e-rate update 2008

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E-rate UpdateE-rate Update20082008

Julia BenincosaJulia Benincosa

State E-rate CoordinatorState E-rate Coordinator

West Virginia Department of West Virginia Department of EducationEducation

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OverviewOverview

– FundingFunding– Service SubstitutionsService Substitutions– SPIN ChangesSPIN Changes– Form to Start Services (486)Form to Start Services (486)– Invoicing to get reimbursements (472 Invoicing to get reimbursements (472

BEAR)BEAR)– Filing Right the First TimeFiling Right the First Time– AppealsAppeals– Form 500Form 500– Returning FundsReturning Funds– MPLS!MPLS!

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FundingFunding

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Funding TimetableFunding Timetable

Funding commitments are made by Funding commitments are made by funding year (July 1 – June 30)funding year (July 1 – June 30)– Recurring services received July 1 – June Recurring services received July 1 – June

30 (12 months)30 (12 months)– Non-recurring services delivered and Non-recurring services delivered and

installed July 1 – September 30 (15 installed July 1 – September 30 (15 months)months)

The Window:The Window: Form 471 filing window Form 471 filing window (mid-November to early February (mid-November to early February before the start of the funding year)before the start of the funding year)

[USAC] encourage[s] you to file online[USAC] encourage[s] you to file online

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Funding Funding CommitmentsCommitments

USAC issues USAC issues Funding Commitment Decision Letter (FCDFunding Commitment Decision Letter (FCDL) L) to applicants and service providers when to applicants and service providers when PIA review is completePIA review is complete

Funding status by Funding Request Funding status by Funding Request Number (FRN):Number (FRN):– Funded (includes modifications)Funded (includes modifications)– Not fundedNot funded– As yet unfunded (applicant FCDL only)As yet unfunded (applicant FCDL only)– CanceledCanceled

Funds approved for specific services from Funds approved for specific services from specific service providers at the specific service providers at the applicant’s approved discount rateapplicant’s approved discount rate

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Service SubstitutionsService Substitutions

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Sometimes funding is lateSometimes funding is late– Items requested on the Item 21 are Items requested on the Item 21 are

no longer availableno longer available– Change in functionality is requiredChange in functionality is required– Products are discontinuedProducts are discontinued– Model number change/replacementModel number change/replacement

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Other reasons…Other reasons…– Applicant requires increase in Applicant requires increase in

servicesservices Example: data lineExample: data line

NOTE: Be sure that any items you NOTE: Be sure that any items you want to substitute were covered want to substitute were covered within your Form 470!within your Form 470!

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May be filed via:May be filed via:– Regular mailRegular mail– FaxFax– E-mailE-mail

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Service SubstitutionService Substitution

A service substitution is a change in the A service substitution is a change in the products and/or services specified in the products and/or services specified in the Form 471. Form 471.

Certain conditions must be met:Certain conditions must be met:– Same functionalitySame functionality– Doesn’t violation contract provisions or state Doesn’t violation contract provisions or state

and local rules/regulationsand local rules/regulations– Doesn’t increase the % of ineligiblesDoesn’t increase the % of ineligibles– Within the scope of the original Form 470/RFPWithin the scope of the original Form 470/RFP

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Global Service SubGlobal Service Sub

Involve a product and/or service that Involve a product and/or service that is being discontinued, has a model is being discontinued, has a model number change, or is being replaced.number change, or is being replaced.

The manufacturer or service provider The manufacturer or service provider may submit notification to USAC that may submit notification to USAC that the product or service is being the product or service is being changed, along with a listing of one or changed, along with a listing of one or more replacement products or more replacement products or services.services.

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Helpful Service Helpful Service Sub TipsSub Tips

Refer to your original Item 21 attachment. Refer to your original Item 21 attachment. The items and dollars from the From: section The items and dollars from the From: section must reflect those in your Item 21 must reflect those in your Item 21 attachment.attachment.

Be sure to include the dollar amounts, Be sure to include the dollar amounts, quantities and the make and model of quantities and the make and model of equipment of the From: and To: sections.equipment of the From: and To: sections.

If one product is being substituted for If one product is being substituted for several FRNs, be sure to include the changes several FRNs, be sure to include the changes in quantity and the change in dollars (if any).in quantity and the change in dollars (if any).

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Helpful Service Helpful Service Sub TipsSub Tips

Be sure to include your contact Be sure to include your contact information: e.g., name, phone information: e.g., name, phone number, fax and e-mail.number, fax and e-mail.

If substituting multiple products, If substituting multiple products, include a spreadsheet.include a spreadsheet.– Digital copies are best (faxes can be Digital copies are best (faxes can be

hard to read)hard to read)– Send to USAC via Submit a QuestionSend to USAC via Submit a Question

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Service Delivery Service Delivery Deadlines and Deadlines and

Extension RequestsExtension Requests

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Service Delivery Service Delivery Deadlines and Extension Deadlines and Extension RequestsRequests

Non-recurring services must be Non-recurring services must be delivereddelivered and and installedinstalled between July 1 of the relevant between July 1 of the relevant funding year and September 30, following funding year and September 30, following the June 30 close of that funding year (i.e., the June 30 close of that funding year (i.e., 15 months after the beginning of the 15 months after the beginning of the funding year). funding year).

Certain recipients have received or may Certain recipients have received or may receive extensions of the deadline for receive extensions of the deadline for delivery and installation of non-recurring delivery and installation of non-recurring services. services.

