update – “I certify that I will retain required documents for a period of at least five years (or whatever retention period is required by the rules in effect at the time of this certification) after the last day of service delivered.” New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 95 Questions? New FCC Forms 470 and 471 I 2013 Schools and Libraries Fall Applicant Trainings 96 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Application Review & Funding Commitments Beginner’s Presentation I 2013 California Department of Education 97 Application Review/Commitments FCC Form 470 Competitive Bidding FCC Form 471 Technology Planning TOM TORLAKSON State Superintendent of Public Instruction Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 98 Program Integrity Assurance (PIA Review) TOM TORLAKSON During PIA review, USAC reviews your Form(s) 471 to: State Superintendent of Public Instruction • Check eligibility discount levels • Verify services are eligible for discounts • Provide opportunity to make allowable corrections to your application (http://www.usac.org/sl/applicants/step02/clerical-errors.aspx) • Ask for additional verification to demonstrate applicant compliance with program rules, as needed. Beginner’s Presentation I 2013 California Department of Education 99 PIA Review Be Responsive to PIA Reviewer: TOM TORLAKSON State Superintendent of Public Instruction • Respond promptly; answer questions in their entirety (you are given 15 days initially to respond) • Document communication with PIA reviewer: – E-mail is preferred (acknowledgement of receipt) • Ask for more time if you need it – More time request…may delay your application review • Don’t assume Reviewer has your original Item 21 attachment • Establish working relationship: PIA reviewer can help clarify questions being asked of you • Contact Service Provider(s) immediately if you need information from them to respond • Contact CDE for site/discount validations, etc., as needed Beginner’s Presentation I 2013 California Department of Education 100 Application Review & Funding Commitments What happens after PIA review? TOM TORLAKSON State Superintendent of Public Instruction • Decision: A Funding Commitment Decision Letter (FCDL) is sent to applicant. • FCDL letter notifies you that your request is: – Funded – Partially funded – Not Funded – As Yet Unfunded (Priority 2 requests) – Cancelled Beginner’s Presentation I 2013 California Department of Education 101 •SAMPLE FCDL: http://www.usac.org/_res/docum ents/sl/pdf/samples/form-471FCDL-applicant.pdf TOM TORLAKSON State Superintendent of Public Instruction •Carefully review FCDL for details on approved or denied requests and determine your next steps •Should be your “trigger” to file subsequent forms to both USAC and Service Providers •Starts deadline clock for appeal on denial(s) – 60 Days: http://www.usac.org/sl/ab out/programintegrity/appeals.aspx Beginner’s Presentation I 2013 California Department of Education 102 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation CIPA Compliance & Protecting Children in the 21st Century Beginner’s Presentation I 2013 California Department of Education 103 CIPA Basics • Children’s Internet Protection Act (“CIPA”) enacted in December of 2000 – effective April 20, 2001 TOM TORLAKSON State Superintendent of Public Instruction • CIPA requirements apply to ALL applicants that receive funding in following categories of service: • P1 - Internet Access • P2 - Internal Connections • P2 - Basic Maintenance of Internal Connections • CIPA compliance is not required for applications for P1 - Telecommunications Services and Voice Over Internet Protocol (VoIP) • First-time applicants (ONLY) may have up to two additional years to come into compliance Beginner’s Presentation I 2013 California Department of Education 104 CIPA Compliance Recap of continuing requirements TOM TORLAKSON State Superintendent of Public Instruction 1. Internet safety policy 2. Technology protection measure (filter) 3. Public notice of – and public meeting or hearing on – the Internet safety policy For a detailed discussion of CIPA requirements: Children’s Internet Protection Act website guidance Form 486 Instructions Form 479 Instructions Beginner’s Presentation I 2013 California Department of Education 105 Protecting Children in the 21st Century Basics • Erroneously referred to as CIPA • Supplement to CIPA Policy TOM TORLAKSON State Superintendent of Public Instruction • Enacted in October of 2008 – effective July 1, 2012 • Requirements apply ONLY to school and school district applicants that receive funding in following categories of service: • P1 - Internet Access • P2 - Internal Connections • P2 - Basic Maintenance of Internal Connections • Requires applicants meet certain requirements regarding education of minors and cyberbullying awareness and response Beginner’s Presentation I 2013 California Department of Education 106 Overview of Protecting Children in the 21st Century Requirements TOM TORLAKSON State Superintendent of Public Instruction • Schools must educate minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms (education requirements apply only to minors and not adults) • Schools must promote