E-Rate: Post Filing W hat happens now that our applications have been filed?

1. E-Rate: Post FilingWhat happens now that our applications have been filed?

2. Topics Covered • Common E-Rate Terminology • Post Filing Processes • Funding Awards • Receipt of Services • Invoicing/Applying Funds • Priority Two Project Considerations • School Documentation • Follow-up and Tracking of Funds • 6th Report and Order Overview of Changes • 2012/2013 Reminders • Contact Information

3. Common E-Rate Terminology

4. Common E-Rate Terminology • FCC: Federal Communications Commission • USAC: Universal Service Administrative Company • E-Rate:Education Rate • Priority One: recurring telecommunication services • Priority Two: internal connections • Consultant: provides applicant with E-Rate consulting support • Service Provider: provides applicant with services related to recurring telecommunication services or internal connections • RAL: Receipt Acknowledgement Letter • PIA Review: Program Integrity Assurance; first level of application review • BEN: Billed Entity Number; a unique number assigned to the applicant, like a social security number • PIN: a unique number assigned to an applicant’s authorized representative to be used for filing and certifying forms online; it acts like a banking PIN

5. Common E-Rate Terminology • Application #: a unique number assigned to a form 471 when entered in to the online E-Rate system; each form 471 receives a unique number • FRN: funding request number; a system generated number assigned to each funding request on a form 471 • FCDL: funding commitment decision letter; a letter that is generated by USAC to communicate funding decision/s • Appeal: a pre-defined process for appealing a funding decision • Forms 470, 471, 472, 473, 474, 486, 500: will be defined in presentation • SPIN: Service Provider Identification Number; a unique number assigned to service providers • CRN: Consultant Resource Number, a unique number assigned to an E-Rate consultant • SPI: Service Provider Invoicing; a discounted method to apply E-Rate funding • BEAR: Billed Entity Application RE-imbursement; a method for receiving re-imbursements of E-Rate funding

6. Post Filing Processes

7. Post Filing Processes • RALs • Application Review/PIA • Other Reviews

8. RALs • Applicants and service providers receive a Form 471 Receipt Acknowledgment Letter (RAL) to confirm receipt of a timely-certified Services Ordered and Certification Form (Form 471). • Applicants should carefully review the RAL and must notify USAC of any data entry errors by the date specified in the letter. • If data entry or ministerial and clerical errors have occurred applicants may make allowable corrections to their Form 471 without submitting a new Form 471. The applicant must make the correction(s) to the RAL Allowable Correction Section and submit the correction(s) to USAC within 20 days of the letter date above the recipient's address in the RAL. RAL corrections are included in the original scope of work, therefore IR will complete on behalf of the applicant

9. Application Review/PIA • Each application is reviewed to ensure that Universal Service Fund support is committed only for eligible products and services as well as eligible uses by eligible entities. • Review of All 471 ApplicationsUSAC reviews all Services Ordered and Certification Forms (Form 471) to verify the accuracy of discount percentages and ensure that support is committed only for eligible products and services. USAC is committed to issuing timely Funding Commitment Decision Letters but its ability to meet that goal depends on efficient processing of application reviews. • Applicants can help speed up application reviews by: • Submitting a complete Form 471 including required certifications and Item 21 Attachments for each funding request • Responding to requests for additional or clarifying information within 15 days • Verifying that USAC has correct contact information • Compliance Audits PIA reviews are included in the original scope of work, therefore IR will complete on behalf of the applicant

10. Other Reviews USAC may conduct other levels of review • Select Review • Procedural Audits • Program Compliance Audits These types of reviews are outside of the original scope of work. If IR’s support is desired, a new agreement will be needed. Please keep in mind that these reviews are time sensitive.