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Such extensions can occur for various Such extensions can occur for various reasons, including:reasons, including:

1.1.A Funding Commitment Decision Letter A Funding Commitment Decision Letter (FCDL) is issued by USAC on or after March (FCDL) is issued by USAC on or after March 1 of the funding year for which support is 1 of the funding year for which support is authorizedauthorized

2.2.Service provider change authorizations or Service provider change authorizations or service substitution authorizations are service substitution authorizations are approved by USAC on or after March 1 of approved by USAC on or after March 1 of the funding year for which support is the funding year for which support is authorizedauthorized

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Such extensions can occur for various reasons, Such extensions can occur for various reasons, including:including:

3.3. The applicant requested an extension because The applicant requested an extension because the service provider was unable to complete the service provider was unable to complete delivery and installation for reasons beyond the delivery and installation for reasons beyond the service provider's controlservice provider's control

4.4. The applicant requested an extension because The applicant requested an extension because the service provider has been unwilling to the service provider has been unwilling to complete delivery and installation after USAC complete delivery and installation after USAC withheld payment for those services on a withheld payment for those services on a properly-submitted invoice for more than 60 days properly-submitted invoice for more than 60 days after submission of the invoice.after submission of the invoice.

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SPIN ChangesSPIN Changes

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SPIN Changes--SPIN Changes--CorrectiveCorrective A request to correct a Service Provider A request to correct a Service Provider

Identification Number (SPIN) is a request to Identification Number (SPIN) is a request to change a SPIN that usually does not change the change a SPIN that usually does not change the actual service provider. There are three actual service provider. There are three categories of SPIN corrections that the SLD will categories of SPIN corrections that the SLD will consider upon written request. consider upon written request.

1.1. USAC made a data entry error - or you did: USAC made a data entry error - or you did: Service provider or SPIN is incorrectly named or indicated Service provider or SPIN is incorrectly named or indicated

in a Receipt Acknowledgment Letter or a Funding in a Receipt Acknowledgment Letter or a Funding Commitment Decision LetterCommitment Decision Letter

(PLEASE NOTE: SPIN corrections CANNOT be used in a (PLEASE NOTE: SPIN corrections CANNOT be used in a situation where the original Funding Request Number situation where the original Funding Request Number (FRN) was denied (such as, for Telecommunications (FRN) was denied (such as, for Telecommunications Services where the service provider was determined not Services where the service provider was determined not to be eligible); denials have to be addressed through the to be eligible); denials have to be addressed through the Appeals process. The SLD can grant the appeal if there is Appeals process. The SLD can grant the appeal if there is evidence that an ambiguity existed about which SPIN to evidence that an ambiguity existed about which SPIN to use.) use.)

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Service Delivery Service Delivery Deadline and Deadline and Extension RequestsExtension Requests May be filed via:May be filed via:

– Regular mailRegular mail– FaxFax– E-mailE-mail

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SPIN Changes--SPIN Changes--CorrectiveCorrective

2.2. The original service provider has, in part or The original service provider has, in part or whole, merged with, or been acquired by, whole, merged with, or been acquired by, another company.another company. Generally, the service provider will do this by Generally, the service provider will do this by

requesting a global SPIN change. A global SPIN requesting a global SPIN change. A global SPIN change may be requested only by the service change may be requested only by the service provider. provider.

There may be occasions where the service provider There may be occasions where the service provider has not requested the global SPIN change requiring has not requested the global SPIN change requiring the applicant to bring the situation to the SLD's the applicant to bring the situation to the SLD's attention and request a SPIN change. attention and request a SPIN change.

3.3. Other instances when the service provider Other instances when the service provider indicated on the Form 471 was changed, and indicated on the Form 471 was changed, and the applicant did not initiate the change. the applicant did not initiate the change.

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SPIN Changes--SPIN Changes--CorrectiveCorrective Corrective SPIN changes must be Corrective SPIN changes must be

postmarked or received no earlier postmarked or received no earlier than the date of your Receipt than the date of your Receipt Acknowledgment Letter (RAL), Acknowledgment Letter (RAL), unless you have been contacted by unless you have been contacted by the SLD about this application, and the SLD about this application, and no later than the last date to submit no later than the last date to submit an invoice.an invoice.

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SPIN Changes-- SPIN Changes-- Operational Operational An operational SPIN change may only be An operational SPIN change may only be

requested by the applicant. requested by the applicant. The SLD permits Operational SPIN The SLD permits Operational SPIN

changes when an applicant certifies that:changes when an applicant certifies that:1.1. the SPIN change is allowed under its state and the SPIN change is allowed under its state and

local procurement ruleslocal procurement rules

2.2. the SPIN change is allowable under the terms the SPIN change is allowable under the terms of any contract between the applicant and its of any contract between the applicant and its original service provideroriginal service provider

3.3. the applicant has notified its original service the applicant has notified its original service provider of its intent to change service provider of its intent to change service providersproviders

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SPIN Changes-- SPIN Changes-- Operational Operational Operational SPIN changes must be Operational SPIN changes must be

postmarked or received no earlier postmarked or received no earlier than the date of the Funding than the date of the Funding Commitment Decision Letter (FCDL) Commitment Decision Letter (FCDL)

ANDAND No later than the last date to No later than the last date to

submit an invoicesubmit an invoice Note that requests for pre-Note that requests for pre-

commitment Operational SPIN commitment Operational SPIN changes will not be processedchanges will not be processed

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SPIN Changes—SPIN Changes—OperationalOperational The new GRO (Brewster Academy) The new GRO (Brewster Academy)

guidance does allow an operational SPIN guidance does allow an operational SPIN change during PIA when the applicant has change during PIA when the applicant has a non-telecom listed by mistake and can a non-telecom listed by mistake and can show that the correct SPIN is a telecom show that the correct SPIN is a telecom provider for P1 TSprovider for P1 TS

April 20, 2007 News Brief:April 20, 2007 News Brief:"In general, an Operational SPIN Change can be "In general, an Operational SPIN Change can be requested only after a funding commitment has requested only after a funding commitment has been made. However, starting in FY2007, PIA been made. However, starting in FY2007, PIA will allow an applicant to request an operational will allow an applicant to request an operational SPIN Change pre-commitment if the chosen SPIN Change pre-commitment if the chosen service provider is an ineligible service provider is an ineligible telecommunications provider."telecommunications provider."

