welcome to fall 2013 e-rate training. agenda introduction to e-rate understanding eligible services...

Welcome To

Fall 2013 E-Rate Training

Agenda• Introduction to E-Rate• Understanding Eligible Services• E-Rate Update• Break• Notice of Proposed Rulemaking (NPRM)• New FCC Form 470 & 471• New FCC Form 486 & 472• Avoid the Dirty Dozen Mistakes

– Lunch on your own• Form 470 Step-by-Step

**Thanks to USAC & SLD staff for providing training materials and program information.

Introduction to E-RateFall 2013 Applicant Trainings

E-Rate Program

• Federal Communications Commission (FCC), an independent U.S. government agency, established and oversees the E-Rate Program.

• Universal Service Administrative Company (USAC), a not-for-profit, administers the E-Rate Program along with three other programs.

• Schools and Libraries Program (SL) is the part of USAC with responsibility for E-Rate.

E-Rate Background

General E-Rate Information

• Congress directed the FCC to establish the E-Rate Program in 1996.

• The FCC sets rules and policies through orders.• USAC develops procedures for specific actions, such

as how to process applications.

E-Rate Rules


• Commitments for E-Rate are made by funding year (FY), which runs from July 1 through the following June 30.

• USAC refers to the funding year as the year in which most services will begin, e.g., FY2013 is July 1, 2013 to June 30, 2014.

E-Rate Timeline


• The FCC capped E-Rate funding at $2.25 billion per year, until 2010 when the FCC began to adjust the cap annually for inflation

• Once a year, the FCC is required to roll over all funds that are collected and are unused from prior funding years to the next full funding year

E-Rate Budget


• Who is eligible for E-Rate funding?– Elementary and Secondary schools and

school districts• Non-traditional facilities

• Non-Instructional facilities

– Libraries and library systems– Consortia – groups of eligible entities that

band together to aggregate demand and negotiate lower prices

E-Rate Eligibility


• How large are the discounts on eligible products and services?– Discounts are 20-90 percent of eligible costs.– Discount level for a school or library depends on:

• Percentage of students who are eligible for National School Lunch Program (NSLP) in – (for a library) the school district in which the

library is located.• Urban or rural location of the school or library.

E-Rate Discounts


Discount Matrix


INCOME % of students eligible for NSLP

URBAN LOCATION Discount

RURAL LOCATION Discount

If the % eligible is... ...and you’re in an URBAN area, your discount will be...

...and you’re in a RURAL area, your discount will be...

Less than 1% 20% 25%

1% to 19% 40% 50%

20% to 34% 50% 60%

35% to 49% 60% 70%

50% to 74% 80% 80%

75% to 100% 90% 90%

• Priority 1 (P1): funded first– Telecommunications Services – Internet Access – Telecommunications

• Priority 2 (P2): funded second and starts with neediest applicants– Internal Connections – Basic Maintenance of Internal Connections

E-Rate Categories of Service


• How do I file a program form?– Three options:

• File online, certify on paper• File online, certify online• File on paper, certify on paper

– USAC encourages you to file online, because online filing speeds processing and reduces errors.

E-Rate Forms


E-Rate Letters


Each time applicants file a program form, USAC sends you a notification or acknowledgement letter.

• Letters are color-coded by funding year

– 2013

– 2014

– 2015

• Note: When storing documents, USAC encourages you to separate your program forms and letters by funding year to better organize them.

PinkBlue

Canary

Introduction to E-Rate

Technology Planning

• A technology plan must contain the following 4 elements:– Goals and strategies for using technology to improve

education or library services– Needs assessment– Staff training– Evaluation plan

• Technology plans must be approved by a USAC-certified Technology Plan Approver (TPA). In this case:

–State Library of Ohio

Technology Plans (P2 Services Only)

Technology Planning


Requesting Services (FCC Form 470)

• Opens your competitive bidding process.• Notifies potential bidders of the types and quantities of

services that you need.• Must be posted on the USAC website at least 28 days

before filing the FCC Form 471.

Note: Request for Proposals (RFPs) or other supplemental documents may be issued in addition to describe specific needs and circumstances. If you issue an RFP (or provide supplemental documents), the RFP, supplemental documents, and FCC Form 470 must be available during the same 28-day period.

FCC Form 470 Purpose

Requesting Services

• FCC Form 470 Receipt Notification Letter (RNL): a letter issued by USAC to the applicant that summarizes the information provided in the FCC Form 470.

• If you notice mistakes, use the RNL to make allowable corrections immediately.

