E-Rate UNfiltered
Oct-Nov, 2011
FY2012 Opportunities
for
California Libraries
Don Dietrich
BTU Consultants, LLC
(Includes content from October, 2011 SLD Seminars, with permission)
1
• Preparing for E-Rate & CTF
• Applying for E-Rate
• Approval and Acceptance of Funds
Oct-Nov, 2011
E-Rate 2011 Agenda
• Record Keeping
• What’s new for FY2012
• NEW – training materials available online at
http://www.infopeople.org/training/past/2011/e-rate/index.html
2
E-Rate and CTF – What are they?
Provides up to 90% discounts on broad array of services
–“…deliver information to and from libraries…”
–
Oct-Nov, 2011
• E-Rate (Education Rate - Federal)
• CTF (California Teleconnect Fund– CA only)
Provides 50% discounts on telecom services only
–To receive CTF, you only need to verify once and your discounts will
continue with your existing vendors.
–
• Both are results of Universal Service concept
1934 - “EVERYONE deserves an affordable telephone”
–
1996 – “ALL SCHOOL & LIBRARIES deserve high speed Internet”
–
3
E-Rate & CTF Work Together
–
–
Pays 20-90% based on poverty level
Different for every library, branch or system
• File for CTF Discounts
–
–
Oct-Nov, 2011
• File for E-Rate Discounts
Assumes all libraries already file for E-Rate
Pays 50% of ‘Non-E-Rate’ amount
• Ex: if your library qualifies for 70% E-Rate Discount…
–
for each $1000 spent you could receive:
$700 (70% E-Rate discount)
–
$150 (50% CTF of the remaining $300)
–
IF you don’t file for E-Rate and CTF you are losing money
4
Oct-Nov, 2011
USAC E-Rate Information
http://www.usac.org/sl/
5
Oct-Nov, 2011
California State Library E-Rate Information
http://www.library.ca.gov/services/libraries/erate.html
6
CTF Homepage
Oct-Nov, 2011
California Teleconnect Fund (CTF) Information
CTF Training Slides
Libraries currently approved for CTF
http://docs.cpuc.ca.gov/ctf/weblibs.csv
7
E-Rate Annual Cycle - 7/1/xxxx through 6/30/xxxx
September – October
Oct-Nov, 2011
Plan & File Form 470
Review / Update / Approve Technology Plan
Free & Reduced Lunch Counts
Competitive RFPs Developed (if required)
October - November
Vendor Conference(s)
October - November
Vendor Responses Received
Early December
System / Vendor Selection
Mid December
Contract Negotiation
December - January
Forms Submission to SLD (Form 471)
Feb (March ‘12?)
Implementation (Form 486 / 500 / 472)
July – June
8
Oct-Nov, 2011
http://www.usac.org/_res/documents/sl/pdf/application-process-flow-chart.pdf
9
Before Filing…
• Must be based on Technology Plan ONLY if applying
for Priority 2 services
• Competitive Process – requests must be posted for
28 calendar (not business) days
Oct-Nov, 2011
E-Rate Program Rules – Basic Requirements
• All funds must be used for
–
–
–
eligible goods and services
installed at eligible facilities
provided by eligible service providers
Everything must be documented
10
Before Filing…
Technology Plan Assistance
Rushton Brandis
Programs Consultant at California State Library
Sacramento, California Area
Oct-Nov, 2011
http://www.myctap.org/index.php/techplan/tpb
Email rushbrandis@library.ca.gov
Ph: 916-653-5471
CA Library E-Rate Site
11
Before Filing…
• CIPA (Children’s Internet Protection Act) compliance is
only required if you are applying for Internet or
Internal Connections
• New CIPA requirements for 2012 (Cyber Bullying )
do not apply to libraries
• If you don’t want to mess with CIPA…
you should still file E-Rate for Telecom
Oct-Nov, 2011
You must demonstrate CIPA compliance
for E-Rate
See CIPA Resources on Webliography
12
Before Filing…
• Must have an Acceptable Use Policy or Internet Safety
Policy that contains specific elements
Oct-Nov, 2011
CIPA Requirements
• Must have a public hearing and public notice
• Must have technology protection (filtering) software in
place to protect minors.
• All documentation supporting compliance with CIPA rules
is maintained in E-rate binder.
13
Before Filing…
• Access by minors to inappropriate matter on the
Internet and World Wide Web.