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SPIN Changes-- SPIN Changes-- Operational Operational 1.1. Operational SPIN changes may be Operational SPIN changes may be

requested and approved for tariffed requested and approved for tariffed and month-to-month services as well and month-to-month services as well as for contract servicesas for contract services

– For tariffed and month-to-month services, For tariffed and month-to-month services, there would be no issue of the change being there would be no issue of the change being permitted under the terms of the contract; permitted under the terms of the contract; however, compliance with state and local however, compliance with state and local procurement rules procurement rules andand notification to the notification to the service provider are requiredservice provider are required

– Note that timing of payments may be a Note that timing of payments may be a critical issue in these instancescritical issue in these instances

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SPIN Changes-- SPIN Changes-- Operational Operational

2. Operational SPIN change 2. Operational SPIN change request deadlinesrequest deadlines– A SPIN change request for a funding A SPIN change request for a funding

request (FRN) must be postmarked or request (FRN) must be postmarked or received by the last date to submit an received by the last date to submit an invoice for that FRNinvoice for that FRN

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SPIN Changes-- SPIN Changes-- Operational Operational 3.3. Changes of SPIN in multi-year Changes of SPIN in multi-year

contracts are conditionally eligiblecontracts are conditionally eligible– Existing multi-year contract may be switched Existing multi-year contract may be switched

to new provider under another multi-year to new provider under another multi-year contract without posting a new FCC Form contract without posting a new FCC Form 470 and waiting at least 28 days470 and waiting at least 28 days

– The multi-year contract with the new service The multi-year contract with the new service provider must have an expiration date no provider must have an expiration date no later than the original contract. later than the original contract.

– Neither contract should be longer than any Neither contract should be longer than any term for the contract described in the term for the contract described in the original Form 470 or the RFP under which the original Form 470 or the RFP under which the original service provider was selected. original service provider was selected.

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SPIN Changes-- SPIN Changes-- Operational Operational 4. 4. Service substitutions.Service substitutions.

– A change in service provider, by itself, does not allow a A change in service provider, by itself, does not allow a substitution in the specific products or services to be substitution in the specific products or services to be supplied.supplied.

– Applicants may make a simultaneous request for both Applicants may make a simultaneous request for both service substitution and change in service provider by:service substitution and change in service provider by:1.1. following the steps as outlined in the Service Substitutions following the steps as outlined in the Service Substitutions

procedure procedure 2.2. including the service provider change letter described below including the service provider change letter described below

as an additional attachment to the service substitution as an additional attachment to the service substitution requestrequest

– In the event that a simultaneous service substitution and In the event that a simultaneous service substitution and service provider change cannot be granted due to a service provider change cannot be granted due to a problem with one request or the other, the SLD will problem with one request or the other, the SLD will contact the applicant to determine if the SLD should contact the applicant to determine if the SLD should continue to process the remaining request.continue to process the remaining request.

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SPIN Changes-- SPIN Changes-- Operational Operational 5. When to file Operational SPIN change 5. When to file Operational SPIN change

requests.requests.

– Applicants should notify the SLD of their intent to change Applicants should notify the SLD of their intent to change service providers as soon as the decision is made and service providers as soon as the decision is made and should advise the SLD of the proposed effective date of should advise the SLD of the proposed effective date of the change. the change.

– Unless the applicant indicates an effective date in the Unless the applicant indicates an effective date in the future or upon approval by the SLD, the SLD will make future or upon approval by the SLD, the SLD will make no additional payments on the FRN until the SPIN change no additional payments on the FRN until the SPIN change is reviewed and either:is reviewed and either:1.1. approved and the SPIN is changed approved and the SPIN is changed

OROR2.2. denied and the SLD verifies that additional invoices are for denied and the SLD verifies that additional invoices are for

services actually rendered to the applicant by the original services actually rendered to the applicant by the original service providerservice provider

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SPIN ChangesSPIN Changes

May be filed via:May be filed via:– Regular mailRegular mail– FaxFax– E-mailE-mail

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Form 486Form 486

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Form 486Form 486

Form 486 Form 486 – Services Confirmed– Services Confirmed Notifies USAC that services have Notifies USAC that services have

started and invoices can be paidstarted and invoices can be paid Applicant certifies that its Applicant certifies that its

technology plan meets program technology plan meets program requirementsrequirements

Applicant certifies its status under Applicant certifies its status under Children’s Internet Protection Act (Children’s Internet Protection Act (CIPA)CIPA)

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Form 486Form 486

Filed online or postmarked no later Filed online or postmarked no later thanthan– 120 days after the Service Start Date 120 days after the Service Start Date

oror– 120 days after the date of the FCDL, 120 days after the date of the FCDL,

whichever is laterwhichever is later Service Start DateService Start Date

– Cannot be before July 1 of the Cannot be before July 1 of the funding yearfunding year

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Purpose of Form 486Purpose of Form 486

Form 486, Receipt of Services Form 486, Receipt of Services Confirmation Form – the applicantConfirmation Form – the applicant– Confirms that services have started Confirms that services have started

