e-Rate Changes for 2008

1. e-Rate Changes for 2008 What’s new with e-Rate for experienced coordinators

2. Introduction • Sabrina Carson – Willamette ESD • e-Rate Contractor for the Oregon Department of Education • Provides statewide e-Rate support to districts on behalf of the agency. • 503-540-4495 or sabrina.carson@wesd.org

3. Purpose of today’s training • Talk about some of the potential changes and new interpretations from USAC such as: • Eligible Services • Audit Document Retention • State Master Contracts • Opening , Closing, and Merging Districts and Schools. • Protecting Children in the 21st Century Act

4. Eligible Services • On August 1st, 2008, the FCC released the draft of the 2009 Eligible Services List for comment. • On August 19th, 2008, the FCC released a Notice of Proposed Rulemaking (NPRM) for comment. • Both documents sought comment on whether some services could remain on the eligible list and if some new services should be added.

5. Eligible Services The FCC proposed adding the following: • Anti-Virus/Anti-Spam • Dark Fiber • Firewall Services • Internet Filters • Scheduling Software/Services • Telephone Broadcast Messaging • Text Messaging

6. Eligible Services The FCC sought opinion on changing the following: • Basic Telephone Service – Should the category be broadened to include ALL voice communication? Should PBX and Key equipment be moved from P2 to P1? • Should VoIP continue to be eligible?

7. Eligible Services • There is concern that it is too late to make substantial changes to the ESL for 2009. • If changes are made to the ESL, it could affect the applications of those who have already filed the 470 for 2009. • Once the FCC makes a decision on the ESL, it will take time for USAC to update their processes, particularly with PIA review.

8. Audit Document Retention • There was heavy emphasis on Audit procedures this year, and a new list of Audit documents was discussed during training. • Many of the documents on the new list are either documents that have never been requested before, or are not documents that the e-Rate coordinator would normally have access to. • I am working on a checklist that will help coordinators to stay organized in case of an audit.

9. Audit Document Retention ELIGIBILITY • Financial Statements • Non-profit status (primarily for private and charter schools) • School Consortia • Listing of all schools for member districts • Documentation that supports assertion that all member entities meet the statutory definition of elementary or secondary schools. • Consortium leads obtain and maintain Letters of Authorization (LOAs) from all participating entities.

10. Audit Document Retention TECHNOLOGY PLANNING • Copy of a dated, draft plan dated prior to Form 470 submission. • Copy of the dated, final technology plan and approval letter. • Copy or copies of updated technology plans with dates. CIPA • Internet Acceptable Use Policy or Internet Safety Policy. • Record of a public hearing or notice. • Evidence a technology protection measure was in place during the audited Funding Year.

11. Audit Document Retention DISCOUNT CALCULATION • Report of NSLP, Survey, Provision I, II, III numbers, etc. used to complete Block 4 of Form(s) 471. • NSLP, Provision I, II, or III documentation submitted to the state or USDA. • Sample of applications or surveys collected. • Consortium lead should obtain and maintain discount calculation documentation of its member schools or districts.

12. Audit Document Retention COMPETITIVE BIDDING • Copy of state and local procurement regulations or policies, as well as copies of contract amendments, extensions, etc., and “vendor correspondence.” EFFECTIVE USE • High level network diagram • Inventory of end user computers located in Block 4 entities and a list of the operating systems and software in use on end user computers. • Maintenance contract(s) for end user computers. • Professional development training log/curriculum and copies of staff training agendas, materials and sign-in/attendance sheets from training sessions.

13. Audit Document Retention SERVICE DELIVERY AND INVENTORY MANAGEMENT • Fixed asset listing/Equipment inventory with enough detail to locate all equipment funded by E-rate. • Equipment packing slips. • Documentation supporting receipt of maintenance services received showing date of maintenance and detail of work performed. • Documentation supporting applicant receipt of equipment installation (sign-off of work completed). When equipment or wiring is installed, applicant performs walk through and documents acceptance of work performed.

14. Audit Document Retention INVOICING, PAYMENTS, AND REIMBURSEMENTS • Customer bills – all pages, not just summaries. The bills should provide details pertaining to the equipment or services delivered. • Support that ineligible charges were removed. • Proof of payment of non-discounted amounts. • Cancelled checks, front and back • Bank statements • Proof of reimbursement from vendor. Maintain copies of reimbursement check(s) from service provider(s), bank statements and deposit records.

15. State Master Contracts USAC provided some clarification of the rules surrounding SMC’s. • The basics haven’t changed; for “single winner” contracts, if the state files a 470, then you can file the 471 using that 470 number. If they did not, you must file your own 470 and use the SMC as a bid and compare it to any other bids. • SMC’s with “multiple winners” where each winner is designated for a certain services or geographical areas can be handled in much the same way, whether or not you filed your own 470. You would want to document why you chose the specific bidder.

16. State Master Contracts Multiple Award Schedule – when an SMC awards multiple vendors that can provide services statewide, or there is more than one vendor that can provide a given service. • Districts are usually required to do a mini-bid, with at least three quotes, if the dollar amount is high enough. • USAC’s requirements are more stringent; you must do a mini-bid with ALL available vendors on the contract.

17. State Master Contracts Some basic steps for a “mini-bid”: • Use email or other reliable and traceable means to notify vendors that you are seeking services and what your needs are. • You CAN provide a simple document outlining your needs, but to avoid time consuming Q and A, it is suggested that you create a “mini-RFP”, simple and informal. • You are allowed to specify some basic parameters for minimum bid requirements in order to minimize responses from under qualified or out of area vendors.

18. Openings, Closings, and Mergers Changes in school locations, names, and other events can reek havoc on an application, since each location to be served must have an entity number. • New entity numbers are required when: • A new facility is constructed in a new location. • A new facility constructed on an existing campus has a different address, serves multiple entities (e.g., a bus garage) not on the same campus, or is located across a public right-of-way. • Two existing entities merge to create a state-recognized new entity.

19. Openings, Closings, and Mergers • The SLD should be informed when any entity is closed, including when: • An entity is simply eliminated. • An entity is merged into another and is not considered the surviving entity. • School district or library system mergers or consolidations are governed by the same principles.

20. Openings, Closings, and Mergers Some things to remember when adding or removing entities: • Updating your technology plan – It is a best practice to list all the entities that a district serves. Also if a new school building will cause plan implementation or costs thereof to be significantly changed, you should update the plan and resubmit it for approval.

21. Openings, Closings, and Mergers • Filing a new 470 – If for some reason the change was not planned for, particularly a merger or closure, it may become necessary to file a new form 470. USAC doesn’t provide clear guidelines as to what constitutes significant change. It will likely vary depending on the size of the district and the costs associated with the change. It is advised that you err on the size of caution. Please feel free to contact USAC or myself for assistance if you aren’t sure what to do.

22. Protecting Children in the 21st Century Act • On October 1st 2008, Congress passed S. 1492: Broadband Data Improvement Act. On October 10th 2008, President Bush signed it. Title 1 addresses the need to increase the governments understanding of broadband services as a whole, and will hopefully encourage improvement of broadband services at the state level. • Title 2, the Protecting Children in the 21st Century Act, could have an immediate impact on e-Rate applicants, specifically on Technology Plans.

23. Protecting Children in the 21st Century Act • The act implements additional CIPA requirements for educating minors on appropriate online behavior, cyber bullying, and other interactions on the Internet. • The FCC and USAC have not produced any guidance as of yet, and probably won’t for some time. However, now is the time to start planning for this requirement and the necessary adjustments to your AUP and Technology Plan.

24. Questions?