Eligible Services Phil Gieseler / Paul Stankus

1. Eligible ServicesPhil Gieseler / Paul Stankus Train-the-Trainer Workshop September 27-29, 2004 Schools & Libraries Division

2. Basic maintenance • Technical Services • Eligible Users and Locations • Equipment locations on Item 21 Attachment • Duplicative Services • Equipment Transfers • Cost Allocation Eligible Services • Eligible Services List • Hazards and Pitfalls • Service Substitutions • Wide Area Networks • Eligible Products Database

3. Eligible Services List • What’s New in 2005? • Formalized List • Changes in Eligibility • New Format • Web-Based Interface

4. Eligible Services List • On or Before June 30 – submitted to FCC. • FCC publishes list in Federal Register for comments. • FCC issues Final list “at least” 60 days in advance of opening of window– on or about September 15. • List is safe harbor for upcoming fund year. Source: FCC 03-323 Third Report and Order: Paragraph 40

5. Eligible Services ListFormat Changes • Standardized Product Types and Functions • Description is now 2 categories: • Description • Eligibility Description • Pages now have Funding Year Date

6. Eligible Services ListWeb Interface • Searchable format • Category • Function • Product Type • Keyword • Results grouped by Funding Bucket • Search by “All” generates entire list.

7. Eligible Services ListWeb Interface

8. Hazards and Pitfalls • Basic maintenance • Technical Services • Eligible Users and Locations • Equipment locations on Item 21 Attachment • Duplicative Services • Equipment Transfers • Cost Allocation

9. Basic Maintenance What is “basic” maintenance? • Without the maintenance, the connection would not function and serve its intended purpose with the degree of reliability ordinarily provided in the marketplace.

10. Basic Maintenance Generally eligible: • Repair and upkeep of eligible hardware • Wire and cable maintenance • Basic technical support • Configuration changes.

11. Basic Maintenance NOT eligible: • On-site technical support • i.e., contractor duty station is at the applicant site • when off-site technical support can provide basic maintenance on an as-needed basis • Help Desks • that provide a comprehensive level of support beyond basic maintenance of only eligible components

12. Basic Maintenance NOT eligible: • 24-hour network monitoring • Network management • Technical support contracts that are more than basic maintenance.

13. Basic Maintenance • If a technical support contract provides more than basic maintenance, it is fully ineligible. • Basic maintenance funding requests are in a separate Priority 2 category of service beginning in Funding Year 2005.

14. Basic Maintenance • Must be cost effective. • Agreement must specifically identify the components covered, including product name, model number, and location.

15. Basic Maintenance Question #1: Eligible or Ineligible? • Hardware maintenance contract (“break/fix”) for 40 routers, 217 network switches, 51 eligible file servers, and internal network cabling.

16. Basic Maintenance Answer– This is eligible as basic maintenance if: • Components are all eligible • Services are cost effective • Agreement provides make, model, and location

17. Basic Maintenance Question #2: Eligible or Ineligible? • Hardware “break/fix” as before, plus ongoing technical support to configure and maintain the file server and router operating systems.

18. Basic Maintenance Answer– This is eligible as basic maintenance under the same conditions as before: • Components are all eligible • Services are cost effective • Agreement provides make, model, and location

19. Basic Maintenance Question #3: Eligible or Ineligible? • Technical support described as “basic maintenance” that provides break/fix, configuration changes, and network monitoring and management.

20. Basic Maintenance Answer– A funding request for these services would be denied in full because the services go beyond basic maintenance as defined by the FCC. The ineligible components are network monitoring and management.

21. Technical Services Conditionally eligible Technical Services include: • Design & Engineering • Installation • Project Management • Training

22. Technical Services Conditions for Design & Engineering: • Basic • Necessary for installation and initial configuration • Coincident with (occurring at the same time) • Part of the same contract or bid as the related products and services

23. Technical Services Conditions for Installation: • Does not include follow-on support. • Outside the scope of eligible installation services: • Planning • Design of network architecture

24. Technical Services Conditions for Project Management: • Basic costs associated with management of installation and initial operation of eligible products and services • Part of the contract or bid for those eligible products and services

25. Technical Services Conditions for Training: • Basic instruction on the use of eligible equipment • Coincident and directly associated with installation of the equipment • Part of the contract or agreement for the equipment

26. Technical Services Technical Services that are NOT eligible include: • Consulting • Initial Planning • Operations Personnel

27. Technical Services Question #4: Eligible or Ineligible? • With tight deadlines, an applicant submits a “stopgap” funding request that specifies a possible technical configuration. • After approval, the service provider provides design and engineering to determine what changes should be made in the technical configuration.