cyberbullying awareness and response • Schools must update their Internet Safety Policies to address these new requirements • These activities must be in place by July 1, 2012 Beginner’s Presentation I 2013 California Department of Education 107 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Begin Receiving Services (Form 486) Beginner’s Presentation I 2013 California Department of Education 108 Begin Receiving Services FCC Form 470 Competitive Bidding FCC Form 471 Application Review & FCDL Technology Planning TOM TORLAKSON State Superintendent of Public Instruction FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) Beginner’s Presentation I 2013 California Department of Education 109 Begin Receiving Services (Form 486) Purpose of Form 486 TOM TORLAKSON State Superintendent of Public Instruction • Notifies USAC that your eligible services have started or delivered and that invoices for those services can be processed and paid • Provides name of TPA (Technology Plan Approver) who approved your technology plan • Reports your status of compliance with CIPA and Protecting Children in the 21st Century Act Beginner’s Presentation I 2013 California Department of Education 110 Begin Receiving Services (Form 486) Form 486 Certifications TOM TORLAKSON State Superintendent of Public Instruction • For P2 services (starting in FY 2011), that applicant’s Technology Plan is approved by USAC-certified technology plan approver by start of services and covers 12 months of funding year • Applicant is compliant with CIPA requirements, unless this is applicant’s first year of participation in E-rate program and is undertaking actions to become compliant (firsttimers ONLY) Beginner’s Presentation I 2013 California Department of Education 111 Begin Receiving Services (Form 486) Form 486 Deadline • Can only be filed AFTER receipt of FCDL TOM TORLAKSON State Superintendent of Public Instruction – Form 486 must be filed online or postmarked no later than: • 120 days after Service Start Date OR • 120 days after date of FCDL Whichever is later • Grace period from USAC – Reminder letter giving additional 20 days to file 486 – (Alaska Gateway order) •Take Reminder letter seriously! Do NOT miss 486 deadline. – http://www.usac.org/sl/applicants/step06/default.aspx Beginner’s Presentation I 2013 California Department of Education 112 Begin Receiving Services (Form 486) What if I miss the 486 deadline? TOM TORLAKSON State Superintendent of Public Instruction • If Form 486 is late, your Service Start Date will be adjusted to 120 days prior to online certification or 120 days prior to postmark. • Adjusting Service Start Date: WILL affect P1 services • Funding will more than likely be reduced MAY affect P2 services • The date …120 days before the Form 486 postmark date.. will become the “new” start date for your services and E-rate funding may be reduced. Beginner’s Presentation I 2013 California Department of Education 113 Begin Receiving Services (Form 486) Reminders TOM TORLAKSON State Superintendent of Public Instruction • DO file within 120 days of the service start date (July 1 for recurring services) or FCDL date, WHICHEVER IS LATER. • DO understand early filing rules if filing BEFORE July 1. • DO review Form 486 Notification Letter to verify all FRNs were included. • DO maintain open communication with your service provider regarding non-recurring services. They cannot invoice USAC until Form 486 is filed. • DO make sure your Technology Plan is approved (as applicable) • DO make sure you are compliant with CIPA and Protecting Children in the 21st Century Act • DON’T ignore your Form 486 Reminder Letter. Beginner’s Presentation I 2013 California Department of Education 114 TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation Invoicing USAC (Form 472 and Form 474) Beginner’s Presentation I 2013 California Department of Education 115 Invoicing USAC TOM TORLAKSON State Superintendent of Public Instruction Beginner’s Presentation I 2013 California Department of Education 116 Invoicing USAC (Form 472 or Form 474) TOM TORLAKSON State Superintendent of Public Instruction Requirements to fulfill before USAC will pay any E-rate invoices 1. Applicants and Service Providers must receive FCDL from USAC for the services to be invoiced AND 2. Applicants must file a Form 486 and receive a 486 Notification Letter Beginner’s Presentation I 2013 California Department of Education 117 Invoicing USAC (Form 472 and Form 474) Applicants choose whether to invoice USAC via one of two methodologies: TOM TORLAKSON State Superintendent of Public Instruction o Billed Entity Applicant Reimbursement: (BEAR) Form 472 is filed by Applicant and approved by Service Provider after applicant has paid for the services in full OR o Service Provider Invoice: (SPI) Form 474 is filed by Service Provider after applicant has been billed for the non-discounted portion of the cost of eligible services • Note: Telecommunications Services & Internet Access services that receive CTF Discounts must use SPI process Beginner’s Presentation I 2013 California Department of Education 118 Invoicing USAC (Form 472 or BEAR) BEAR is filed by Applicant TOM TORLAKSON State Superintendent of Public Instruction 1. Applicant