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Learn about the E-rate program, which provides discounts on broadband, internet, and voice services for libraries in Pennsylvania. Presented by Julie Tritt Schell, PA E-rate Coordinator, at the PaLA Conference in October 2015.
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E-rate Training Workshopfor Pennsylvania’s Libraries Presented by Julie Tritt Schell PA E-rate Coordinator for the Pennsylvania Department of Education October 2015 PaLAConference
What is E-rate? • Federal program overseen by FCC, run by USAC • $3.913 billion cap, plus unspent $ from prior years • Provides discounts ranging from 20-90% on broadband, internet and voice services, and 20-85% on internal connections equipment • All services/equipment must be competitively bid on USAC website for at least 28 days
Library Discount Calculations Two factors determine library discounts: • The percentage of students that qualify for NSLP from the school district in which the library’s main branch is located and • Whether the main branch of the library is located in a “rural-designated” area • Urban applicants are those with addresses in an “urbanized area” or “urban cluster” • Urbanized areas have populations of 50,000 or more • Urban clusters have populations between 25,000 – 49,999 • All areas that are not considered “urban” are classified as rural
2 Ways PA Libraries Apply for E-rate • Individual Libraries • Most PA libraries should apply as the Main Branch of their library, and not as a library system • USAC calls them Independent Libraries • Library Consortia • Systems purchasing shared services on behalf of other libraries, such as Internet Access or broadband services, would be considered an E-rate consortium -- not a system • Systems applying for discounts on their OWN services would be considered an Individual Library
2 Ways PA Libraries Apply for E-rate • Individual Libraries • Would be considered the ‘Main Branch’ • Libraries use the NSLP data of the school district in which they are located • If the library contains branches, the branches would be included on the application, but still using the NSLP data of the district in which the main branch is located • Library Consortia • Discounts would be calculated as the simple average of the consortium members' discounts • Consortium lead should have some documentation (such as a Letter of Agency or consortium agreement) where the consortium members have granted the consortium lead to apply for E-rate discounts on their behalf
Where to Find NSLP Data • PDE NSLP Data is available on the www.e-ratepa.org website • However, beginning in FY 2016, the library will not provide any discount calculation data • The library’s EPC Portal will identify which school district the main branch is located • The district will have their enrollment/NSLP data in THEIR own EPC Portal • The new Form 471 will draw the school district and its NSLP data directly from the EPC portal of the school district that the library has “associated” itself with in the library’s EPC Portal
What’s Eligible for Category 1? • Category 1 (to the building): • Telecommunications/broadband services • Lit leased fiber and Leased dark fiber • Ethernet • T-1 lines • Cable modem/DSL service • Purchase of dark fiber beginning in FY 2016 • Internet access • Filtering is not eligible • Voice services (being phased out by 20%/year) • PRIs, VOIP, local, long distance, cellular voice – eligible • Data plans, DID blocks, special calling features – not eligible • Only exceptions for mobile data plans are for bookmobiles, or where you can prove that they are more cost effective than installing WIFI in the library
What’s Eligible for Category 2? • Category 2 (inside the building): • Internal connections • Wireless equipment (WAPs/controllers) • Internal wiring • Hub, routers, switches • Firewalls, racks, UPSs (to support eligible equip) • Caching servers (this is the only eligible server) • Basic maintenance of eligible IC • Warranties with separate cost are not eligible • Managed broadband services • Paying an outside vendor to own/maintain the equipment • Paying an outside vendor to maintain library-owned equipment • Eligible for $30/year/student • No voice or video equipment is eligible for C2
Category 2 - Other • Training on how to use eligible equipment is eligible • Installation and configuration is eligible • Doesn’t have to be provided by the same vendor • Multi-year licenses are eligible and can be required in full in first year • Eligible equipment may be purchased and/or installed on or after April 1 prior to the beginning of the funding year
Category 2 Overview Maximum Category 2 discount is 85%
Priority 2 Funding Budgets • Most library buildings are eligible for a pre-discount cap of $2.30 per square foot or a minimum building cap of $9,200, over a rolling five-year basis • Square footage shall include areas off-limits to the public • Only indoor footage may be counted • Money is allocated per libraryand applicants cannot move funding from one library to another • Annual application is required and funding approval is subject to available funds each year