11. Funding Awards

12. Funding Commitment Decision Letters (FCDL) • Following application review, USAC issues one or more Funding Commitment Decision Letters (FCDLs) to both the applicant and the service provider(s) • Describes the services funded and not funded by FRN and other relevant information for reminders and deadlines

13. Funding Commitment Decision Letter (FCDL) • You may elect to begin receiving Priority One services or acquire Priority Two hardware/equipment prior to an FCDL, but you can only do so on July 1, 20XX or after • If you elect to begin before an FCDL award, you have to pay all costs in full and seek re-imbursement at a later time and upon receipt of an approved FCDL IR will notify you directly and provide a copy of your official funding commitment decision letter once received. IR will also file any changes/appeals and begin the Receipt of Services process for your school.

14. Changes and Appeals

15. Changes/Appeals Changes • Reduction in award amount • Service Substitution Change • Service Provider Change • SPIN Changes Appeals • Appeal a denial of funds

16. Changes Reduction / Cancellation of awards: Form 500 • The Form 500 Application is the mechanism used for requesting modifications to submitted FRNs. Within this application you can submit reduction requests (there is no mechanism to request additional funding), change contract beginning and ending dates, and cancellation of an FRN (be sure….as there is no opportunity to change your mind afterwards). • It should be noted that it is the school’s responsibility to register reductions and cancellations of FRNs. IR can file Changes for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.

17. Changes A Closer Look of What’s Involved: Form 500 • Information Needed to Complete the Form: • FRN information…vendor, SPIN number, amount, etc.. • Authoritative staff’s contact information

18. Changes Best Practices: Form 500 • Make changes as you need them…do not put off for later as this typically leads to the form not being filed in time to be of use to the school • Make a copy of the completed form for your own records • Mail at Post Office using the “Notification of Receipt” service. Retain all such receipts as part of your documentation • There is no “deadline” on when to file. This form is based on a school’s need for modifying certain items within an FRN. Typically, submitted forms are addressed between 3-5 weeks.

19. Changes Service Substitutionis a change in the products and/or services specified in the Services Ordered and Certification Form, FCC Form 471. Criteria to meet for service substitutions: • The substituted services or products have the same functionality as the services or products contained in the original proposal. • The substitution does not violate any contract provisions or state or local procurement laws. • The substitution does not result in an increase in the percentage of ineligible services or functions. • The requested change is within the scope of the controlling FCC Form 470, including any Requests for Proposal, for the original service.

20. Changes Service Substitution process for initiating: • Meet criteria for service substitutions • Make application for substitutions • USAC review of service substitutions • Timeline for Requests / Corrections to Installed components • Service Substitutions initiated by service providers due to discontinued products IR can file Service Subs for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.

21. Changes SPIN Changes • Operational SPIN Changes May only be requested by the applicant. The SLD permits Operational SPIN changes when an applicant certifies that (1) the SPIN change is allowed under its state and local procurement rules, (2) the SPIN change is allowable under the terms of any contract between the applicant and its original service provider, and (3) the applicant has notified its original service provider of its intent to change service providers. Operational SPIN changes must be postmarked or received no earlier than the date of the Funding Commitment Decision Letter (FCDL) and no later than the last date to submit an invoice

22. Changes SPIN Changes • Corrective SPIN changes A request to change a SPIN that usually does not change the actual service provider. There are three categories of SPIN corrections that the SLD will consider upon written request: 1. Data entry error 2. The original service provider has, in part or whole, merged with, or been acquired by, another company 3. Other instances when the service provider indicated on the Form 471 was changed, and the applicant did not initiate the change Corrective SPIN changes must be postmarked or received no earlier than the date of your Receipt Acknowledgment Letter (RAL), unless you have been contacted by the SLD about this application, and no later than the last date to submit an invoice. IR can file SPIN changes for the applicant but since it is not within the original scope of work, additional hourly fees will be charged.