Response Letter

Requesting Services


Competitive Bidding

• No one other than the applicant or an authorized representative of the applicant should prepare, sign or submit the FCC Form 470 or certification.

• The FCC Form 470 must describe the desired products and services with sufficient detail to enable interested parties to submit bid responses.

• All potential bidders must have access to your FCC Form 470, RFP (or other supplemental documents describing the procurement, if you have them).

• You must evaluate the incoming bids fairly and equally.

Competitive Bidding Requirements

Competitive Bidding

Competitive Bidding

Factor Points Available Vendor 1 Vendor 2 Vendor 3Price of the ELIGIBLE

products and services 30 15 30 25Prior experience w/ vendor 20 20 0 20Prices for ineligible services,

products and fees 25 20 15 25Flexible Invoicing: 472 or 474 15 0 15 15

Local or in-state vendor 10 10 8 7Total 100 65 68 92

• The price of the eligible products and services must be the most heavily weighted factor in your evaluation of bids

Sample Matrix

• After the 28-day waiting period closes, on the 29th day, you can:1. Evaluate bids received

2. Choose your service provider(s)

3. Sign a contract (if applicable)

4. Submit an FCC Form 471.

*Be sure to check for the Allowable Contract Date (ACD) shown on the Form 470

Competitive Bidding Process

Competitive Bidding


Ordering Services (FCC Form 471)

• Identifies the service providers and eligible services you have chosen on funding requests.

• Identifies the eligible schools and libraries that will receive services.

• Calculates how much support you seek for the funding year using your discount calculation information.


Ordering Services

• Funding Request Number (FRN): The identification number assigned to each FCC Form 471 Block 5 funding request.

• Service Provider Identification Number (SPIN): The identification number assigned by USAC to a service provider.

• Item 21 Attachment (Item 21): A description of services and prices associated with each funding request.– Item 21 attachment(s) are part of the FCC Form 471

and are a window filing requirement.

Acronyms and Terms

Ordering Services

• Receipt Acknowledgment Letter (RAL): a letter issued by USAC to the applicant and the service provider that summarizes the information provided in the FCC Form 471, which you should carefully review.

• If you notice mistakes, use the RAL to make allowable corrections immediately.

Response Letter

Ordering Services


Application Review and Funding Commitments

• Program Integrity Assurance (PIA) is the USAC group that reviews and makes funding decisions on program applications: – Verifies eligibility of the schools and libraries entities,

entity discount levels, and the services requested.– Gives you an opportunity to make allowable corrections

to your form.– In some cases, asks for additional verification of your

compliance with program rules.

PIA and USAC Reviews, FCC Form(s) 471

Application Review/Commitments

• Funding Commitment Decision Letter (FCDL): Following application review, USAC issues this letter to both the applicant and the service provider. It contains decisions on approved or denied funding requests and next steps.

Decision Letter

Application Review/Commitments


Begin Receiving Services (FCC Form 486)

• Notifies USAC that your eligible services have started or been delivered and invoices for those services can be processed and paid.

• Provides the name of the TPA that approved your technology plan (if applicable).

• Reports your status of compliance with Children’s Internet Protection Act (CIPA)—a law with specific requirements on Internet safety policies.


Begin Receiving Services

• FCC Form 486 Notification Letter: a letter issued by USAC to the applicant and service provider after an FCC Form 486 has been processed.

Response Letter

Begin Receiving Services


Invoicing USAC (FCC Forms 472, 474)

• Applicants and service providers receive an FCDL from USAC for the services being invoiced.

• Applicants must file an FCC Form 486 and receive an FCC 486 Notification Letter.

• Service providers must file an Service Provider Annual Certification (SPAC) FCC Form 473 each funding year.

Requirements Before Invoicing USAC

Invoicing USAC

1) Billed Entity Applicant Reimbursement (BEAR) FCC Form 472: filed by applicant after services have been paid in full OR

2) Service Provider Invoice (SPI) FCC Form 474: filed by service provider after the applicant has been billed for the non-discount portion of eligible services.

Note: Applicants can choose their method of invoicing; service providers cannot force applicants to use a particular method.

Two Methods of Invoicing

Invoicing USAC

• BEAR Notification Letter: a letter issued by USAC to the applicant with a copy to the service provider after a BEAR is processed.

• Quarterly Disbursement Report: a letter issued to the applicant detailing all invoicing activity (BEARs and SPIs) during the previous quarter.