• The safety and security of minors when using
electronic mail, chat rooms, and other forms of
direct electronic communications.
• Unauthorized access including "hacking" and other
unlawful activities by minors online.
• Unauthorized disclosure, use, and dissemination of
personal information regarding minors.
• Measures designed to restrict minors' access to
materials harmful to minors.
Oct-Nov, 2011
Acceptable Use Policy Requirements
14
Before Filing…
• Enacted in Fall 2008 to address Internet Safety in schools,
specifically cyber-bullying awareness and response
• New requirements apply to K-12 Schools only
Oct-Nov, 2011
Protecting Children in the 21st Century Act (New)
• no changes for libraries
15
Before Filing…
• Priority 1 (to the Library) – always funded
–
Telecommunications Services Category
–
Internet Access Category
Oct-Nov, 2011
E-Rate Eligible – 2 Priorities / 4 Categories
• Priority 2 – (within the Library) - awarded to poorest
applicants first, until all funds are exhausted
–
Internal Connections Category (only available 2 out of 5 years)
–
Basic Maintenance of Internal Connections Category
16
Before Filing…
Priority 1
• Local and long distance telephone usage, Cellular and Paging
• Internet access costs, Web Hosting, Email Service
Oct-Nov, 2011
What’s Covered Is On the
Eligible Services List (ESL)
Priority 2
• Cabling and hardware (switches, routers, racks, UPS…)
• Network Servers for Internet access and E-mail
• Telephone systems (PBX’s) including VoIP and VoiceMail
• Maintenance charges – “only for work performed”
17
Before Filing…
• Computers, Telephone instruments, Video Cameras
Oct-Nov, 2011
What’s Not Covered ?
• Power infrastructure
• Physical security or construction
• Application Software
• Consulting Services, Training, Personnel Costs
18
Before Filing…
Oct-Nov, 2011
Eligible Services List (ESL)
Eligible Services List - Schools and Libraries - USAC
19
Before Filing…
Take some time to Review this ESL
Oct-Nov, 2011
Eligible Services List (ESL)
Put a Check Mark in the margins of the items that you are sure
you will need
Put a question mark in the margins of the items that you have
questions about
Eligible Services List - Schools and Libraries - USAC
20
Before Filing…
• Libraries that meet Library Services and
Technology Act (LSTA) requirements.
• Library Administration Buildings
Oct-Nov, 2011
E-Rate Eligible Locations – Priority 1
• Bookmobile garages
• Interlibrary loan facilities
• Library technology centers
http://www.usac.org/sl/applicants/step01/
SLD eligibility requirements
21
Before Filing…
Priority 2 services for administrative sites are
NOT eligible unless those services are “essential
for the effective transport of information to a
library”.
Oct-Nov, 2011
E-Rate Eligible Locations – Priority 2
Be Careful
22
Before Filing…
1. What library locations (entities) are you responsible for ?
Oct-Nov, 2011
E-Rate Eligible Locations – start your own list
2. Which will you want to include on E-Rate Form 470 ?
3. Assume all locations are in need of Priority 1
4. Are some (all) locations in need of Priority 2 ?
23
Before Filing…
“My Internet Provider wants to ‘give’ me a router.”
Oct-Nov, 2011
Priority 1 On-Premise Equipment – Be Careful
“My Phone Company wants to sell me a phone system under
E-Rate Priority One”
Be CAREFUL – you must satisfy SLD’s 8 Requirements
24
Before Filing…
Oct-Nov, 2011
Priority 1 On-Premise Equipment – Example 1
This leased router may be eligible for P1 funding if all conditions are met. Single
demarcation – if the router is removed, the LAN would continue to function
25
Before Filing…
Oct-Nov, 2011
Priority 1 On-Premise Equipment – Example 2
Leased VoIP and PBX equipment are NOT eligible for Priority One funding.
By removing the VoIP PBX equipment, the local voice network will cease to
function. This equipment is eligible ONLY as Internal Connections.
26
Before Filing…
• Provides a means for a library to display content on
the Internet.