(or will start, for early filing) and (or will start, for early filing) and USAC can process invoicesUSAC can process invoices

– Certifies that a technology plan, if Certifies that a technology plan, if required, has been approvedrequired, has been approved

– Supplies the status under the Supplies the status under the Children’s Internet Protection Act for Children’s Internet Protection Act for the entities receiving servicesthe entities receiving services

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Online FilingOnline Filing

Block 1, Billed Entity InformationBlock 1, Billed Entity Information Block 2, Early Filing and CIPA Block 2, Early Filing and CIPA

Waiver RequestsWaiver Requests Block 4, Certifications (Items 8–11)Block 4, Certifications (Items 8–11) Block 3, Service InformationBlock 3, Service Information Block 4, Certifications and Block 4, Certifications and

SignatureSignature

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Apply Online Apply Online Form 486Form 486

http://www.sl.universalservice.org/menu.asp

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Online Form 486 HelpOnline Form 486 Help

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Online Form 486Online Form 486

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Online Form 486Online Form 486

4141

Form 486 Block 1Form 486 Block 1

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Applicant Form Applicant Form ID / FYID / FY

4343

Contact InformationContact Information

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Button OptionsButton Options

Save & Exit saves your work to this Save & Exit saves your work to this pointpoint

Reset Page – clears current entriesReset Page – clears current entries < Previous goes back one page< Previous goes back one page Next > goes forward one pageNext > goes forward one page

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Print PreviewPrint Preview

4646

Form 486 # Form 486 # Security CodeSecurity Code

4747

Early Filing Early Filing WaiversWaivers

4848

Block 4 CertificationsBlock 4 Certifications

Choose your tech plan approver from the dropdown list

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CIPA CertificationsCIPA Certifications

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Enter FRN, Enter FRN, SPIN, SSDSPIN, SSD

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Multiple FRNsMultiple FRNs

Delete

Add Item

5252

Signature and Signature and Contact InfoContact Info

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Submit FormSubmit Form

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Invoicing Invoicing Form 472 BEARForm 472 BEAR

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InvoicingInvoicing

Form 472 or 474 – Services InvoicedForm 472 or 474 – Services Invoiced Requests reimbursement from USAC for Requests reimbursement from USAC for

discount on cost of services delivereddiscount on cost of services delivered Filed online or postmarked no later thanFiled online or postmarked no later than

– 120 days after the last date to receive 120 days after the last date to receive service orservice or

– 120 days after the date of the Form 486 120 days after the date of the Form 486 Notification Letter, whichever is laterNotification Letter, whichever is later

Two options for requesting reimbursement Two options for requesting reimbursement

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Invoicing Invoicing

Form 472Form 472Billed Entity Applicant Reimbursement Billed Entity Applicant Reimbursement

(BEAR) Form(BEAR) Form– Filed if applicant PAID for services in Filed if applicant PAID for services in

fullfull– Reimbursement handled through Reimbursement handled through

service providerservice provider– Cash or credit reimbursementCash or credit reimbursement– Service provider must reimburse Service provider must reimburse

applicant within 20 days of receipt of applicant within 20 days of receipt of fundsfunds

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Invoicing ProcessInvoicing Process

Before you submit an invoice to USAC:Before you submit an invoice to USAC:– USAC must make a commitment for the USAC must make a commitment for the

Funding Request Number (FRN)Funding Request Number (FRN)– Applicant must file and successfully Applicant must file and successfully

certify Form 486, Receipt of Service certify Form 486, Receipt of Service Confirmation Form, for that FRNConfirmation Form, for that FRN

– Service provider must file Form 473, Service provider must file Form 473, Service Provider Annual Certification Service Provider Annual Certification (SPAC) Form for that funding year and (SPAC) Form for that funding year and that Service Provider Identification that Service Provider Identification NumberNumber

– In general, services must have been In general, services must have been delivereddelivered

5858


Two invoicing methodsTwo invoicing methods– Form 472, Billed Entity Applicant Form 472, Billed Entity Applicant

Reimbursement (BEAR) FormReimbursement (BEAR) Form Applicant pays for services in full and Applicant pays for services in full and

then requests reimbursement from then requests reimbursement from USACUSAC

– Form 474, Service Provider Invoice (SPI) Form 474, Service Provider Invoice (SPI) FormForm Service provider discounts customer Service provider discounts customer

(applicant) bills and then requests (applicant) bills and then requests discount amount from USACdiscount amount from USAC

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BEAR FormBEAR Form– Applicant must pay for services in full Applicant must pay for services in full

before submitting BEARbefore submitting BEAR– Service provider reviews and approves Service provider reviews and approves

BEAR Form before it is submittedBEAR Form before it is submitted– USAC approves payment to reimburse USAC approves payment to reimburse

the discount amount to the service the discount amount to the service providerprovider

– Service provider must remit funds to Service provider must remit funds to applicant no later than 20 days after applicant no later than 20 days after RECEIPT of fundsRECEIPT of funds

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SPI FormSPI Form– Service provider must bill applicant Service provider must bill applicant

(customer) before submitting SPI (customer) before submitting SPI – USAC reimburses the discount amount USAC reimburses the discount amount

to the service providerto the service provider– SPIs can be submitted electronically, SPIs can be submitted electronically,

online, or on paper online, or on paper

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Line ItemsLine Items– You can file one line item or many line You can file one line item or many line

items on a single invoiceitems on a single invoice– A line item is not limited to a certain A line item is not limited to a certain

time periodtime period You can file one year’s worth of You can file one year’s worth of

service on one line, or file monthly, service on one line, or file monthly, bimonthly, quarterly, etc.bimonthly, quarterly, etc.