Response Letters

Invoicing USAC


Deadlines

• Tech Plan - drafted before the competitive bidding process and approved on or before the date when you begin receiving services or at the time you file the FCC Form 486, whichever date is earlier.

• FCC Form 470 - Posted at least 28 days before the filing of the FCC Form 471, keeping in mind the FCC Form 471 application filing window opening and closing dates.

• FCC Form 471 and Item 21 Attachment - Received or postmarked no later than 11:59 PM ET on the day of the close of the FCC Form 471 application filing window (exact window dates will be posted on our website).

Application Deadlines

Deadlines

• FCC Form 486 - Received or postmarked no later than 120 days after the date of the FCDL or the service start date, whichever is later.

• FCC Form 472/ FCC Form 474 - Received or postmarked no later than 120 days after the date of the FCC Form 486 Notification Letter or the last date that the applicant can receive service from the provider in the funding year at issue, whichever is later.

• Appeals - Received or postmarked no later than 60 days after the date of USAC's decision letter.

More Deadlines

Deadlines

E-Rate Program

Understanding Eligible Services

Overview

• Priority One (P1)• Priority Two (P2)• Miscellaneous• Interconnected Voice over Internet Protocol (VoIP)

Overview

Priority One

• Digital Transmission Services– Digital Subscriber Line (DSL)– Primary Rate Interface (PRI)– T-1, T-3– Satellite service

Telecommunications Services

Priority One

• Broadcast “Blast” messaging• Monitoring services for 911, E911 or alarm telephone

lines• Services to ineligible locations• End-user devices

– Cell phones, tablet devices, netbooks and computers

Not Eligible as Telecom Services

Priority One

• Support for IA includes charges to access the Internet and costs for the conduit to the Internet

• Other eligible Internet Access services include:– Email service– Wireless Internet access– Interconnected VoIP– Web hosting

Internet Access (IA)

• Costs for Internet content– Subscription services such as monthly charges for

on-line magazine subscriptions• Internet2 membership dues• Website creation fees• Web-based curriculum software• Software, services or systems used to create or edit

Internet content

Not Eligible as Internet Access

Priority One

• Support for equipment and cabling onsite that transport info to classrooms or public rooms of a library

• Subject to the Two-in-Five Rule– Entities can only receive funding two out of every

five years

Internal Connections

Priority Two

• End-user components

–Computers, laptops, tablets, speakers, white boards

• Most software

–Anti-virus, anti-spam, curriculum or productivity software

• Spare parts

• Intercom or public address (PA) systems

Not Eligible as Internal Connections

Priority Two

• Support for basic maintenance of eligible internal connections

• Such as:– Repair and upkeep of hardware– Wire and cable maintenance– Basic tech support– Configuration changes

Basic Maintenance of Internal Connections (BMIC)

Priority Two

• Agreements or contracts must state the eligible components covered, make, model, and location

• Services must be delivered between the July 1 to June 30 Funding Year

• Two-in-Five Rule does not apply to BMIC

Basic Maintenance of Internal Connections

Priority Two

• Standard manufacturer warranties of no more than three years remain eligible

– If there is a cost associated with the warranty, then the warranty is not eligible

• Support for BMIC is limited to actual work performed under the contract

• Exceptions that will not require demonstration that work was performed are:

– Software upgrades and patches

– Bug fixes and security patches and

– Online and telephone based technical support

Basic Maintenance of Internal Connections

Priority Two

• Miscellaneous charges can apply to all service categories and are funded in the same category of the service they are supporting

• Training is eligible when included as part of the contract and performed coincidently with the installation of the new service/product or in a reasonable time thereafter

– Training for end-users or professional development is not eligible

Miscellaneous Charges

Miscellaneous

• Other charges that are not eligible include but are not limited to:

– Universal service administration fee– Interest or finance charges– Late payment fees and– Termination fees

Miscellaneous Charges

Miscellaneous

Interconnected VoIP

• Interconnected VoIP service is eligible as a Priority One service

• Interconnected VoIP is defined as a service that– Enables real time, two-way voice communications– Requires a broadband connection from the user’s

location– Requires Internet protocol-compatible customer

premises equipment (CPE)– Permits users generally to receive calls that originate on

the public switched telephone network and to terminate calls to the public switched telephone network