• Generally includes:
Oct-Nov, 2011
Web Hosting – What is it and What’s Eligible
– provision of web site traffic (bandwidth)
– provision of disk space for storing applicant provided
content
– provision of File Transfer Protocol (FTP) transfer or a
Web interface to upload files
Source: http://www.usac.org/sl/about/training-presentations/trainingpresentations-archive/training-2009/fall/materials.aspx
(Advanced Eligible Services)
27
Before Filing…
•
•
•
•
•
•
•
Content Creation tools
Templates
Check in/out software
Book Catalogs
Chat Rooms (2011)
Blogs (2011)
Other Library Applications
Oct-Nov, 2011
Web Hosting – Not Eligible
28
Before Filing…
• The percentage of students eligible for the National School
Lunch Program (NSLP) or an equivalent measure of poverty in
the school district where your library resides
–
current Discount Data is online at
Oct-Nov, 2011
Calculating E-rate discounts depend on:
http://www.cde.ca.gov/ds/sh/cw/filesafdc.asp
• The urban or rural status of the county or census tract in
which the library building is located
–
current U/R status lookup online at
http://www.usac.org/sl/applicants/step05/urban-rural/
http://data1.cde.ca.gov/dataquest/
29
Before Filing…
INCOME
URBAN LOCATION
RURAL LOCATION
Measured by % of
students eligible for
the National School
Lunch Program
Discount
Discount
If the % of students
in your school that
qualifies for the
National School Lunch
Program is…
…and you are in an
URBAN area, your
discount will be…
…and you are in a
RURAL area, your
discount will be…
Less than 1%
20%
25%
1% to 19%
40%
50%
20% to 34%
50%
60%
35% to 49%
60%
70%
50% to 74%
80%
80%
75% to 100%
90%
90%
Oct-Nov, 2011
E-Rate Discounts are Based on Poverty Level
30
Before Filing…
• Single Library Outlet or Branch
–
use discount for the School District in which the library or
branch is located
Oct-Nov, 2011
Calculating Discounts
• Library System & Consortia
–
–
calculate discount for each individual entity
calculate simple average discount
(total discounts/total entities)
• New Construction
–
use discount for the School District in which the library is
located
31
Before Filing…
• Your discount level determines whether or not you will
be funded for Priority 2 goods and services:
–
below 70% = low probability of Priority 2 funding
–
80% and above = high probability of Priority 2 funding
–
cutoff level changes every funding year
–
FY2010 will fund ALL levels – including 20%
Oct-Nov, 2011
Should I file for Priority 1, Priority 2 or Both?
32
Oct-Nov, 2011
Before Filing…
Exercise #1 – E-Rate Background Data
Exercise #1 – E-Rate Background Data
33
Plan
Tech Plan
Requirements
Design
Detail
Specifications
Internal
Approvals
Procure
Competitive RFP
(if required)
Vendor Selection
Award Contracts
Submit Specific
Requests
Implement
Oct-Nov, 2011
Non-E-Rate Procurement Process
Coordinate Vendors
Monitor Installation
Resolve Upsets
Audit Financial
Documents
Assure Completion
Recommend Acceptance
34
Plan
Procure
Implement
Form 470
Form 471
Form 486
Notice of
applicant’s
intent to acquire
goods and
services (nonspecific as to
amounts or
vendors)
Specific request for
goods and services
by entity, category,
detailed costs and
vendor (requires
signed contract
with vendor)
Notice of intent
to accept funds
awarded
Oct-Nov, 2011
E-Rate Forms Follow the Same Flow
Form 500
Change award
amount or items
Form 472 (BEAR) – Recover discounts already paid to vendors
for eligible goods and services.
35
Oct-Nov, 2011
http://www.usac.org/_res/documents/sl/pdf/application-process-flow-chart.pdf
36
Filing your Form …
Oct-Nov, 2011
E-Rate Form 470 – A Poor Man’s RFP
Step 3: Form 470 Filing Information - Applicants - Schools and Libraries - USAC
37
Filing your Form …
• Filing Form 470 opens a competitive bidding process
– can also issue a Request for Proposals (RFP)
• Applicants are responsible for ensuring an open and fair
process and selecting the most cost-effective provider of
the desired services
• RFP is not required under FCC rules
• Even if you have an RFP, you must describe the services
you desire on your Form 470
Oct-Nov, 2011
E-Rate Form 470 – What’s it for?