– Line items can also be for one-time Line items can also be for one-time charges charges

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Deadlines/Deadlines/ExtensionsExtensions

Invoice deadline:Invoice deadline:– Invoices must be postmarked or Invoices must be postmarked or

received by USAC no later than:received by USAC no later than: 120 days after the last date to receive 120 days after the last date to receive

service orservice or 120 days after the date of the Form 120 days after the date of the Form

486 Notification Letter486 Notification Letterwhichever is laterwhichever is later

– Extensions can be requestedExtensions can be requested

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Service delivery deadline:Service delivery deadline:– Recurring servicesRecurring services

June 30 of funding yearJune 30 of funding year– Non-recurring servicesNon-recurring services

September 30 following end of funding September 30 following end of funding yearyear

Some extensions are automatic while Some extensions are automatic while others must be requestedothers must be requested

Requests for extensions must be Requests for extensions must be postmarked or received by USAC no postmarked or received by USAC no later than the last day to receive later than the last day to receive serviceservice

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Automatic extensions are processed for:Automatic extensions are processed for:– Funding Commitment Decision Letter (FCDL), Funding Commitment Decision Letter (FCDL),

SPIN Change approval, or service substitution SPIN Change approval, or service substitution approval notification dated on or after March 1approval notification dated on or after March 1

Extensions must be requested for:Extensions must be requested for:– Service providers unable to complete Service providers unable to complete

implementation for reasons beyond their implementation for reasons beyond their controlcontrol

– Service providers unwilling to complete Service providers unwilling to complete installation because USAC withheld payment installation because USAC withheld payment on a properly completed invoice for at least 60 on a properly completed invoice for at least 60 daysdays

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If a service delivery extension occurs:If a service delivery extension occurs:– Contracts may need to be extendedContracts may need to be extended

(HINT: Set contracts for non-recurring (HINT: Set contracts for non-recurring services to expire September 30)services to expire September 30)

Applicants must file a Form 500 to Applicants must file a Form 500 to extend the contract expiration date extend the contract expiration date before an invoice dated after that date before an invoice dated after that date can be paidcan be paid

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Invoice ReviewInvoice Review

Invoices are assigned daily for Invoice Invoices are assigned daily for Invoice ReviewReview

Invoice Review process works quicklyInvoice Review process works quickly– Average processing time in 2007 is Average processing time in 2007 is

six days after receiptsix days after receipt Payments on approved invoices are Payments on approved invoices are

run twice a weekrun twice a week

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Invoice Review verifies that funds are Invoice Review verifies that funds are disbursed only for products and disbursed only for products and services that are:services that are:– Installed at and/or delivered to eligible Installed at and/or delivered to eligible

recipients of servicerecipients of service– Eligible and approved for funding during Eligible and approved for funding during

the PIA review of the Form 471the PIA review of the Form 471– In general, received during the funding In general, received during the funding

year (including extensions)year (including extensions)

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Service certificationsService certifications– Only requested under some circumstancesOnly requested under some circumstances– Verify that the invoiced services were Verify that the invoiced services were

approved on the Form 471 and deliveredapproved on the Form 471 and delivered– May include requests for detailed (customer) May include requests for detailed (customer)

bills from the applicant or the service bills from the applicant or the service provider and verification of paymentprovider and verification of payment

– Check for service substitutions if the services Check for service substitutions if the services invoiced do not match the services requestedinvoiced do not match the services requested

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Filing a BEAR online – Applicants Filing a BEAR online – Applicants needneed– Personal Identification Number (PIN)Personal Identification Number (PIN)

Issued to authorized person onlyIssued to authorized person only Some PINs are BEAR-specificSome PINs are BEAR-specific

– Valid email addressValid email address– Form 471 Application Number, FRN, and Form 471 Application Number, FRN, and

SPIN that matchSPIN that match– Customer billsCustomer bills– Contact person informationContact person information

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Approving a BEAR online – Approving a BEAR online – Service providers needService providers need– Form 498 E-cert ID and passwordForm 498 E-cert ID and password

Service provider can assign Service provider can assign multiple usersmultiple users

– Valid email addressValid email address– Customer billsCustomer bills– Contact person informationContact person information

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Filing a SPI online – Service Filing a SPI online – Service providers needproviders need– Customer billsCustomer bills– Contact person informationContact person information– No certifications on Form 474No certifications on Form 474

Certifications already made on Certifications already made on Form 473Form 473

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Filing Right Filing Right the First Timethe First Time

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File onlineFile online– System checks for errors and notifies you System checks for errors and notifies you

if data are missing or inconsistentif data are missing or inconsistent– Invoice Review process can begin soon Invoice Review process can begin soon

after all required information is submitted after all required information is submitted onlineonline

– Service providers: Update your Form 498 Service providers: Update your Form 498 information and verify your E-cert ID and information and verify your E-cert ID and password so that you can approve BEARspassword so that you can approve BEARs For assistance, call 1-888-641-8722For assistance, call 1-888-641-8722

7474


Read and follow directions provided in:Read and follow directions provided in:– Form instructionsForm instructions– Website guidanceWebsite guidance– Notification letters (samples on USAC Notification letters (samples on USAC

website)website)– Other communicationsOther communications

Provide complete documentationProvide complete documentation Do not wait until the last minuteDo not wait until the last minute

– Applicants should ask service providers Applicants should ask service providers what their lead time is for approving BEARswhat their lead time is for approving BEARs

