E-rate: A Review for 2010 - Session starts at 3pm – (slides, Nov. 10 version)

1. November 10 and 12, 2009 E-rate:AReview for 2010- Session starts at 3pm –(slides, Nov. 10 version) Steve Sanders 608-266-3856stephen.sanders@dpi.wi.gov Bob Bocher 608-266-2127cell 608-212-2773 robert.bocher@dpi.wi.gov

2. Agenda • Overview of the program • Eligibility and discounts • Technology plans • Application forms, follow-up processes • Common issues • TEACH and BCN update Video and PowerPoint: http://dpi.wi.gov/pld/erate.html

3. Overview • Created by 1996 Telecom Act • $2.25 billion annually from interstate phone revenue • Can use rollover funds • WI averages $25 million annually • FCC has regulatory and legal oversight • SLD does program administration • SLD division of USAC • Eligible applicants • K-12 public and private schools, CESAs, Head Starts • Public libraries, library systems • Program has many acronyms The Telecom Act created a program to enable “access to advanced telecommunications and information services for K-12 schools and public libraries.”

4. Check your application status at http://www.sl.universalservice.org/FY3_form471/471StatusCheck.asp

5. What Are The Eligible Services? • Priority 1 • Telecommunications services (telco’s only) • Local/long distance, wireline and wireless, voice, video, data • FCC Nov 3 Public Notice emphasizes bandwidth • Internet access • Basic access • Priority 2 • Internal connections (2 in 5 year rule) • Basic maintenance of IC (each year) • Very few WI applicants get P2 • Funding now at 85%, may drop tomid-70s Demand exceeds funds available. Priority 1: Funded first. Priority 2: Funded starting at highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.

6. 2010 Eligible Services List (ESL) • Official 2010 ESL not yet released by FCC • ESL release opens 471 filing window • FCC issued draft ELS in June • Clarifies that text messaging is eligible • Email archiving is ineligible (archiving vs. storage issue) • Interactive "white boards" are not eligible • VoIP may be applied for as telecom or Internet access • FCC Nov. 3 Notice: • Expand eligible services to PCs, staff CE?

7. If it’s not in the ESL, assume it’s not eligible Must be used in an eligible location for eligible purposes See SLD site “Determine Eligible Services” Ineligible components/services must be removed Full funding may be provided as Ancillary Use Funding requests must be cost effective Update on TEACH and BCN Eligible Services USAC will not approve funding requests that have unreasonable costs compared to the marketplace. -FCC’s 2003 Ysleta Order

8. How Much Discount Can I Get? • Discounts range from 20% to 90% • Based on free/reduced lunch eligible • Enrollment and lunch data entered on ISES • Data now being reviewed, most districts doing revisions • DPI does not verify schools using their own data • DPI posts Excel file mid-December • DPI sends file to SLD • If you use DPI data and are contacted by PIA, contact DPI • Actual Calculating Discount Methods done on Form 471

9. Discount Matrix State average is 57%

10. Technology Plans • Technology plans must be “developed” before the Form 470 is filed. (1st step in process) • Plans must support requested services on Form 470 • Plans must be approved before service begins, usually July 1, 2010 • Technology plans must cover the entire funding year for which a service is being sought. (Can’t expire before June 30, 2011)

11. Technology Plans

12. CIPA/NCIPA Compliance (Children's Internet Protection Act) • Compliance with CIPA required for: • Internet access • Internal connections • But not telecommunications • CIPA requires filtering and having an Internet Safety Plan • New law will require Internet safety policy to include educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response. See DPI’s CIPA FAQ at: http://dpi.wi.gov/pld/cipafaq.html

13. E-Rate Flowchart* (Part 1) Tech Plan before 470 Form 470 posted RNL Oct - Dec Select vendor, cost main factor. If no bids, applicant selects provider. Wait 28Days Pick vendor, sign contract RAL Submit 471 Dec – Feb ? *See also the SLD’s flowchart

14. E-Rate Flowchart (Part 2) PIA Review Applicant can appeal a denial of funding to the SLD within 60 days of date on FCDL. FCDL - Decision April - Aug SLD mails applicant and service provider a 486 approval letter. Form 486 – Service Start July – Oct BEAR (472) Discount on bills SLD mails applicant and service provider a BEAR approval letter. Form 500 (optional)

15. Forms and Deadlines

16. Form 470

17. Form 470 • 470 begins bidding process, must be filed for 2010 • If you have no contract for the requested services • Often tariffed or monthly telco or Internet service • If a contract expires on or before June 30, 2010 • File 470 once for length of multi-year contracts or contracts with voluntary extensions • 470 and any RFP must indicate this • Check 7a and b and both options under b • In out years on the 471, site the original 470 • Be sure to file for correct category of service

18. Form 470 137 WI applicants have already filed 236 form 470s. • Can file the 470 now for 2010 services • Be certain to have draft Tech Plan • File one 470 for all services, or file separate forms for each service • 470 must be posted on SLD website for at least 28 days before you select a provider or sign a contract • See “Form 470” in News Briefs(10-30 Brief) Form 470 drop dead filing date is 28 days before 471 deadline. But do not wait until then!