38
Filing your Form …
• You must wait at least 28 days from the submission date
before entering into a contract for services
• If filed online, the form will calculate this date for you
• If you are under a multi-year contract from a previous
year, you do not need to file a Form 470 every year
• If you are under Month-Month or Tariff rates, you must
file a Form 470 every year
Oct-Nov, 2011
E-Rate Form 470 – Gotcha’s
39
Filing your Form …
Oct-Nov, 2011
E-Rate Form 470 – Gotcha’s - new for 2012
40
Filing your Form …
Oct-Nov, 2011
E-Rate Form 470 – Gotcha’s - new for 2012
41
Filing your Form …
Oct-Nov, 2011
E-Rate Form 470 – Gotcha’s - new for 2012
42
Filing your Form …
• File online – only use paper as a last resort
• Online Filers can use Interview Mode or Form Fill-out
• You will need the general descriptions for each service that
you are requesting
• If using a consultant – will need Consultant Registration
Number and contact info
• You will need a PIN # (automatically issued the first time
you file a paper form)
Oct-Nov, 2011
E-Rate Form 470 – What you will need
43
Filing your Form …
Oct-Nov, 2011
E-Rate Form 470 – Online
Take notes on your Form 470 Handout
Training Website SLD Training Site
44
Oct-Nov, 2011
Exercise #2 Form 470 Prep Worksheet
Ex #2 – Form 470 Descriptions
45
Filing your Form …
• Transfer the items from your Form 470 Prep Worksheet
from previous Exercise to the Form 470 Handout
Oct-Nov, 2011
Exercise #3 – Form 470 Details
• Review the Eligible Services List Handout for possible
additional items or services
• Goal is to compile a completed Form 470 Handout that you
can use to enter your own online
46
After Form 470…
SLD is on the lookout for these common ‘problems’
• Must wait 28 days and ‘be accessible’
• Must respond to all legitimate inquiries
• Vendor cannot help you with Form 470 or be involved in
competitive process
• Multi-tiered vendor selection must follow rules
• NO ‘Sham’ Bidding (i.e. “I already know who I want”)
• Cost to transfer to another provider alone is not by itself
a good enough reason to stay with incumbent
• NO Gifts or ‘Free’ Services
Source: http://www.usac.org/sl/about/training-presentations/trainingpresentations-archive/training-2009/fall/materials.aspx
(Issues In Competitive Bidding)
Oct-Nov, 2011
RFP Process – Issues in Competitive Bidding
47
After Form 470…
Vendor Selection – if there’s not a formal RFP
E-Rate Form 470 Service Provider Response and Selection Log
Funding Year:
Applicant Name:
2010
Contact Name:
Your CA Library
Latest Update:
1/5/2010
470 Posting Date:
12/4/2009
470 Allowable Contract Date:
1/1/2010
470 Review/Selection Date:
2/8/2010
BEN:
Form 470 No.:
963940000779355
470 Date Closed:
Form 470 Description:
Use Item Descriptions from
Form 470
1/31/2010
Priproty One services, no RFP.
Date
Vendor Name / SPIN
incumbent
Mode of
Contact
Notes, Comments and Actions Taken
FRN
Verizon North
Most cost effective since no new equipment required - only solution
that will run over existing WAN.
1984425
12/4/2010
Calltower
email
Rec'd proposal for VoIP - requires new equipment (Cisco VoIP) and new
phones. Also would require upgrade to WAN beyond DS1s.
12/7/2010
Trumpet Networks
email
Rec'd requiest for information but no pricing. Trumpet provides both
WAN and VoIP services. This vendor would require new equipment
(VoIP PBXs) and new phones. Also would require upgrade to WAN
beyond DS1s.
incumbent
Verizon North
Telecommunications
• Use this template
or one of your own
to record Form 470
responses from
vendors
• Keep logs of all
vendor emails
Local Voice Tel Services Approx
430 Centrex Lines to 14
Locations. Provided by Verizon
North on a tariff basis.
Dedicated Data Lines - Pt-Pt DS1
lines to 12 locations. Provided
12/7/2010
by Verizon North on Tariff basis.
Oct-Nov, 2011
• You must
document and
retain your vendor
selection process
Use this form to log all vendor contacts regarding non-RFP items on this Form 470. Document Service Provider Selection and assign FRN numbers only after the Allowable Contract
Date. Form 470 Items that are described by a formal RFP should be documented elsewhere.
Most cost effective solution - other two offerors do not match specs and
1984427
would require new equipment.
Trumpet Networks
email
Rec'd requiest for information but no pricing. Trumpet provides both
WAN and VoIP services as P1.
1/11/2010
Comcast
email
Proposed Fiber WAN and 50mb Internet. Does not match specs, would
require new equipment and higher cost.
