PIA Review

1. PIA Review Fall 2000

2. PIA Team Reviews Your 471 to Assure Compliance with FCC Rules Regarding: • Eligibility of entities • Appropriateness of discounts • Eligibility of services • Services delivered in funding year • Proper posting of 470 • Allowable Vendor Selection/Contract Date vs. Contract Award Date, 471 Signature/ Submission Date

3. PIA Reviews(Cont’d.) • Scope of work - all entities to receive service listed • True competitive process • If contract voluntarily extended, complied with posting requirements • Presence of contract (or legally binding agreement)

4. PIA Reviews(cont’d.) • “High risk” reviews • Adequacy of support resources • Consortium has “knowing” participants

5. Documentation Needed by the PIA Team • Eligibility of entities - state DOE letter, letter of accreditation • Discount - NSLP report to state, summary of student survey results • Services • Detailed list of products with associated prices that add up to funding request • Maintenance request showing equipment being maintained

6. Documentation Needed(Cont’d.) • Copies of bills if ongoing service • Quote sheet from service provider if new tariff or month-to-month service -- and explanation if request exceeds documented costs • Itemized details of one-time costs associated with Internet access or telecommunications services • State master contract -- contract number and the contract expiration date

7. Documentation Needed(Cont’d.) • Number of phone lines and/or cell phones receiving service and information about their use, if any will be used for other than educational purposes • If ineligible use, allocation of costs (percent) among eligible and ineligible • Contract in some cases

8. Documentation Needed(Cont’d.) • Adequacy of support resources • Budget information, this year and next • List of what’s in place (training already done, electrical upgrade, warranties or maintenance contracts) • Consortium • Signed documentation for all entities - letters of agency, project agreement

9. Top Denial Reasons • Form 470 not posted for service type requested • Form 470 not filed for new services requested • Application signed or submitted and/or contract signed prior to 28-day Form 470 posting period

10. Top Denial Reasons(Cont’d.) • Ineligible services ³ 30% in a funding request (threshold subject to change) • No response to request for additional information required for review within 7 days (after multiple attempts to reach applicant) • No technology plan in place (when required)

11. Top Denial Reasons(Cont’d.) • Discount % under internal connections funding threshold

12. Eligible Services • Check Eligible Services List from SLD Web Site • Service categories important -- Priority 1 versus Priority 2 -- don’t mix them up • Who can be service provider? • Basic phone service (no tech plan) • Local, Long distance, Cell, Fax • If not certain and you have no tech plan, call CSB • Be careful: voice mail, directory advertising, unpublished number ineligible

13. Eligible Services (Cont’d.) • Principles • Costs to get information to classroom generally eligible -- end-user equipment (e.g, telephone, PC) not eligible • Telecommunications (including video service) must be from eligible telecommunication provider, i.e., provides service on a common carriage basis

14. Eligible Services (Cont’d.) • WAN eligible only if leased from service provider -- recent clarification on PIA procedures: we don’t deny for internal connections to a WAN • LAN is internal connections • Service provider equipment on customer premises is Priority 1 if: • Service provider owns • Customer does not use for any other purpose • Customer’s LAN functions without it

15. Eligible Services (Cont’d.) • Amortization of service provider equipment. FCC does not want to deplete USF by full up-front purchase of service provider infrastructure - Brooklyn Public Library decision • Use is important - must be for educational purposes • Paging & phone service eligible if eligible use • Prepaid Calling cards -- ineligible because no assurance of eligible use • Remote access router -- cannot be used remotely

16. 470 vis a vis 471 • If new contract or T or MTM, must post 470 for 28 days before: • Selecting vendor • Signing contract • Signing 471 • Submitting 471 • Posting occurs when data entry is complete

17. 470 vis a vis 471(Cont’d.) • Allowable Vendor Selection/Contract Date is on 470 RNL • Don’t count it yourself. Don’t assume when your mailed form got posted. Use the 470 RNL. • Must post for correct service category • Must indicate correct scope of work • Can’t extend contract for longer than term suggested in RFP • Be careful entering Form 470 Application #

18. “High Risk” Reviews • High unit cost • Concern about free ineligible services paid for through inflated prices on eligible services • Sometimes leads to identification of vendors that have not been selected through a truly competitive process • Adequacy of support resources -- Item 25 certification • Matching share

19. “High Risk” Reviews (Cont’d.) • E-rate ineligible items - end-user equipment, training, maintenance, electrical capacity, software • If applicant can’t demonstrate resources, we must deny although FCC directed us to to take a separate look at basic telephone service • Especially important here to be ready to provide documentation that PIA is seeking

20. “High Risk” Reviews (Cont’d.) • Consortium • Applicant certifies that entities it represents have secured access • Must have documentation that members know • Consortium applicant is responsible for documentation to show adequacy of entities’ support resources

21. Form 471 Certifications • Certifications that • Schools and libraries • are eligible • have secured access to necessary support resources to make effective use of discounts • are covered by technology plans if required • complied with all applicable state and local procurement laws

22. Form 471 Certifications(Cont’d.) • will use discounted services solely for educational purposes and will not resell • have complied with all program rules (e.g., most cost-effective choice of vendor with price primary factor) • Applicant • will ensure most disadvantaged schools and libraries in shared discount calculation receive an appropriate share of services

23. Form 471 Certifications(Cont’d.) • recognizes it may be audited and will retain documentation for five years • is authorized to submit request on behalf of named entities