23. Changes Lets look at how to make CHANGES… Online Instructions

24. New Rules for SPIN Changes • Can no longer switch vendors because of lower price • Must select vendor that received the next highest point value in the original bid evaluation, assuming there was more than one bidder • If only one original bidder, an applicant may select a substitute service provider that satisfies its needs most effectively and efficiently • An applicant will not be required to initiate another competitive bidding process by submitting a new Form 470 • Split FRNs when transitioning to new service is acceptable • Can submit new 470 in mid-year if you want to switch for any other reason or want to sign new multi-year contract

25. Appeals An Appeal is a request to USAC to address any challenges and support in regards to a negative award finding or related to extension of time due to extenuating circumstances (i.e. hospitalization, death, etc..). Appeals must be received or postmarked no later than 60 days after the date of USAC's decision letter. It should be noted an appeal process could take anywhere from several months to several years to come to a conclusion.

26. Appeals Specific process for initiating an Appeal: • Compose a letter/narrative identifying the nature of the appeal request (on letterhead). • Utilize on-line request capability through SLD homepage under “submit a question” • Include any supporting documentation that justifies your request • If appropriate, IR can file Appeals related to the original scope of work at no additional cost.

27. Receipt of Services

28. Receipt of Services • Establishing Roles • Begin Receipt of Services • Getting Set up with Service Providers

29. Establishing Roles Establish who at your school will be responsible for the following: • Setting up service installs/start dates, project starts, signing service provider related paperwork/work orders, etc.. • Liaison to Intelagent Resources to provide relevant service related materials, i.e. invoices Intelagent Resources will handle the following on behalf of the applicant: • Form 486 filing (Receipt of Services form) • Setting up invoicing method with each Service Provider - SPI/BEAR • Filing and monitoring of the BEAR re-imbursement process

30. Begin Receipt of Services Relevant Forms Form 486 – Informs USAC that services and/or equipment identified within a filed 471 has either been received or is process of being received and allows for the program to start receiving and process corresponding requests for funds. Form 472 – Also known as the “BEARS” (Billed Entity Applicant Reimbursement ) Form is used to inform USAC of the school’s intent to submit an invoice for reimbursement of discounts. Form 474 – Also known as “SPI”. The Form 474 informs USAC of the amount of the discounts provided to eligible schools and libraries and for which the service provider seeks universal service support. Form 500 – Is used to request changes within filed FRNs (i.e.: contract dates, reductions in originally requested funds, cancellation of the entire FRN)

31. Begin Receipt of Services Important Reminder: • You may begin your service pre-funding, but you will have to pay the invoices in full until award, unless otherwise established with your service provider • Depending on when you are awarded, your discount options may change. For example the service provider may not allow credits/discounts after a certain timeframe and you will have to file BEAR re-imbursements

32. Getting Set-up with Service Providers • Service providers may have their own unique process for setting up a customer for E-Rate discounts, but discounts are only offered via credit (SPI) or re-imbursement (BEAR). • Service providers may contact you before or after an FCDL is issued to elect a invoicing method, please notify Intelagent Resources when contacted

33. Invoicing/Applying Funds

34. Funding Discount Options & Forms Service Provider Invoice (SPI): Form 474 • If SPI method has been set up, your Service Provider will submit a Form 474 to USAC, as well as their annual service provider certification, Form 473 • Your invoices should arrive with credits already applied to your totals. For example if you are funded at 80%, your invoice will show an 80% credit and you will be responsible for paying the remaining 20% which should be indicated on the statement

35. Funding Discount Options & Forms Billed Entity Applicant Reimbursements (BEAR) • The Form 472 Application identifies to the SLD that the school has received services/equipment and is seeking to be reimbursed for the items which have already been paidin full • A separate Form 472 Application must be filed for each service provider • Intelagent Resources will file BEARs on a quarterly or annual basis for applicants on an as needed basis using the online BEAR system

36. Funding Discount Options/Forms Lets look at the online filing tool… BEAR Invoice System Login

37. Priority Two Project Considerations

38. Moving Forward Your infrastructure implementation strategy is contingent on the following: • Pre funding commitment: July 1, 20XX or after without receipt of FCDL) • Post funding commitment: July 1, 20XX or after receipt of FCDL)

