Idaho E -Rate Update

1. Idaho E-Rate Update Fall 2013 • Rex Miller

2. Introduction • E-Rate requires ongoing attention • Today’s session is focused on the E-Rate filing window and approval process • Seek out experienced assistance • Some errors are still difficult to correct • Contradiction leads to denial • Get it right the first time • Filing season is near – key items to note: • Deadline – just set this week – March 26, 2014 • Q & A • At the end of the presentation • ENA is available at your convenience

3. ENA Background • Customer service and education focus • K-12 customized service • E-Rate expertise • E-Rate Program Service Provider since Year 1 (1998) • Experienced E-Rate team • Rex Miller, April Scott, Kris Vivrette, Madeline Dusenberry, Ward Chaffin • E-Rate Service Provider Leader • A Top-10 E-Rate Service Provider • Over $500M in E-Rate funded • $130M+ in 2013 E-Rate filings

4. E-Rate in a Slide • $2.3 Billion Technology Matching Program • Run by FCC and its “agent” SLD • Paid for by Universal Service Fees – not by Congress • Administered differently than other education programs – more like IRS audit • Eligible service to eligible sites for eligible users • Priority 1 – Telephone and Internet • Priority 2 – Internal Connections/Basic Maintenance • Schools, Libraries and Admin Sites can be eligible • Typically K-12 students, teachers and admin • Annual application process • Technology Plan may be required as starting point if P2 funds requested • Open procurement run by state/local • Annual funding form (471) listing amount, vendor and matching % • Matching % based on Free/Reduced Lunch info • Detailed forms and deadlines required every step of the way • Funds Flow – reimbursement (BEAR) or vendor discount (SPI) • Documentation– if not kept, funds can be denied or revoked/recovered

5. E-Rate Annual Timeline - Recurring • Fall • Update Technology Plan (if needed) • Do procurements for new services if needed (form 470) • FCC updates Eligible Services List • FCC sets application deadline • Winter • Complete Funding Application (471) by deadline – March 2014 • Begin responding to Application questions (PIA) • Spring • Get Tech Plan Approval Letter (if needed) • Receive Funding Commitment (FCDL) • File Service Start and CIPA Compliance Form (486) • Required before vendor can bill SLD • Summer • Complete installation of new services • Begin receiving bills for services –continuing • Begin filing reimbursement forms (BEAR 472) if applicable

6. E-Rate News • Window dates have been set • Opening January 9, 2014 • Closing March 26, 2014 • Similar to last year • Growth in Priority 1 funding requests • Rising above funding cap • Funding reforms/ConnectED/E-Rate 2.0/NPRM • Lots of ideas – unlikely to impact ’14-15 • Still enough funds for P1 – but getting tight • P2 funding unlikely to be available – or only 90% • Eligible Services List issued for ’14-15 • Very little change from ’13-14 • Web hosting –eligibility of ancillary components • Dark vs. lit fiber – construction charge eligibility

7. SLD Training Topics • FCC Appeal Order related to RFPs: • Relates to 470s that do not have an RFP (box not checked) • If any additional information is made available only to entities that contact the applicant, the FCC may deem that to be an “RFP” • If you have an “RFP” and do not check the RFP box on the 470, you will be denied funding • This is a difficult area for many districts as “RFP” typically has a very specific meaning in local/state procurement law • Best practice: consider the term “RFP” on the 470 to mean any written information describing services to be procured that is not included on the 470 • If you are providing interested vendors with additional information – via your website or a written document – check the RFP box to protect yourself • If you only have conversations with those that call or e-mail, you are likely OK • Use of multiple providers – application of cost-effective rule • Applicants cannot award an RFP to multiple providers for the same service at different costs • SLD has indicated that using multiple providers for services such as web hosting or cell phone service might be considered ineligible

8. E-Rate Tips and Notes • E-Rate requires ongoing attention • Consider the cost/benefit of how your district does E-Rate filings • Do you have an internal expert on E-Rate? Is it the right person? • E-Rate is only as good as the foundation • Must follow rules for tech plan and 470/procurement to get funding • If a procurement is canceled, cannot reuse original 470 • Need a new one! • Don’t let your district be an island • Seek out experienced assistance • Some errors are still difficult to correct • Contradiction leads to denial • Get it right the first time

9. E-Rate Tips 2014 • Open eligibility items • Free devices with purchase of eligible service • Cell phone is eligible if offered for free to public • VoIP phone, laptop, handheld device, etc. – not currently eligible • Separate NPRM issued – FCC intends to close this loophole beginning ’14-15 • Wireless access points • On-premise managed wireless access points currently ineligible • Under further FCC review • Mentioned heavily in NPRM • Use of different technologies for same purpose creating E-Rate inconsistency