Long Distance - Approx 300
lines. Provided by Qwest on
MTM basis.
incumbent
Qwest
No responses received - remaining with incumbent provider.
1984430
Cellular Voice - 35 existing plus
up to 15 new phones. Provided
by Verizon Wireless on MTM
basis.
incumbent
Verizon Wireless
No responses received - remaining with incumbent provider.
1984435
incumbent
Verizon Wireless
No responses received - remaining with incumbent provider.
1984435
Internet
Cellular Data - / Internet 35
existing plus up to 15 new
phones. Provided by Verizon
Wireless on MTM basis.
See Handout Form 470 Response Log Spreadsheet
48
After Form 470…
Oct-Nov, 2011
Vendor Selection – if there is a formal RFP
..\Training Presentation Fall 2010\samples-checklist-vendor-selection-worksheet.pdf
49
Oct-Nov, 2011
Competitive
Process
Tip Sheet
..\Training Presentation Fall 2010\Tip Sheets\Tip Sheet competitive-bidding-process.pdf
50
• Applicants and service providers must sign
contracts for services that are not provided under
tariff or under month-to-month arrangements
Oct-Nov, 2011
E-Rate Form 471 – Do You Need a Contract?
• Contracts can cover more than one year or contain
extensions
Step 4: Contract Guidance - Schools and Libraries - USAC
51
..\Training Presentation Fall 2010\Tip Sheets\Tip Sheet contracts.pdf
Oct-Nov, 2011
Contracts
Tip Sheet
52
Oct-Nov, 2011
E-Rate Form - 471
Step 7: Form 471 Filing Information - Applicants - Schools and Libraries - USAC
53
• Provides specific information on services, service
providers selected, and contracts
• Provides discount calculation information
Oct-Nov, 2011
E-Rate Form - 471
• Must be filed for each funding year
• Contains certifications of compliance
• Includes one or more funding requests
• Each FRN must reference a specific Form 470
54
• Must be filed online or postmarked on or before
the close of the Form 471 application filing
window.
• Forms 471 filed after the close of the window will
be considered after all Forms 471 filed on time.
• Certifications for associated Forms 470 also must
be filed online or postmarked before the close of
the window.
Oct-Nov, 2011
E-Rate Form – 471 - Deadline
55
Oct-Nov, 2011
E-Rate Form 471 – Online
Training Website SLD Training Site
Example Stockton 2010
56
• Don’t combine Priority 1 and Priority 2 requests on the
same Form 471.
– review of Priority 2 requests may hold up Priority 1
commitments.
• If filing for more than one discount rate – use separate
Form 471 applications.
• You will need an FCC Registration # avail at:
Oct-Nov, 2011
E-Rate Form 471 – Gotcha’s
https://fjallfoss.fcc.gov/coresWeb/publicHome.do
57
• Remove ineligible costs from funding requests
– document ineligible costs carefully
– 30% rule – if 30% or more of the dollar value of the
request is for ineligible products and services, the
entire request will be denied
• You can work with your service provider(s) to create your
Item 21 attachment(s)
• File Item 21 Attachments online
Oct-Nov, 2011
E-Rate Form 471 - Tips
58
20`0 Total PreTotal
SLD
Total
Discount
%
Funding Libr Funding
Amount
Disc
(est.)
(est.)
Svc Cat
470 Description
Current Vendor
SPIN
1.1
1984425
Telecom
Approx 430 Centrex Lines to 14 Locations, includes all eligible services.
Currently provided by Verizon North on tariff basis.
Verizon North
Inc.
143004791
$159,686 81%
$
129,346
$
30,340
1.2
1984427
Telecom
Dedicated point-to-point DS1 Lines from admin center to 12 locations
for data transport. Currently provided by Verizon North on tariff basis.
Verizon North
Inc.
143004791
$52,350 81%
$
42,403
$
9,946
1984430
Telecom
Qwest
Long Distance Voice Services for approx 300 Lines. Currently provided
Communications 143001157
by Qwest on a MTM basis.
Corporation
$13,375 81%
$
10,834
$
2,541
1984435
Telecom
Cellular Voice and Data Services for approx 35 existing plus 15 new cell
phones and laptops. Currently provided by Verizon Wireless on a
Verizon Wireless 143000677
MTM basis.