39. Moving Forward Pre-funding commitment: • Identify central point of contact for all E-Rate related business and become familiar with E-Rate documentation especially the form 471 and Item 21 attachments • Identify any changes or substitutions with FRNs and file appropriate E-Rate paperwork • Collaboratively create a project plan, project schedule and communication strategy and share with all relevant parties • Sign any work/install orders, issue purchase orders, etc.. for July 1, 20XX or after • As services/hardware is received, capture all E-Rate related documentation and keep for records • Pay all invoices in full and file for BEARs after FCDL is issued

40. Moving Forward Post funding commitment: • Identify central point of contact for all E-Rate related business and become familiar with E-Rate documentation especially the form 471 and Item 21 attachments • Identify any changes or substitutions with FRNs and file appropriate E-Rate paperwork • Collaboratively create a project plan, project schedule and communication strategy and share with all relevant parties • Sign any work/install orders, issue purchase orders, etc.. for July 1, 20XX or after. Be sure to inform the service provider to SPI invoicing so that your invoices come discounted • As services/hardware is received, capture all E-Rate related documentation and keep for records

41. School Documentation

42. School Documentation • Documentation Compliance Rules • Application Documentation • Post Application Documentation

43. Documentation Compliance Rules • Applicants and service providers must maintain program documentation for five years after services are received • All applicants and service providers are required to retain receipt and delivery records relating to the technology plans, pre-bidding, bidding, contracts, application process, invoices, provision of services, and other matters relating to the administration of the Universal Service Fund

44. Application Documentation Myeratedocs: myeratedocs.com • Password and Login required • Contains all application paperwork from bid docs, quotes, bid/quote responses, Forms 470 & 471, Item 21 attachments, RALs, etc.. • Contains some customer provided E-Rate materials like the online E-Rate survey data

45. Post Application Documentation Contracts, Purchase Orders, Invoices, etc.: • Purchase and Delivery of Services –Beneficiaries and service providers should retain all documents related to the purchase and delivery of E-rate eligible services and equipment. Beneficiaries must retain purchase requisitions, purchase orders, packing slips, delivery and installation records showing where equipment was delivered and installed or where services were provided. Service providers must retain all applicable documents listed above • Invoicing – Both service providers and beneficiaries must retain all invoices. Beneficiaries must retain records proving payment such as accounts payable records, service provider statement, beneficiary check, bank statement or ACH transaction record. Beneficiaries and service providers must also be able to show proof of service provider payment to the beneficiary of the GEAR • Contracts –Both beneficiaries and service providers must retain executed contracts, signed and dated by both parties. All amendments and addendums to the contracts must be retained, as well as other agreements relating to E-rate between the beneficiary and service provider, such as up-front payment arrangements

46. Follow-up and Tracking

47. Follow-up and Tracking You can use the Data Retrieval Tool on USAC’s site to access applications, funding commitments and funding disbursements Access the tool here: Online Data Retrieval Tool Or from the myeratedocs portal: www.myeratedocs.com

48. Important Reminders • If your school's Internet Safety Policy (or Acceptable Use Policy) doesn't contain at least this minimal language, you need to revise your policy before July 1, 2012:  "The school district will educate all students about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response.“ • Internet Safety Education must specifically cover the following topics: • Cyber-bullying • Social Networking • Chatrooms

49. Important Reminders • Technology Plans need to be certified by your state prior to accepting any funds for that particular funding year • 2013 Official Application filing window will most likely open in Dec. 2012 and close the first week of Feb. 2013 • Income Data Collection Process: 2012/13 income levels have been released. Please use this link to access this data: http://www.fns.usda.gov/cnd/Governance/notices/iegs/IEGs.htm • Set your application strategy meeting/conference call with IR for July and August 2012. Proposals will be provided to schools by September 14, 2012 with expectation that contracts can be signed at October board meetings

50. Intelagent Resources Contact Remy Bibaud Phone: 412-231-1515 or 412-334-1888 Email: remy@intelagentresources.com Delana Murphy Phone: 412-231-1515 Email: dmurphy@intelagentresources.com