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Call or email your reviewer with Call or email your reviewer with questionsquestions– Contact information is provided on requests Contact information is provided on requests

for information from Invoice Reviewfor information from Invoice Review If possible, resubmit your invoice If possible, resubmit your invoice

instead of filing an appealinstead of filing an appeal– If you understand from USAC’s If you understand from USAC’s

communication what was incorrect on your communication what was incorrect on your invoice, you can just resubmit the invoice invoice, you can just resubmit the invoice with the correct information or within the with the correct information or within the correct timeframecorrect timeframe

7676


Before filing, verify that:Before filing, verify that:– Your invoice is not a duplicateYour invoice is not a duplicate– You removed any ineligible products and You removed any ineligible products and

servicesservices– You removed any products and services You removed any products and services

that were not approved on that FRNthat were not approved on that FRN– Funds still remain on the FRNFunds still remain on the FRN– You are filing timely and do not need to You are filing timely and do not need to

first request an invoice deadline first request an invoice deadline extensionextension

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AppealsAppeals

7878

AppealsAppeals

Affected parties to decisions made Affected parties to decisions made by USAC on billing, collection, or by USAC on billing, collection, or disbursement matters can seek an disbursement matters can seek an appeal of those decisions from USAC appeal of those decisions from USAC or directly with the Federal or directly with the Federal Communications Commission (FCC)Communications Commission (FCC)

An appeal cannot be considered An appeal cannot be considered until the USAC issues a formal until the USAC issues a formal decision.decision.

7979

Waiver RequestsWaiver Requests

A waiver request is a request to waive an A waiver request is a request to waive an FCC policy, rule or deadline.FCC policy, rule or deadline.– An applicant missed the filing deadline An applicant missed the filing deadline

for the Form 471 because of extenuating for the Form 471 because of extenuating circumstances and would like the filing circumstances and would like the filing deadline waived.deadline waived.

– An applicant failed to post a Form 470 An applicant failed to post a Form 470 for the type of services requested on for the type of services requested on their Form 471 and would like the their Form 471 and would like the competitive bidding requirement waived.competitive bidding requirement waived.

Waiver requests should be filed with Waiver requests should be filed with the FCC.the FCC.

8080

Writing an AppealWriting an Appeal

Identify your correspondence as an Identify your correspondence as an appealappeal

Provide relevant information Provide relevant information – Applicant name, BEN and contact Applicant name, BEN and contact

informationinformation– FCC form type/numberFCC form type/number– Case numbers and dates of Case numbers and dates of

associated contact with USAC, etc.associated contact with USAC, etc.

8181


Provide decision letter Provide decision letter information:information:– the title of the Administrator’s the title of the Administrator’s

decision letterdecision letter– the text from the decision being the text from the decision being

appealed, orappealed, or– a copy of the decision lettera copy of the decision letter

8282


Address all denial reasons and FRNs Address all denial reasons and FRNs affected by the decision.affected by the decision.

Explain why you disagree with the Explain why you disagree with the decision and what outcome you request. decision and what outcome you request.

Provide documentation that supports your Provide documentation that supports your claim. Clearly label each attachment.claim. Clearly label each attachment.

If you are providing previously requested If you are providing previously requested information with your appeal, explain the information with your appeal, explain the reason for the late filing.reason for the late filing.

8383


Procedures for filing an appeal Procedures for filing an appeal with USAC and/or the FCC are with USAC and/or the FCC are located on your decision letter located on your decision letter and at:and at:

http://http://www.usac.org/sl/about/appealswww.usac.org/sl/about/appeals

8484

Providing New Providing New InformationInformation

USAC will generally accept new USAC will generally accept new information on appeal if the information:information on appeal if the information:– is provided to resolve an ambiguity that is provided to resolve an ambiguity that

existed in the original file.existed in the original file.– does not contradict information that has does not contradict information that has

previously been submitted. (Explain previously been submitted. (Explain discrepancies)discrepancies)

– should have been, but was not, requested should have been, but was not, requested or received during PIA Review.or received during PIA Review.

– BUT you shouldn’t “create” documents nowBUT you shouldn’t “create” documents now

8585

Submissions to Submissions to USACUSAC

Appeals can be submitted to USAC via Appeals can be submitted to USAC via email, fax or mail. Email or fax is email, fax or mail. Email or fax is recommended.recommended.

• E-mail: E-mail: [email protected]@sl.universalservice.org• Fax: (973) 599-6542Fax: (973) 599-6542• Mail: Letter of AppealMail: Letter of Appeal

Schools and Libraries Division - Schools and Libraries Division - Correspondence UnitCorrespondence Unit100 S. Jefferson Rd100 S. Jefferson RdP.O. Box 902P.O. Box 902Whippany, NJ 07981Whippany, NJ 07981

8686

Submissions to Submissions to the FCCthe FCC

The FCC accepts appeals or waiver The FCC accepts appeals or waiver requests via the Electronic requests via the Electronic Comment Filing System (ECFS), fax Comment Filing System (ECFS), fax or mail. or mail. • ECFS: ECFS: www.fcc.gov/cgb/ecfswww.fcc.gov/cgb/ecfs//• Fax: (202) 418-0187Fax: (202) 418-0187• Mail: Mail: See the Appeals Procedure for See the Appeals Procedure for

specific mailing requirements at:specific mailing requirements at: http://www.usac.org/sl/about/appeals/http://www.usac.org/sl/about/appeals/

8787

DeadlinesDeadlines

Appeals must be postmarked Appeals must be postmarked no later no later than 60 daysthan 60 days after the date of the after the date of the decision letter being appealed.decision letter being appealed.