Urban Library – Larger C2 Budgets • $5.00 per square foot for libraries located in • in urbanized areas within principal cities with a population over 100,000; or, • in areas outside of a principal city, but within an urbanized area with a population of over 250,000. • These libraries have a locale code of 11, 12 and 21 as assigned by the Institute of Museum and Library Services (IMLS). • List also found here: http://e-ratepa.org/?p=5321
Priority 2 Funding Budget Example • The Budget Cap is the pre-discount price, not the E-rate eligible price. E-rate discounts will then apply on top of the budget cap. • * Although 505 x $2.30 = $1,161.50, the minimum floor is invoked because library has less than 4000 square feet
Priority 2 – Admin Buildings • Library Administrative Buildings (that are not actual libraries) are not eligible for Category 2 funding • However, if the admin building houses the WAN/WLAN central equipment (such as the network operations center, C2 equipment may be located there • Libraries must allocate a portion of each library’s $2.30 or $5.00 budget toward the purchase of such equipment
New EPC Portal Required • Beginning NOW, all entities applying for E-rate (or included on a consortium application) must set up an E-rate EPC Portal • Complicated process AND non-intuitive portal • Each Billed Entity will have an Account Administrator who must set up the library’s account • The AA will then assign other users, designate consultants, enter enrollment/NSLP data, join consortia, etc • If you haven’t yet set up your EPC account, do it now • FY 2016 Form 470 MUST be filed in EPC
Application Process – 7 Easy Steps • Bid All Services/Equipment – Form 470 • Vendor Selection/Bid Evaluation • Request E-rate Funding – Form 471 • Application Review – PIA • Funding Commitment – FCDL • Turn on Funding/CIPA Compliance – Form 486 • Submit Invoice to USAC – Form 472 BEAR • If paying invoices in full • Vendor submits invoice to USAC if you receive discounted bills
Step 1: Posting the Form 470 • Form 470 opens the competitive bidding process for any new contract • If multi-year contract signed, 470 not required in out years of contract • RFPs may be used to describe specific needs and circumstances, but aren’t required • If available, RFPs must be uploaded into Form 470 when it’s posted • Descriptions of equipment/services cannot be manufacturer-specific • Form 470 must be filed in EPC Deadline: Form 470 must be posted online at least 29 days before the Form 471 window close (example: March 18 close = Feb 18 deadline). File 470 by Thanksgiving, if possible
Step 2: Vendor Selection/Bid Evaluation • After the Form 470 has been posted online, vendors submit proposals to the library • Proposals must be accepted for a minimum of 28 calendar days, but applicants may accept proposals after this date • Vendors will contact you if they need additional information • When contacted by a vendor, you must indicate your willingness to receive a proposal for services listed on Form 470 • Do NOT say you are just going to stay with your current vendor • On 29th day after Form 470 is posted (called the Allowable Contract Date), you may conduct your bid evaluation and select a vendor • Price of eligible services/equipment MUST be the most heavily weighted factor during bid evaluation
Vendor Selection/Bid Evaluation • Vendor selection must be done before you submit Form 471 • Be careful not to make any decisions, sign anything or file any forms during 28-day waiting period • Contracts must be signed and dated by applicant • Unless receiving services on month-to-month basis • Cannot select 2 vendors to provide the same service • FCC believes there should always be one bidder that is more ‘cost effective’ than any other
Step 3: Filing the 471 • Purpose of the Form 471 • Formally requests E-rate funding commitments from USAC • Shows discount calculations • Asks which 470 was used to bid services, what were contract signing dates, contract amounts, etc. • Asks detailed questions about services or equipment • Asks which entities (buildings) are receiving the service/equipment • Asks for upload/download speeds of services • Filed by entity that actually pays the bills (the billed entity)
When and How Many to File • 471 Application Window: Likely early January – Mid March Do NOT miss this March deadline! • Can file a single 471 for all C1 requests • Multiple Category 1 471s are ok • Category 2 requests must be placed on a separate 471 • New Form 471 for FY 2016 • Not yet available • Must be filed in EPC Portal • Enrollment and NSLP data will be pre-populated using EPC Portal data
Step 4: PIA Review • Program Integrity Assurance (PIA) Review • Checks for rule compliance • eligible services • eligible entities • appropriate discount • Almost everyone receives a PIA contact • Applicants have 15 days to respond • If they are going to deny an FRN, they will tell you so and give you 1 more chance to submit new information • Check application status on SLD website • Under Form 471 Column of ‘apply online’ page
Step 5: SLD Issues FCDL • FCDL = Funding Commitment Decision Letter • Beginning in FY 2016, will be delivered in EPC Portal • Tells you which funding requests (block 5’s) of Form 471 are approved or denied • Provides information for the next form - Form 486 • Can appeal if you don’t agree with your decision* • Must do so within 60 days • Appeal to SLD if they made an error • Can then appeal to the FCC if USAC denies • Appeal to FCC for waivers and policy issues • Watch PA E-rate listserve for weekly wave notices!