10. E-Rate Tips 2014 • Form 470 • New FCC guidance – applicants will no longer be penalized for choosing the wrong Priority 1 category on their 470 • 470 Form is changing • Still need to select the right category on the 471 – Telecom or Internet Access • Flexibility is valuable – consider both P1 categories • If you want a multi-year contract, consistency is key • Make sure your 470, RFP or other bid documents and contract are consistent • Cannot add renewal options after initial 470/contract process • FCC Order – “and equivalents” • Cannot list a brand name but can list “brand name and equivalents” • PIA review • Remember to answer their specific questions • Providing extra information creates more work for all parties • The SLD must review everything you send them • Communicate in writing with PIA • Phone calls have no record and can result in misunderstandings with SLD

11. E-Rate Rulebook Break

12. NPRM – Modernizing E-Rate • FCC issued very extensive NPRM with hundreds of topics about modernizing the program • Newly appointed FCC Chairman Wheeler is a new element to this process • Topics included: • Broadband goals and measurement • How to lower cost of service – with a presumption perhaps that schools can’t • Potential reset of priority system • Potential development of separate fund to promote fiber ownership • Consideration of eliminating E-Rate for voice service or traditional voice service • How to get more funding for internal connectivity to devices used at schools – wireless access points, switches, etc. • Program funding levels • Discount matrix • Streamlining program administration • And many more minute details

13. NPRM – Modernizing E-Rate • FCC received over 1,000 different sets of comments and reply comments • Many were one-pagers supporting increased funding or web hosting • Differing opinions on many levels in the comments • Some comments seemed to have universal support including: • Delivery of BEAR payments direct to applicant • Moving more E-Rate forms and information online • Consideration of multi-year contract 471 • Streamline E-Rate processes to issue funding decisions quicker • Retain flexibility of the applicant to select their provider • Given that the FCC has released the ESL for ’14-15, we do not expect the NPRM to impact ’14-15 • Be alert for potentially dramatic changes for ’15-16

14. New Forms – 470 & 471 • Changes to 470 and 471 are pending review by OMB • Form 470 – Combines Telecom and IA into one category • Form 471 – Block 2 data moved to Block 5 and focuses on broadband • Information consistent with Item 21 Attachment • Work with your service provider as needed to fill that information out correctly • Likely to be used like Item 21 Attachment in testing invoices • Form 471 – formally establishing that Item 21 Attachment is due by filing deadline

15. FCC

16. Streamlining and Simplifying • Technology Plans • New requirements apply for FY 2011 and beyond • No longer required for: • Priority 1(Telecom and Internet Access) • Still required for: • Priority 2services (Internal Connections and Basic Maintenance of Internal Connections) • ENA comment: make sure you keep your Tech Plan and Approval Letters from prior years in case you are audited

17. Tips to Eliminate E-Rate Surprises • Make sure you have a solid E-Rate team – internal/external • Staffing changes are key • Make sure documentation is transferred • Consider an E-Rate update report with deadlines and plans – perhaps quarterly • E-Rate information requests – PIA, audits and other – develop consistent process to evaluate, understand and reply with the district’s best answer • Recognize that SLD role is to prevent ANY inappropriate release of E-Rate funding • Their role is not to help you get or use the E-Rate funds – different than other programs • Gift rules tracking and compliance • Stay updated on approval status each year • Don’t get surprised by a funding denial after the start of the service year • Procurement – make sure you are comfortable that the process is simple and compliant and be ready for an audit • Documentation – make sure the files are complete and up to date • E-Rate rule updates need to be tracked and implemented in a timely manner

18. 471 Timing

19. E-Rate Timing Soapbox • E-Rate continues the trend of the later closing of filing window in March • Strongly encourage applicants who want to get approved before July 1 to file their 471s as soon as possible • Target mid-February at the latest • PIA will likely start for you before the 471 filing window is closed, so be ready • Advantages • Earlier approval • No last-minute rush to file • If you have an error, you can file another 471 before filing deadline and cancel initial incorrect filing – probably easier than using RAL process

20. Idaho E-Rate 2014-15 Information • IEN Contract remains in effect-same process as last year • State will provide certain levels of service to schools at their discretion • Schools and libraries can purchase additional services from the IEN contract • Since IEN did a 470/bid, schools do not need a new 470 to purchase off IEN contract • State will file a 471 for purchases paid for by the State • Schools will file their own 471 for any additional services • Information needed for 2014 • You will receive a packet from the State requesting documents similar to last year’s request in order to continue participating under the IEN contract/consortium • Letter of agency • Form 479 – CIPA compliance certification • Providing this information quickly will help IEN file in a timely manner

21. Resources • Contact ENA • Rex Miller – rmiller@ena.com • April Scott – ascott@ena.com • Kris Vivrette – kvivrette@ena.com • Ward Chaffin – wchaffin@ena.com • Madeline Dusenberry – mdusenberry@ena.com • SLD News Brief – make sure your are signed up for these e-mails • Go to SLD Website training section to sign up • Key info provided during E-rate window and throughout the year • Websites – • SLD – main E-Rate rule site – training/Web Ex • 2013 Fall Training materials are available and valuable • http://www.universalservice.org/about/tools/TrainingArchive/Default.aspx?div=3 • www.universalservice.org/sl/

22. Happy Holidays & E-Rate Season

23. Rex Miller • rmiller@ena.com - 615.312.6000