Petitions for Reconsideration must be Petitions for Reconsideration must be receivedreceived by the FCC within 30 days of by the FCC within 30 days of the FCC Decision.the FCC Decision.

Appeals via fax and email will be Appeals via fax and email will be considered “postmarked” on a specific considered “postmarked” on a specific business day up until midnight in the business day up until midnight in the sender’s local time zone.sender’s local time zone.

8888

Expedite Expedite your appealyour appeal

Designate an alternate contact Designate an alternate contact person if the primary contact is person if the primary contact is not available.not available.

Include support documentation for Include support documentation for your claim.your claim.

Keep all associated documentation Keep all associated documentation readily accessible so you can readily accessible so you can answer questions quickly.answer questions quickly.

8989

USAC Can Grant USAC Can Grant an Appeal …an Appeal …

When the appeal shows that USAC erred in When the appeal shows that USAC erred in its initial review.its initial review.

When the appeal shows that the applicant When the appeal shows that the applicant made a mistake and that USAC could have made a mistake and that USAC could have identified the mistake from information identified the mistake from information provided with the application.provided with the application.

When the appeal provides documentation When the appeal provides documentation to correct an incorrect USAC assumption to correct an incorrect USAC assumption due to insufficient information.due to insufficient information.

If USAC obtains policy clarification or new If USAC obtains policy clarification or new policies between the time of funding policies between the time of funding commitment and the appeal decision.commitment and the appeal decision.

9090

USAC Can Grant USAC Can Grant an Appeal …an Appeal …

If USAC determines that the issue on If USAC determines that the issue on appeal should be granted, USAC will appeal should be granted, USAC will continue its review process on the continue its review process on the application.application.– Applications up to FY 2006Applications up to FY 2006– Applications for FY 2007 and beyondApplications for FY 2007 and beyond

9191

Appeals ProcessAppeals Process

USAC will acknowledge receipt of your USAC will acknowledge receipt of your appeal.appeal.

USAC may contact you for additional USAC may contact you for additional information.information.

Meritorious appeals issued BEFORE an FCDL Meritorious appeals issued BEFORE an FCDL (“pre-commitment appeals”) will go into the (“pre-commitment appeals”) will go into the normal review process.normal review process.

Meritorious appeals issued ON or AFTER an Meritorious appeals issued ON or AFTER an FCDL (“post-commitment” appeals) will FCDL (“post-commitment” appeals) will receive a revised FCDL (RFCDL).receive a revised FCDL (RFCDL).

Appeal denials can be issued via an Appeal denials can be issued via an Administrator’s Decision Letter (ADL) or Administrator’s Decision Letter (ADL) or RFCDL.RFCDL.

9292

Appeals ProcessAppeals Process

If the appeal relates to a funding denial, If the appeal relates to a funding denial, the Form 486 can be filed once USAC the Form 486 can be filed once USAC issues the RFCDL.issues the RFCDL.

If you appeal a funding request that has a If you appeal a funding request that has a positive commitment, positive commitment, DO NOT WAIT for DO NOT WAIT for an ADL or RFCDL before filing your an ADL or RFCDL before filing your Form 486 if services have started. Form 486 if services have started.

Granted appeals of a Service Start Date Granted appeals of a Service Start Date adjusted due to a late-filed Form 486 will adjusted due to a late-filed Form 486 will result in a revised Form 486 Notification result in a revised Form 486 Notification Letter. Do not file a new Form 486.Letter. Do not file a new Form 486.

If an invoicing appeal is granted, the If an invoicing appeal is granted, the invoice that was appealed should be invoice that was appealed should be resubmitted. resubmitted.

9393

USAC-identified USAC-identified AppealsAppeals

If USAC determines through its own review If USAC determines through its own review that a decision was made in error, USAC will that a decision was made in error, USAC will correct the error.correct the error.– The error must be identified by USAC within The error must be identified by USAC within

60 days from the issuance of the incorrect 60 days from the issuance of the incorrect decision.decision.

– USAC will notify the applicant when a USAC will notify the applicant when a correctable error has been identified.correctable error has been identified.

– The applicant will receive an RFCDL or The applicant will receive an RFCDL or other notification letter at the end of the other notification letter at the end of the process. process.

9494

Top Appeal Denial Top Appeal Denial ReasonsReasons

Appeal CategoryAppeal Category % Denials% Denials

Not providing all of the Not providing all of the documentation requesteddocumentation requested 14.11%14.11%

Invalid Telecom ProviderInvalid Telecom Provider 12.29%12.29%

Service EligibilityService Eligibility 11.15%11.15%

Discount CalculationsDiscount Calculations 10.86%10.86%

Bid Violation (price not primary Bid Violation (price not primary factor, tainted bidding process, factor, tainted bidding process, etc)etc) 8.08%8.08%

No binding contract at the time of No binding contract at the time of 471 submission471 submission 7.68%7.68%

28 Day Violation 28 Day Violation 5.75%5.75%

Based on FY2006 Appeals

9595

What You Can DoWhat You Can Do

Respond to USAC’s requests for additional Respond to USAC’s requests for additional information in a timely manner. If you need information in a timely manner. If you need additional time, let us know.additional time, let us know.

If the contact person on the application or If the contact person on the application or appeal changes, notify USAC immediately.appeal changes, notify USAC immediately.

Use tools available on the website to Use tools available on the website to determine eligibility of service providers and determine eligibility of service providers and services:services:

SPIN Contact SearchSPIN Contact Search Eligible Services ListEligible Services List

9696

What You Can DoWhat You Can Do

Wait at least 28 days after the posting Wait at least 28 days after the posting of the 470 before you file your Form of the 470 before you file your Form 471.471.