$31,918 81%
$
25,854
$
6,065
1984439
Internet
1984445
Web Hosting Services for District website, includes all eligible services.
In addition, the District requires additional, non-eligible services for
district operations including but not limited to Website design and
Internet
mgmt, Forms Design and Mgmt, Database design and mgmt, online
payments and other features. Vendors shall clearly separate pricing
for all non-eligible services proposed.
1.4
1.5
1.6
471 App # 733886 / 64562
2010
FRN
1.3
2010
471#
High Speed Internet Access currently under MTM agreement with
Aero Internet, 10mb at startup, upgradeable in 1mb increments to at
least 20mb with no new equipment.
Aero Internet
Services, Inc.
143010090
$23,400 81%
$
18,954
$
4,446
Schoolwires
143027372
$10,000 81%
$
8,100
$
1,900
Total Requests
(Sample Project Tracking Spreadsheet )
$290,729
$235,491
Oct-Nov, 2011
Line #
Form 471 Project Tracking Spreadsheet
$55,239
59
Oct-Nov, 2011
Form – 471 – Item 21 – Paper Example
Step 7: Item 21 Attachments for Form 471 - Applicants - Schools and Libraries - USAC
Training Website SLD Training Site
60
Oct-Nov, 2011
Form – 471 – Item 21 – Online Example
Training Website SLD Training Site
61
•
•
•
•
•
•
•
•
Service Provider Hotline (1-973-428-7335)
User Hotline (1-888-203-8100)
Online “Submit a Question” www.slforms.universalservice.org
Email Questions to: questions@sl.universalservice.org
Search Reference Area: Reference Area - USAC
SLD Newsbriefs: News-briefs - Schools & Libraries – USAC
Training Website: SLD Training Site
One Page Guidelines: SLD TIP Sheets
• SLD Training Presentations
http://www.usac.org/sl/about/training-presentations/trainingpresentations-archive/training-2008/fall/materials.aspx
• E-Rate Central Newsletter (example)
–
http://www.e-ratecentral.com/subscribe.asp
Oct-Nov, 2011
SLD E-Rate Resources – When you need help…
62
E-Rate Resources
Oct-Nov, 2011
(questions@sl.universalservice.org)
63
Forms 471 are reviewed by Program Integrity Assurance
(PIA) for compliance with program rules concerning areas
such as:
• Competitive bidding process
• Contracts
• Discount Calculation
• Sufficient Budget
• Establishing Form 470
• Technology Plan & CIPA
Oct-Nov, 2011
PIA Review – What is it ?
64
Source: http://www.usac.org/sl/about/training-presentations/trainingpresentations-archive/training-2009/fall/materials.aspx
(Pre-Commitment Corrections)
Clerical
Corrections
Examples:
• Entered the incorrect amount (i.e., data
entered $100 instead of $1,000)
• Omitted an entity from the Block 4
• Provided the incorrect Form 470 number
on the Form 471
• Selected the wrong category of service
• Submitted an unsigned contract to PIA
• Omitted an FRN
Oct-Nov, 2011
PIA Review – Corrections Allowed
65
• At the end of the review, your reviewer must give you an
opportunity to respond to any reductions or denials
Oct-Nov, 2011
PIA Review – Know Your Rights
• Applicants can cancel or reduce funding requests as a
result of PIA-detected errors
• Applicants can “split out” services or entities into
separate (new) funding requests.
66
Oct-Nov, 2011
PIA Review – If you don’t comply – you will be denied.
SLD Training Presentations FY2010
67
Oct-Nov, 2011
Denials Tip
Sheet
..\Training Presentation Fall 2010\Tip Sheets\Tip Sheet common-applicant-errors.pdf 68
• You will receive an FCDL (Funding Commitment Decision
Letter)
– cover page of important reminders
– reports status of individual funding requests:
o
funded
o
not funded
o
as yet unfunded (Priority 2 requests)
o
cancelled
– may receive more than one FCDL
Oct-Nov, 2011
E-Rate Approval & Acceptance!
69
Oct-Nov, 2011
E-Rate Form 486 – Accepting the Funding
Step 10: Form 486 Filing Information - Applicants - Schools and Libraries - USAC
70
• Notifies USAC that services have started and
invoices can be paid
• Certifies that Tech Plan (if required) is in force and
meets program requirements.
• Certifies that CIPA is in force and meets
requirements.