Step 6: Filing the Form 486 • Form 486 signifies that it’s OK for SLD to pay any invoices for that FRN, AND certifies CIPA compliance • Deadline: Must be certified no later than: • 120 calendar days after the Service Start Date featured on the Form 486 or • 120 calendar days after the date of the Funding Commitment Decision Letter whichever is later • Submit online using info from FCDL • Use 07/01/2015 as service start date for FY 2015 • Will be done in EPC for FY 2016 • USAC then issues the Form 486 Approval Letter to vendor and applicant
CIPA Requirements Any library receiving either Internal connections or Internet access must... • Filter all Internet access • Have an Internet Safety Policy that addresses required elements • Policy must have been adopted after public hearing • Recipients only receiving telecommunications services are exempt from E-rate CIPA compliance • If you apply for just telecom, but are in an Internet consortium (perhaps through a system), you must be CIPA compliant • Consortium members submit Form 479 to consortium leader certifying compliance in order for consortium lead to submit Form 486
Step 7: Receiving E-rate Funding! • Applicant has a choice • Discounts on bills (vendor invoices USAC) or • Reimbursement process (applicant pays bills in full, then invoices USAC) • Must select one or the other for entire year • If you want discounted bills, call provider and file Form 486 as soon as you are funded • Vendors sometimes have additional forms to complete to proceed with discounted bills
Discounted Billing Method • Discounts appear on applicant’s bill • Service provider submits Form 474 to USAC after providing discounted bill • the Service Provider Invoice Form (SPIF) • Providers usually get reimbursed by USAC within 30 days from date of submission • Applicants do nothing except make sure they are receiving the discounts they deserve on bills • Do the math!
Reimbursement Method - BEAR • Applicant pays bill in full • Applicant submits Form 472 – BEAR Form for reimbursement* • Quarterly, semi-annually, or at end of year • Complete one BEAR for each SPIN • Calculated based on eligible charges on actual bills • Not AP register or amount committed • Subtract ineligible charges • Deadline: • October 28 (following close of funding year) for recurring services; • January 28 for non-recurring services/equipment • Can request 1 extension • Request must be submitted prior to invoice deadline
Reimbursement Method - BEAR • FY 2014: • SLD approves BEAR and sends approval letter to vendor and copy of letter to applicant • SLD then sends check to vendor • Vendor must send check to applicant within 20 business days of date on BEAR approval letter • Starting July 1, 2016: • SLD approves BEAR and posts approval letter in EPC • SLD then sends check to applicant • Applicants will need to provide bank account information to USAC in order set up EFT arrangements • USAC doesn’t mail checks
Want E-rate Training? • EPC Portal training: • October 8 – 1:00 • October 15 – 10:00 • Beginners training: • November 11 – IU 7 • November 13 – IU 15 • November 15 – IU 24 • Veterans webinar: TBD • Form 470 Window is OPEN NOW • Form 471 Filing Window will open from January – mid March
E-rate Help • SLD • Client Service Bureau (CSB) • E-rate “Help Desk” where applicant & service providers can get answers to questions • Accessed via 888-203-8100 • ‘Submit a Question’ on SLD website • PA E-rate Coordinator • E-mail jtschell@comcast.net • www.e-ratepa.org