Know the Form 471 window close date Know the Form 471 window close date and plan accordingly.and plan accordingly.

Select the most cost-effective Select the most cost-effective services. services.

Follow your state contract & Follow your state contract & procurement laws.procurement laws.

Make sure you are using an approved Make sure you are using an approved method for calculating your discount. method for calculating your discount.

9797

What [is USAC] DoingWhat [is USAC] Doing

Allowing pre-commitment intra-Allowing pre-commitment intra-company SPIN changes for telecom company SPIN changes for telecom FRNsFRNs

Giving applicants an opportunity to Giving applicants an opportunity to reduce request or move ineligibles reduce request or move ineligibles before applying the 30% rulebefore applying the 30% rule

Not requiring two signatures & two Not requiring two signatures & two dates on contractsdates on contracts

Providing more information on the Providing more information on the Form 470 RNL and Form 471 RALForm 470 RNL and Form 471 RAL

9898


Accepting new information on Accepting new information on appealappeal

Including Including tip sheets tip sheets in the ADL in the ADL – Also available on the USAC websiteAlso available on the USAC website

Targeted invitations to trainingTargeted invitations to training HATS visitsHATS visits NewsBriefsNewsBriefs

9999

FCC Form 471 certification FCC Form 471 certification reminderreminder

FCC Form 486 due reminderFCC Form 486 due reminder Verifying denials and modifications Verifying denials and modifications

before the FCDL is issuedbefore the FCDL is issued Minimum Processing Standards Minimum Processing Standards

are incorporated in M&C errorsare incorporated in M&C errors


100100

Bishop Perry OrderBishop Perry Order

For FY2005 USAC processed 625 For FY2005 USAC processed 625 appeals related to not submitting appeals related to not submitting a timely or complete Form 471a timely or complete Form 471– 80% of these appeals were denied80% of these appeals were denied

Post Bishop Perry, USAC has Post Bishop Perry, USAC has processed 115 and 53 appeals processed 115 and 53 appeals respectively for FY2006 and respectively for FY2006 and FY2007FY2007

101101

Alaska Alaska Gateway OrderGateway Order

Form 486 appeals have decreased Form 486 appeals have decreased by 60% from FY2005 to FY2006by 60% from FY2005 to FY2006

We expect the number to drop We expect the number to drop again for FY2007again for FY2007

The approval percentage on Form The approval percentage on Form 486 appeals has gone from 13% to 486 appeals has gone from 13% to 88% since Alaska Gateway was 88% since Alaska Gateway was issuedissued

102102

Form 500Form 500

103103

Form 500Form 500

Uses: Uses: – Release fundsRelease funds– Modify information submitted during the Form Modify information submitted during the Form

486 process:486 process: Recover year of Internal Connections fundingRecover year of Internal Connections funding New Start Date: New Start Date: Change the Funding Year Change the Funding Year

Service Start Date you listed on a previously Service Start Date you listed on a previously filed Form 486 in this funding year. This filed Form 486 in this funding year. This action will NOT result in more fundingaction will NOT result in more funding

Contract Expiration Date: Contract Expiration Date: If you wish to If you wish to change the ending date for services. This change the ending date for services. This action will not result in more funding but you action will not result in more funding but you could combine it with a reduction in fundingcould combine it with a reduction in funding

104104

Form 500Form 500

Uses: Uses: – Modify information submitted during the Form 486 Modify information submitted during the Form 486

process:process: Cancel: Cancel: If you wish to cancel a Funding Request If you wish to cancel a Funding Request

Number. Please note: This action is irrevocable and Number. Please note: This action is irrevocable and the FRN can NOT be reinstated later. This action the FRN can NOT be reinstated later. This action would allow money to be put back into the Universal would allow money to be put back into the Universal Service fund for possible commitment to other Service fund for possible commitment to other applicantsapplicants

Reduce: Reduce: If you wish to reduce the amount of your If you wish to reduce the amount of your funding commitment for a particular FRN. This action funding commitment for a particular FRN. This action is irrevocable and the FRN can NOT be increased is irrevocable and the FRN can NOT be increased later. This action would allow money to be put back later. This action would allow money to be put back into the Universal Service fund for possible into the Universal Service fund for possible commitment to other applicantscommitment to other applicants

105105

Form 500: Returning Form 500: Returning FundsFunds

Use Form 500 as soon as you know Use Form 500 as soon as you know you will not be utilizing fundsyou will not be utilizing funds

Complete Complete very carefullyvery carefully

Once you return funds, you cannot Once you return funds, you cannot change your mindchange your mind

106106

Returning FundsReturning Funds

107107

Returning FundsReturning Funds

SLD is citing during audits entities SLD is citing during audits entities that are not completing Form 500that are not completing Form 500

If USAC has disbursed funds on a If USAC has disbursed funds on a Funding Request Number (FRN), Funding Request Number (FRN), entities listed in the worksheet entities listed in the worksheet cannot regain a year for 2 in 5cannot regain a year for 2 in 5

108108

MPLS Contract MPLS Contract InformationInformation

Chris Blankenship, VerizonChris Blankenship, Verizon

Chip Merritt, VerizonChip Merritt, Verizon

109109

MPLS and County MPLS and County Network InformationNetwork Information

Greg Chapman, WVDEGreg Chapman, WVDE

Eric Petrucci, WVDEEric Petrucci, WVDE

e-rate update 2008

Documents

service substitutionsmay

product andor service

specific service providers

specific services

funding yearusac

rfpglobal service subinvolve

relevant funding year

products andor services