Oct-Nov, 2011
E-Rate Form 486 – Certifications Required
71
• Form 486 must be filed online or postmarked no
later than
– 120 days after the Service Start Date OR
– 120 days after the date of the FCDL
whichever is later.
• If the Form 486 is late, the date 120 days before
the Form 486 online filing or postmark date will
become the start date for discounted services and
funding may be reduced.
Oct-Nov, 2011
E-Rate Form 486 Deadline
72
• Applicants must use SPI (Service Provider
Invoicing) or BEAR (Billed Entity Application for
Reimbursement) process to actually GET THE
MONEY.
• CTF participants must use DISCOUNTS
• Contact your vendor if not sure (most vendors
have standard forms for E-Rate discounts)
Oct-Nov, 2011
E-Rate Reimbursements
You Have To Ask For The Money
73
• Requests for extensions must be postmarked or received by
USAC as soon as possible after the last date to invoice
• USAC provides for the extension of invoice deadlines under
certain conditions, such as
– authorized service provider changes
– authorized service substitutions
– USAC errors (for example, in data entry) that ultimately
result in a late invoice
– circumstances beyond the service provider’s control
If you need more time to invoice, file an invoice deadline extension request
Oct-Nov, 2011
INVOICE DEADLINE IS 10/28 – every year
74
• Setup an electronic and paper file for each
funding year
Oct-Nov, 2011
Record Retention – “if it isn’t written down it didn’t happen”
• Make a checklist of included items
• Make a spreadsheet across years
• Monitor at least monthly
• Build an E-Rate Binder
75
• Downloadable Table of Contents Guide
• Downloadable Table of Contents (Word document
Oct-Nov, 2011
Record Retention – USAC Guidance
preformatted for Avery© Ready Index 10)
• Located in USAC web site Reference Area
http://www.usac.org/sl/tools/reference-area.aspx#c
76
• Change FRN Start Date
• Contract Extensions
Oct-Nov, 2011
E-Rate Changes – Form 500
• FRN Reductions
• FRN Cancellations (Unused Funds)
77
• You must notify SLD of any changes in the
services that have been approved
–
–
–
FRN Implementation Extensions – you need more time
to implement a Priority 2 project
Service Substitutions – you change your Internet from
a DSL line to a T1 line
SPIN Changes – your ISP goes out of business and you
need a new provider
• There are standard SLD processes for all of
these (and more)
• Examples and assistance at SLD website or ask
for help.
Oct-Nov, 2011
E-Rate Changes – Stuff Happens…
78
• USAC decisions can be appealed to USAC or to the FCC.
– generally, appeal first to USAC.
– can appeal to the FCC if USAC denies.
Oct-Nov, 2011
Appeals
• Can be filed electronically or on paper.
• Must be filed within 60 days of the USAC decision.
• Requests for waivers of rules must be filed with the FCC.
File an Appeal - Schools and Libraries - USAC
79
• Applicants and service providers certify and
agree to be audited for up to five years from end
of service
• Some are random
• Some are not (whistle-blower complaints)
• You will receive advance notice of the audit
• Auditors can be from USAC, the FCC or external
auditors
Understanding Beneficiary Audits - Schools and Libraries - USAC
Oct-Nov, 2011
Audits – Why me?
80
• Maintenance charges only for “work performed”
• More rollovers of funds => apply for P2
Oct-Nov, 2011
Changes for Year 2012
• Increased scrutiny of ‘Gifts’
• Impact of expanded use of wireless Internet (cell
phones, ipads, tablet computers) is still undefined,
but changes are coming…
81
Oct-Nov, 2011
Changes for Year 2012
82
• Document everything
• Email yourself
• Build and retain an “E-Rate Binder”
• Plan for eventual audit
• File for BOTH E-Rate and CTF
Oct-Nov, 2011
Final Tips
83
471 Filing Window:
Oct-Nov, 2011
FY 2011 Window – not yet announced
opens at noon (EST) on ????
closes at 11:59pm (EST) on ????
LAST DAY FOR Form 470 is ????
84
BTU Consulting, LLC
Oct-Nov, 2011
Information & Assistance
Email to:
Carol Underriner: carol@btu-consultants.com
Lori Thompson: lori@btu-consultants.com
Don Dietrich’s email: ddietrich01@earthlink.net
Don Dietrich’s Cell Phone: 314-378-1667
85
Oct-Nov, 2011
Questions & Evaluation
86