19. Form 470 and Competitive Bidding • Must have a fair and open bidding process • Bid document (RFP) optional, is a local decision • All vendors are treated the same; have access to same information • Vendors cannot be involved in your 470 • Applicant’s consultant cannot be associated with vendor • Must choose most cost-effective bid • Cost must be primary factor • Non-eligible products/services not part of cost effectiveness • Fully document your bid review process and any decision(s) • Record dates of any decisions, actions taken, etc.

20. Online Forms Training Site(http://sldtraining.usac.org) 470 options See Oct 3, ‘08 News Brief for training site information.

21. Checking all to keep all options open.

22. NOTE: For “Quantity and/or Capacity” be certain to enter maximum bandwidth needed. Example for schools on BCN:“20Mbps to 100Mbps service for 3,000 teachers and students”

23. Check these boxes

24. Block 4 information

25. Check all certifi-cations, enter authorized person (bottom)

26. Use Print Preview to check all data, then Submit and certify online or via paper

27. Form 471

28. E-rate Form 471 • Provides specific information on services, service providers selected, and contracts and/or agreements, costs, etc. • Provides discount calculation information • Must be filed each funding year • Applicant certifies compliance with all program rules • Must be postmarked or filed online by ??? • Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window 2010 Form 471 drop dead date:Likely Early-Mid Feb, 2010, 10:59PM CST

30. Block 1: Basic contact information

31. Record Your security code!!

32. Block 4: Calculate Discount. Adding entities (schools)

33. Block 4: Calculate Discount. Adding entities (schools) one at a time

34. Block 4: Calculate Discount. Adding entities (schools) NCES Codes: http://nces.ed.gov/ccd/schooLSearch

35. Block 5: One for each funding request. Adding entities (schools) Spin search tool http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp But VERIFY with service provider!

36. Block 5: Type of service. 470 Number Contract or Month-to-month

37. Block 5: Service start and end dates OR Contract award and expiration date

38. Block 5: Item 21 Attachment

39. Block 5 — Item 21 Attachment • ”You MUST attach a description of the service, including a breakdown of components, costs, manufacturer name, make and model number….” • Examples are provided in the document “Item 21 Attachments for Form 471” http://www.sl.universalservice.org/reference/Form471item21Attachments.asp 39

40. Block 5: • Enter Amounts. • Add another block 5?

41. Block 6: Certifications Have necessary resources

42. Block 6: Certifications: Have Technology Plan

43. Block 6: Certifications: Send Signed Certifications or PIN

44. Block 6:

45. Tips on Filing Form 471 • File separate Forms 471 for Priority 1 and Priority 2 services • Remove ineligible costs and document or estimate eligible costs carefully (30% Rule) – (Now Bishop Perry makes less important) • Filing online speeds processing and reduces errors • Examine, correct, and save Receipt Acknowledgement Letter (RAL) • Paper forms and instructions: http://usac.org/sl/tools/required-forms.aspx

46. Receipt Acknowledgement Letter (RAL) • Form 471 Receipt Acknowledgment Letter (RAL) • Cover page of important reminders • Provides confirmation of certain information entered from Form 471 • Data entry errors may be corrected within three weeks by using the RAL (including Block 4 worksheets) • Applicants can request funding reductions but not funding increases

47. Funding Commitment Decision Letter (FCDL) • FCDL reports status of individual funding requests: • Funded • Not funded • As yet unfunded (internal connections) • Canceled • May receive more than one FCDL • Use info on FCDL to prepare Form 486

48. E-rate Form 486 • Notification that services have started and that SLD can pay invoices • Certifies that Tech Plan (if required) has been approved and covers the entire funding year. • Form 486 deadline is 120 days after service starts –OR– • 120 days after date of Funding Commitment Decision Letter date, whichever is later • October 29 deadline for FCDL before July 1

49. E-rate Form 472/474 (Invoices) • Invoices — Form 472 or Form 474 • BEAR (Billed Entity Applicant Reimbursement) Form 472 filed by applicant and certified by service provider after receipt and payment for services • Form due October 28, 120 days after last service date, June 30 • Or 120 days after date of Form 486 Notification Letter -OR- • SPI (Service Provider Invoice) Form 474 filed by service provider after providing services and billing applicant for its non-discount share

50. Issues of Waste, Fraud, Abuse • W/F/A still problem in program, mostly caused by • 90% discount, P2, complex program rules • Vendors have been debarred, people are in prison • W/F/A drives many FCC decisions • More certifications • More PIA requests for information • More audits leading to more COMADs • FCC can recoup funds going back 5 years • See SLD Fall 2009 slides on audits March 2009 - A former school administrator in Michigan was sentenced to four years in prison after pleading guilty to defrauding the federal E-rate program.