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NAVIGATING THE E-RATE APPLICATION PROCESS: WHY ME?. Presented by: Mary Mehsikomer Network Coordinator NW-LINKS /Region 1 November 2009 . WARNING. Presentation not to be undertaken by the those allergic to Power Point Contains use of at least 10,000 acronyms
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NAVIGATING THE E-RATE APPLICATION PROCESS: WHY ME? Presented by: Mary Mehsikomer Network Coordinator NW-LINKS /Region 1 November 2009
WARNING • Presentation not to be undertaken by the those allergic to Power Point • Contains use of at least 10,000 acronyms • Liberally abuses cute clip art in a futile attempt to make content interesting • High octane caffeine is recommended throughout the presentation E-Rates 2009
WHAT THE HECK IS E-RATE? • Funded by Universal Service Fund through fees on phone bills • Provides discounts of 20-90 percent on telecommunications services • For schools and libraries • Created by Telecommunications Act of 1996 • 12 years old in 2009 E-Rates 2009
E-RATE: WHY NOT? YOU CAN DO IT! • Eligibility • Schools • Definition of Educational Purpose • Libraries • Eligible Products and Services • The Application • Audits and Documentation • SLD Website Features E-Rates 2009
ELIGIBILITY • Schools • Statutory definition of elementary or secondary school found in the No Child Left Behind Act of 2001 • Non-profit institutional day or residential school, including a public charter school, that provides elementary or secondary education, as determined under state law • Not operating as a for-profit business • No endowment exceeding $50 million E-Rates 2009
ELIGIBILTY • Schools (continued) • Must be providing elementary or secondary education as defined in state law • Minnesota allows juvenile justice and prekindergarten eligibility • Head starts eligible as prekindergarten • All head start students 100% free & reduced • No child under three years is ever eligible and must be left behind (at least as far as E-rate is concerned) E-Rates 2009
ELIGIBILITY • Public Libraries • Must be eligible for funding under Library Services and Technology Act • Must have budget separate from any other entity • Must be operating as a nonprofit E-Rates 2009
EDUCATIONAL PURPOSE • Activities that occur on 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 education purposes E-Rates 2009
MORE ON ELIGIBILITY • Noninstructional Facilities (NIFs) • Eligible for Priority 1 Services (telecommunications and Internet access) • Sometimes for Priority 2 (Internal connections) • Meet definition of educational purpose E-Rates 2009
ELIGIBILITY • Some NIF(TY) Examples • Administrative buildings • School bus barns and garages • Cafeteria offices • Facilities for athletic activities • Technology centers • Bookmobile garages E-Rates 2009
ELIGIBILITY • Products and Services • ALWAYS refer to the Eligible Services List • Make sure you use the correct year • Service Categories • Priority 1 • Telecommunications • Internet Access • Priority 2 • Internal Connections • Basic Maintenance on Internal Connections E-Rates 2009
ELIGIBILITY • Priority 1 • Telecommunications Services • Basic telephone service — wireline or wireless phone service (local, cellular/PCS, and/or long distance) • Voice mail • Transmission services (T-1, DSL) E-Rates 2009
ELIGIBILITY • Priority 1 (continued) • Internet Access • Basic conduit access to the Internet • Broadband over Power Lines (BPL) • Cable Modem • Digital Subscriber Line (DSL) • Satellite • T-x, DS-x, OC-x • Priority 2 • Internal Connections (switches, hubs, routers, wiring) • Basic Maintenance on Internal Connections E-Rates 2009
ELIGIBILITY • Priority 2 (continued) • Usually only funded at the highest level of discount (most economically disadvantaged) • Entity may only receive funding twice in five years • Check guidance and tip sheets for conditions and anomalies • SLD diagrams for lines of demarcation for eligibility E-Rates 2009
ELIGIBILITY • Organization of Eligible Services List (ESL) • Five sections • Telecommunications Services • Internet Access • Internal Connections • Basic Maintenance of Internal Connections • Miscellaneous E-Rates 2009
ELIGIBILITY • Organization of Eligible Services List (continued) • Three special areas with additional information • Special Eligibility Conditions • Glossary • Index • READ CAREFULLY E-Rates 2009
QUESTIONS • Any questions so far? • Are we still awake? • Has anyone expired from sheer despair? • Has anyone started looking on Craig’s List for a new job? • Now we’re ready to move on to THE APPLICATION PROCESS E-Rates 2009
THE APPLICATION PROCESS • WE CAN DO IT!!!! • WE ARE NOT AFRAID! • WE WILL NOT BE DEFEATED BY FORMS AND PROCEDURES! • WE ARE MINNESOTANS! • WE’RE TOUGH! • WE CAN MAKE GAS OUT OF CORN! E-Rates 2009
THE APPLICATION PROCESS – THE TWELVE, NO SEVEN, STEPS • Write a technology plan • File Form 470 • File Form 471 • Receive Funding Commitment Decision Letter • Obtain technology plan approval • File Form 486 • File Form 472 (BEAR) E-Rates 2009