28. Technical Services Answer– Not eligible because this is planning for network architecture rather than basic services necessary for the installation and initial configuration of the components as proposed and approved.

29. Technical Services Question #5: Eligible or Ineligible? • To provide support for a new network design, an applicant seeks funding for internal staff training that will result in their receiving industry technical certifications.

30. Technical Services Answer– Not eligible in virtually all situations. To be eligible, training must meet all of these criteria: • Provided by the same service provider as is providing the installation • Coincident and directly associated with that installation • Part of the same contract • Limited to basic training

31. Eligible Users and Locations • Also known as “Educational Purposes” • Must understand the different treatment of Priority 1 and Priority 2

32. Eligible Users and Locations Priority 1: • Eligible activities are “integral, immediate, and proximate” to: • Education of students • Provision of library services to patrons • Presumption is that activities on school or library property meet this standard.

33. Eligible Users and Locations • Some offsite telecommunications activities may also be eligible: • School bus driver using a cellular phone • Connectivity to a mobile library van • Paging service for teachers on field trips

34. Eligible Users and Locations Priority 2: • Internal connections in administrative or non-instructional buildings are only eligible if “essential for the effective transport of information to an instructional building of a school or to a non-administrative building of a library.”

35. Eligible Users and Locations Question #6: Eligible or Ineligible? • Cell phone use by a cafeteria worker? • Cell phone roaming charges for a teacher to contact family and friends during summer vacation?

36. Eligible Users and Locations Answer– Cafeteria workers are eligible users beginning in Funding Year 2004. However, these cell phone charges do not meet the presumption that the cell phone use is for educational purposes, and these charges in this example would not be considered eligible.

37. Eligible Users and Locations Question #7: Eligible or Ineligible? • A school district office is located in the high school building, and wants funding for the cabling and equipment that will support district office staff.

38. Eligible Users and Locations Answer– Since the internal connections are requested for a building that houses instruction, the request to cover administrative offices would be approved. • (If the District Office were in a separate building, the internal connections used for District Office connectivity could not be approved.)

39. Equipment locations onItem 21 Attachment • Be aware of new and important instructions for Form 471: • “For Internal Connections products, sufficient information must be provided so that the SLD understands the installation location.”

40. Equipment locations onItem 21 Attachment • Examples: • “One per school” • “District Office” • “Entity number 12345” • “One per location, except three will be installed at entity number 12345”

41. Duplicative Services • Ineligible duplicative services provide “…same functionality to the same population in the same location during the same period of time.” • SLD may request further information if funding requests appear to be seeking redundant products or services. • Example: Multiple T-1 lines are okay if supported by needs of the applicant, but not okay if the extraT-1 lines are only providing backup capability.

42. Duplicative Services Question #8: Eligible or Ineligible? • An applicant wants to use wireless networking for its portable classrooms, but copper cabling for its traditional classrooms.

43. Duplicative Services Answer– If there is no overlap in the locations served, then the configurations are not duplicative, and both technologies can be funded. • Clear information on Item 21 Attachments will help speed review of funding requests.

44. Equipment Transfers • E-rate-funded equipment may not be transferred for money or any other thing of value. • A no-cost transfer of E-rate-funded equipment may take place three years or more after the purchase of such equipment. • No equipment transfer may take place prior to three years from purchase.

45. Equipment Transfers • Exception to the 3-year transfer prohibition: permanent or temporary closing of the eligible entity. • In this case, the applicant must notify USAC and maintain records of the transfer. • Note that all entities must maintain asset and inventory records for five years.

46. Equipment Transfers • The transfer limitations do not prevent an applicant from trading-in E-rate-funded equipment for other equipment with similar functionalities. • The trade-in amount reduces the pre-discount amount of a new funding request.

47. Equipment Transfers Question #9: Eligible or Ineligible? • A school with an 80% discount rate has closed. E-rate-funded equipment from that school is transferred to another school with a 50% discount rate.

48. Equipment Transfers Answer– This is eligible. Since the school has permanently closed, a transfer that is without monetary consideration or any other thing of value can take place. The discount rates of the entities need not be comparable, but both must be E-rate eligible entities.

49. Equipment Transfers Question #10: Eligible or Ineligible? • A school has equipment that was not purchased with E-rate funds, and is trading-in this equipment to a service provider for new E-rate eligible equipment. The applicant uses the trade-in value to reduce the applicant portion owed to the service provider.

50. Equipment Transfers Answer– This is eligible because the equipment traded-in was not obtained using E-rate funds. However, the trade-in must be based on fair market value, and SLD makes a rebuttable presumption of a three-year life with straight-line amortization.