E-rate Stumbling Blocks and How to Avoid or Overcome Them

1. E-rate Stumbling Blocks and How to Avoid or Overcome Them Michigan Year 5 Train-the-Trainer SessionOctober 8, 2001Jeff OgdenAssociate DirectorMerit Network, Inc.

2. Always Read the Instructions • Be sure to use the most recent versions of the forms and instructions. • The instructions for the forms (470, 471, 486, 479, 472, 500) have some of the best information about the program. • Always check the SLD’s list of eligible services (an updated version is expected to be released soon).

3. Dates and Deadlines • Don't leave everything until the last minute. • Remember that computer systems sometimes fail or get slow as deadlines and heavy usage approach. • Remember that some deadlines are “postmark” deadlines, but others are “received by” deadlines. • Don't assume that express mail services always deliver everything overnight, leave yourself an extra day or two to recover if things go wrong. • October 28, 2001 is a new deadline for submitting Form 486 with CIPA certifications. • Remember the July 1, 2002 CIPA full compliance deadline.

4. Dates and Deadlines (continued) • Wait the full 28 days after your Form 470 information is posted to the SLD Web site before signing contracts and filing Form 471. • Check your receipt notification letter or check on-line for your allowable contract date. • Have a signed contract or other evidence of a legally binding agreement before submitting Form 471. • Don't miss the end of the equal application window • This means starting well in advance of the deadline. • Don't forget to submit any required signature pages and attachments (item 21 information). • Don't miss the 30 day appeal window.

5. Don't combine multiple applications • Mail applications or their attachments separately. • Be sure to clearly mark everything (each and every page) to help the SLD keep things properly organized and also to help them recover if some pages get separated from the rest of the pages. • Remember that if we think there is too much paperwork in the E-rate process, that it must be 30,000 times worse to be on the receiving end of all of the paperwork.

6. Have an approved technology plan • Technology plans must support in general terms the items you are requesting USF discounts on. • Plans must be reapproved at least every three years. • Plans for both public and private schools are approved by the Michigan Department of Education after review by staff at Intermediate School Districts. • Plans for libraries are approved by the Library of Michigan.

7. Avoid using “flag” words or phrases • On applications or other forms, on copies of invoices, or contracts that you send to the SLD, or when talking to the SLD. • Avoid “Wide area network”, “WAN”, “modem”, “own”, “monitor”, or “Internet2” • If you aren’t sure how to describe an item, try to quote directly from the SLD’s list of eligible services. • For example: • Don't use the phrase “Wide area network” or “WAN” since wide area networks aren't eligible for discounts as part of internal connections. They are eligible as part of telecommunication services or Internet access, but it is better to use a name other than “Wide area network”.

8. Form 470 and 471 • Don't allow service providers to fill out Form 470: • You must fill out and submit the forms yourself, • You must be listed as the contact on the form, and • The Form 470 process must be open and fair to all qualified potential providers. • Make sure all items requested on Form 471 are covered by a Form 470 from this or for multi-year contracts from a previous funding year. • Beware of offers of “free” services or offers by providers to pay the applicant’s portion of the costs

9. Keep complete records of everything • Keep copies of everything you send or submit to the SLD or FCC. • Send in everything by express courier or with return receipt requested, and keep copies so you'll have a record of when you sent materials and when they were received. • Keep worksheets and work papers showing how you did calculations, who you received bids from, how you evaluated the bids, … • You are required to keep records for five years, but you’ll want to do this to protect yourself from lost materials and to help resolve disputes as well.

10. Keep a log or journal • Record what items you submitted and when you submitted them to the SLD or FCC. • Record when and who you contacted at the SLD to get questions answered as well as what they told you Sometimes e-mail or a FAX is better than the phone since you get a record of your question and the answer, but sometimes it takes much longer to get an answer by e-mail or FAX. • Record when, by whom, and why you were contacted by the SLD, and what you told them or what additional information you supplied.

11. Get your discount percentage up • By getting your school lunch figures up. • It is always better to receive a larger discount, but given the cutoffs on internal connection funding having a larger discount level of a few percent can be the difference between funding and no funding. • If your school or library is close to one of the school lunch thresholds that would get you a larger discount, think about ways to improve your school lunch figures.

12. Get your school lunch percentage up • For schools this usually means using eligibility data rather than participation data and making it the best eligibility data you can. • For libraries this means working with your local schools to find out about or even help them obtain good eligibility data rather than just using participation data. • Don't use disallowed measures such as feeder schools, projections based on title I programs, or projections based on non-random surveys.

13. Get your school lunch percentage up (continued) • There are alternatives to using school lunch program figures, but they are usually a lot of time and work and require careful and complete record keeping. • If you use school lunch figures other than the participation figures from the MIN Web site, keep information on how you developed the figures you used and where the information came from. You are free to use other information that is more recent or more accurate or which shows program eligibility rather than participation, but you have to be able to explain what you did. If you use a survey be sure to survey everyone and remember that you need at least a 50% response rate. Remember too that using pass through calculations isn't allowed, but matching siblings is.

14. Fill out the forms correctly and completely • It is always better, faster, and less work to avoid mistakes in the first place. • Sometimes the SLD will let you correct mistakes, but other times they will not. • Have someone look over the forms after you have filled them out, but before they are submitted. • Make sure that you only request items on Form 471 for categories that you requested on Form 470. • It is easy to get confused about what category something is in (is it telecommunications or Internet access or internal connections). You may not even know what category will provide you the best solution at the time you submit Form 470 and so you may want/need to request services in multiple categories on Form 470 just to be safe.

15. Fill out the forms correctly and completely (continued) • Check over Receipt Acknowledgement Letters • Submit corrections (or, if necessary, appeals) to the SLD. • Corrections in response to RALs are much faster than corrections that come later as part of PIA reviews or appeals. • When in doubt split it out! • Don't apply for ineligible services. • If you aren't sure if an item is eligible or not, apply, but make a separate funding request for each item. • If some items have both eligible and ineligible elements, you need to separate out the cost of the ineligible elements and keep records. • Don't mix items with different priorities in a single funding request. • You can use a single Form 471 for multiple funding requests, but don't combine different priority categories or eligible with possibly ineligible items in a single funding request.

16. To be eligible for E-rate discounts services and facilities must • Fall into an eligible category (telecommunication services, Internet access, or internal connections). • Must not be an item specifically excluded by the FCC • Such as Wide Area Networks as part of internal connections. • Must be delivered to eligible schools or libraries. • Must be used for eligible purposes • Delivered at a location where instruction takes place or library patrons are served rather than at a strictly administrative location. • And, in the case of telecommunication services, must be provided on a common carrier basis by a telecommunications provider. • Always check the SLD’s list of eligible services.

17. The End