THE TIMELINE • Funding Year – July 1 through June 30 • Competitive Bidding Process – Form 470 Anytime after July 1 – 28 days before end of 471 window • Services Selected – Form 471 November – February (check website for exact dates) (Opens 60 days after release of Eligible Services List from FCC) • Receipt of Services Confirmation – Form 486 120 days after USAC response from 471 letter or 120 days after the service start date • Billing Entity Reimbursement Form – Form 472 or Form 474 120 days after date of the Form 486 Notification Letter or 120 days after the last date to receive service E-Rates 2009
STEP ONE: THE TECHNOLOGY PLAN • Allow ample time for pacing the office prior to writing technology plan • Develop a technology plan • Must be WRITTEN prior to filing Form 470 (the first form to be filed) • Make sure plan has a date of creation on it that predates the Form 470 E-Rates 2009
STEP ONE: THE TECHNOLOGY PLAN • Make sure the technology plan includes all services to be requested for E-rate discount • Technology plan must cover the full program year • Plan cannot be more than three years in length E-Rates 2009
STEP ONE: THE TECHNOLOGY PLAN Technology Plans • Not required for basic telephone service • Must be approved by a certified approver before the Form 486 is filed or discounted services start, whichever is earlier (MDE) • Must cover five specific elements (needs assessment, goals and strategies, budget, staff development, and evaluation) E-Rates 2009
STEP TWO: FORM 470 • Form 470 – Services Requested • Filed by applicants to define desired services and open the competitive bidding process • Choose the correct category of service (Telecommunications Services, Internet Access, Internal Connections, or Basic Maintenance of Internal Connections) for each set of services • Observe appropriate roles E-Rates 2009
STEP TWO: FORM 470 • Filing Form 470 opens a competitive bidding process • Applicants are responsible for ensuring an open and fair process and selecting the most cost-effective provider of the desired services • Be clear and complete E-Rates 2009
STEP TWO: FORM 470 • Posted on the USAC website for at least 28 days before selection of service provider and/or signing a contract • Form 470 request must be based on the technology plan • Applicants may issue a Request For Proposal (RFP), which must also be available for at least 28 days before making a vendor selection • Receipt Notification Letter (RNL) E-Rates 2009
STEP TWO: FORM 470 • Multi-year or renewable agreements are allowed if stated on Form 470 • Tariff or month-to-month services REQUIREposting Form 470 annually • Service providers are prohibited from completing and signing Form 470 or for being involved in the bidding evaluation process • Choose the correct category of service (Telecommunications Services, Internet Access, Internal Connections, or Basic Maintenance of Internal Connections) for each set of services E-Rates 2009
BIDDING • Applicants must conduct a fair and open competitive bidding process • All bidders are treated the same • All bidders have equal access to information • All bidders know what is required of them • All bidders know any reasons for disqualification E-Rates 2009
BIDDING (continued) • Bid Evaluation • Applicants must choose the most cost-effective offering with price the primary factor • Can include other important factors for evaluating bids but these must weigh less than price • Set up a chart, evaluate the bids and keep your documentation of the process E-Rates 2009
BIDDING (continued) • What if I receive only one or no bids? • Once you have waited 28 days, you can solicit more bids • If you receive one bid and select this bid, document this fact by sending yourself an email indicating this was the only bid received E-Rates 2009
QUESTIONS? • Summary so far… • Write technology plan • Ensure technology plan has a date of creation prior to Form 470 submission • Complete Form 470 to define services sought • Use a fair and competitive bidding process • Keep all documentation • Document receipt of no bids or one bid E-Rates 2009
STEP THREE: FORM 471 • Form 471 – Products and Services Ordered • Actual E-rate application • Provides USAC with all information needed to make decisions on funding • Filed EACH year WITHIN the filing window • No vacation from Form 471 E-Rates 2009
STEP THREE: FORM 471 • Contains specifics on services ordered, quantities, from whom, at what price • Calculates discount rate and lists entities receiving services • Certifies compliance with rules and verifies that applicant has the resources to make effective use of the services E-Rates 2009
STEP THREE: FORM 471 • FCC Registration Numbers • Recommend one for each billed entity • http://www.fcc.gov – CASE link • Need federal tax ID number • NCES Numbers • Needed for each site • http://www.nces.ed.gov • FSCS Code – Libraries • http://www.nces.ed.gov E-Rates 2009