must receive services and pay invoices in full (amount must be for E-rate eligible portion only) 2. Once form is filled out, it must be certified by Applicant and Service Provider 3. Completed form is then mailed to SLD (unless certified online) I. SLD reviews the form II. BEAR Notification Letter is sent to both Applicant and Service Provider i. ii. Discounts are transmitted electronically to Service Provider Service Provider has 20 days to reimburse Applicant from BEAR Notification Letter date Beginner’s Presentation I 2013 California Department of Education 119 Service Provider Invoice (Form 474 or SPI) SPI is filed by Service Provider TOM TORLAKSON State Superintendent of Public Instruction • Used by Service Providers (SP) – Allows SP to apply discounts to the bill AFTER funding commitment has been issued and all relevant forms are submitted – Allows applicant to eventually pay only their nondiscounted portion – SP Forms such as “Grid” and “Data Gathering Form” MUST be submitted • Every SP has their own process and suggested deadline • Follow up with SP to ensure receipt of funds • Helps your district/library’s CASH FLOW ! RETURN GRIDS/Data Gathering information to SP ASAP to start discounts! Beginner’s Presentation I 2013 California Department of Education 120 Invoicing USAC Reminders TOM TORLAKSON State Superintendent of Public Instruction • DO pay your bills. The expectation of E-rate funding is that you pay your bill(s) within 90 days of receipt of bill. • Do ensure your Form 486 is filed in a timely manner. Invoicing cannot occur until Form 486 is filed and certified. • DO, if using the SPI method, ensure that all service provider forms are completed and returned in a timely manner. • DO work with your service provider to verify discounts posted on your invoices. • DO file the BEAR form prior to the Invoice Deadline. • DO document your BEAR form calculations and retain for audit purposes. • DO file an Invoice Deadline Extension Request if your FRN does not show any or incomplete disbursement of funding by the invoicing deadline. • DON’T assume the discounts posted are correct. • DON’T include ineligible costs in your BEAR form amount. Beginner’s Presentation I 2013 California Department of Education 121 Invoicing USAC Upcoming Deadlines for FY 2012 (prior year) 2012/13) TOM TORLAKSON State Superintendent of Public Instruction Type of Service Date of FCDL Invoice Extension Invoice Deadline Deadline Recurring Service Before June 30, 2013 October 28, 2014 February 25, 2015 Recurring Service After June 30, 2013 October 28, 2014 February 25, 2015 Non-Recurring Service Before March 1, 2013 January 28, 2015 May 27, 2015 Non-Recurring Service After March 1, 2013 January 28, 2015 May 27, 2015 Beginner’s Presentation I 2013 California Department of Education 122 Invoicing USAC Future Deadlines for FY 2013 TOM TORLAKSON State Superintendent of Public Instruction Type of Service Date of FCDL Invoice Extension Invoice Deadline Deadline Recurring Service Before June 30, 2014 October 28, 2015 February 25, 2016 Recurring Service After June 30, 2014 October 28, 2015 February 25, 2016 Non-Recurring Service Before March 1, 2014 January 28, 2016 May 27, 2016 Non-Recurring Service After March 1, 2014 January 28, 2016 May 27, 2016 Beginner’s Presentation I 2013 California Department of Education 123 Application Deadlines TOM TORLAKSON State Superintendent of Public Instruction • Form 470 - Posted at least 28 days before the filing of the Form 471, keeping in mind the Form 471 application filing window opening and closing dates Note that contracts must be awarded and signed before filing the Form 471 • Form 471 - Received or postmarked no later than 11:59 p.m. EST on the day of the close of the Form 471 application filing window (exact date will be posted on SLD website) Beginner’s Presentation I 2013 California Department of Education 124 Other E-rate Deadlines TOM TORLAKSON State Superintendent of Public Instruction • Form 486 - Received or postmarked no later than 120 days after the date of the USAC Funding Commitment Decision Letter or the service start date, whichever is later • Form 472/Form 474 - Received or postmarked no later than 120 days after the date of the Form 486 Notification Letter or the last date to receive service, whichever is later • Appeals - Received or postmarked no later than 60 days after the date of USAC's decision letter Beginner’s Presentation I 2013 California Department of Education 125 General Reminders Document Retention • Keep for 5 years after last date of service TOM TORLAKSON State Superintendent of Public Instruction – Be aware of contract dates and extensions – All E-rate documentation – don’t throw anything away • Make sure all departments (e.g., food services, accounting, etc.) understand E-rate document retention requirements • Align Board policies with E-rate requirements • Per 5th Report and Order: if applicant can’t prove compliance with rules through documentation, USAC must assume that you didn’t follow the rules • No documentation = Recovery of Funds (Applicant may have to pay back the SLD for E-rate discounts they already received) Beginner’s Presentation I 2013 California Department of Education 126