STEP THREE: FORM 471 • Calculating Discounts – The Matrix E-Rates 2009
STEP THREE: FORM 471 • Discount Calculations • Individual schools use percentage of students eligible for NSLP in the school • Library outlets/branches use the percentage of students eligible for NSLP in the school district • Shared Discounts • School districts use the weighted average of the discounts of individual schools in the school district • Library systems use the simple average discount of the school district in which they are located • Consortia use the simple average of the consortium members E-Rates 2009
STEP THREE: FORM 471 • Block 5: Funding Request Number (FRN) must include the following: • Contract information (signed) • Service start and end dates • Service Provider Identification Number (SPIN) • Eligible and ineligible amounts for each FRN E-Rates 2009
STEP THREE: FORM 471 • Item 21 Attachment • Narrative overview or description of the products and services • Line item detail and cost associated with eligible and ineligible products and services requested • Additional details - equipment location, make, model and bandwidth for all products or services to support the request • Service providers can assist applicants to complete • Receipt Acknowledgement Letter (RAL) E-Rates 2009
STEP FOUR: THE PIA • PIA is Program Integrity Assurance • They work in New Jersey • Checking for • Eligible entities • Eligible services • Competitive bidding process and contracts • Cost effectiveness • Correct discount calculations • Ability to pay for non-discount share • Proper posting of Form 470 E-Rates 2009
STEP FIVE: THE FUNDING COMMITMENT DECISION LETTER • OH HAPPY DAY – NOW YOU CAN GO TO DISNEY WORLD • Much anticipated response from SLD to Form 471 • Possible Funding status by Funding Request Number (FRN): • Funded (includes modifications) • Not funded • As yet unfunded (applicant FCDL only) • Canceled • Under Review (part of application still under PIA review) • Funds approved for specific services from identified service providers at approved discount rate • Check this to make sure all info is ACCURATE E-Rates 2009
STEP 6: FORM 486 • Form 486 – Services Confirmed • Congratulations • You’ve made it this far • Don’t mess this part up • Acknowledgement of discount approval and start of services • DON’T FORGET TO FILE IT OR YOU WILL WISH YOU HAD NEVER BEEN BORN E-Rates 2009
STEP SIX: FORM 486 • Notifies USAC that invoices can be paid • Provides the name(s) of the USAC-certified Technology Plan Approver(s) that approved the appropriate technology plans • Certifies compliance status under the Children's Internet Protection Act (CIPA) E-Rates 2009
STEP SIX: FORM 486 • 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 or • The deadline specified in the “Urgent Reminder: Your Form 486 May be Late” letter • Service Start Date • Cannot be before July 1 of the funding year E-Rates 2009
STEP SEVEN: FORM 472 OR DIRECT DISCOUNTS • Work with service provider • Form 472 – Billed Entity Applied Reimbursement • Used when entity pays bills in full and claims discount from SLD • Some providers will apply discounts directly to bills (Applicant should make sure discounts are correct) • Make sure you know which one you are doing • Discount or BEAR method must be consistent for program year E-Rates 2009
STEP SEVEN: FORM 472 OR DIRECT DISCOUNTS • Don’t neglect the BEARS • Do Form 472 (BEARS) quarterly • Online • Service provider must certify • Filed online or postmarked no later than • 120 days after the last date to receive service or • 120 days after the date of the Form 486 Notification Letter, whichever is later E-Rates 2009
DOCUMENTATION • Maintain copies of EVERYTHING • See SLD recommended list • Retain at least five years after the last date of service for that program year • Try to be organized • Set up a system • Make sure equipment is tagged and tracked • If selected for an audit DON’T PANIC E-Rates 2009
APPEALS • Decisions of the SLD can be appealed to the SLD or to the FCC • Appeal to SLD first • Can be filed electronically or on paper • Must be received or postmarked within 60 days of the SLD decision • Requests for waivers of rules must be filed with the FCC • When in doubt appeal it E-Rates 2009
COMADS AND RIDFS • Commitment Adjustment (COMAD) / Recovery of Improperly Disbursed Funds (RIDF) occur when USAC has to recover funds after the fact • Result of a COMAD/RIDF is a reduction in commitment and potentially a cash recovery • If you do not pay your debt on time, the FCC Red Light Rule will take effect, meaning you risk losing all of your funding E-Rates 2009
IT’S NOT REALLY SO BAD, IS IT? • Questions??? • Resources • Universal Service Administrative Company (USAC) http://www.universalservice.org/sl • Your telecommunications region coordinator • USAC/SLD Client Service Bureau • 888-203-8100 • Your Higher Power of choice E-Rates 2009