Interconnected VoIP

• Leased VoIP system or PBX equipment are not eligible for Priority One funding

• VoIP or PBX equipment are eligible as Internal Connections

• A VoIP gateway may be leased with an eligible Priority One VoIP Service

• A VoIP gateway is considered a single basic terminating device

Interconnected VoIP

• Example of a common configuration containing a leased gateway

E-Rate Update

E-Rate Update

• FY2013 demand for funds

• Priority 1 - $2.7 bil• Priority 2 - $2.2 bil

• Application review

• Processing positive funding for P1 only

• P2 funding still to be determined

• Target 90% of all FY2013 applications completed by 12/31/2013

E-Rate Update

FY2013 at a Glance

• FCC issues NPRM

7/23/2013

• New FCC Form 474 (SPI) online

8/7/2013

• New FCC Form 472 (BEAR) online

8/28/2013

E-Rate Update

FY2013 at a Glance, cont.

E-Rate Update

E-Rate 2.0 NPRM: Preview of Proposed

Changes

E-Rate 2.0 NPRM General

• This presentation tries to outline the major issues/topics being considered.

• None of the proposals/topics are final. FCC is seeking feedback from the applicant/vendor

community whether they are on the right track and why/why not.

• Some of the topics are actual proposals; others are issues for which they are seeking comments.

Make Broadband Priority 1

FCC survey data indicates that 80% of the applicants surveyed stated they did not have sufficient bandwidth.

FCC proposes to update E-Rate priorities so that high-capacity broadband and the associated equipment needed to disseminate that broadband to and within those buildings becomes Priority 1.

All other services would become Priority 2 or phased out altogether (¶ 65)

What different or additional services should be considered eligible such as filtering, caching and network security services, etc?

Treat Lit and Dark Fiber Equally

The FCC proposes to treat lit and dark fiber more consistently by making modulating electronics and special construction charges eligible as part of dark fiber (as it now does for lit fiber). (¶ 71) Asks many questions related to fiber deployment:

What are barriers to fiber deployment?

Should E-Rate support the purchase of WANs if it’s more cost effective than leasing? (¶ 80)

Should the one-time installation costs receive a higher discount?

Can the FCC do anything to reduce recurring costs over time by altering any of its policies

Should the Eligible Services List be amended to include additional equipment that is needed for broadband connectivity within buildings?

Revise Eligible Services List

The FCC proposes to phase out support for a number of specific services including:

◦ paging◦ wireless text messaging◦ directory assistance◦ custom calling features◦ inside wiring maintenance plans◦ call blocking◦ 800 number services. (¶ 90)

When should such changes be made? FY 2014?

Revise Eligible Services List

The FCC also seeks comment on whether support for the following services should be phased out, de-prioritized or eliminated:

◦ All voice services (presumably basic telephone service, local and long distance◦ If so, should VOIP continue to be eligible? (¶ 105)

◦ Internet access provided via cellular data plans, including aircards. (¶ 102)

◦ Web hosting and hosted e-mail services. (¶ 97)

◦ Basic maintenance of internal connections. (¶ 101)

Should other items on the Eligible Services List that are not directly related to high-capacity broadband be ineligible? (¶103)

Streamline E-Rate

The FCC proposes several options for streamlining the administration of the E-Rate program, including:

Requiring all forms and USAC correspondence to be submitted/sent electronically (¶ 227);

Providing more detailed and comprehensive funding statuses throughout the application process (¶ 232);

Speeding review of applications and issuance of commitment decisions (they seek specific comments on problems they have had during the PIA review process) (¶ 233);

Removing the distinction between telecommunications services and Internet access (¶ 258);

More effectively identifying and capturing unused funds (why do funds go unused and how can USAC identify and de-obligate those funds more quickly?) (¶ 254); and

Streamlining the E-Rate appeals review process (¶ 266).

Change Funding Distribution Model

The FCC seeks comment on 4 major options for revising the structure for distributing E-Rate funds as follows:

1) Revising the discount matrix to increase certain applicants’ matching requirements through a phase-in process. (¶117)

What should the maximum E-Rate discount be? 70%? 75%? Should all of the discount bands be adjusted downward by a certain

percentage? Should the discount matrix be abandoned in lieu of a discount calculated as

NSLP percentage plus 20% (urban) or 25% (rural)?

2) Incorporating a per-student or per-building cap on funding into the discount matrix. (¶ 135)

What would those caps be? Should they apply to both Priority 1 and Priority 2 funding? Should installation fees be excluded from the calculation? Should there be a di minimus amount funding available? How would consortia apply using a per-student cap?

Change Funding Distribution, cont.

3) Providing more equitable access to Priority 2 funding (¶ 133)

How can the FCC ensure more applicants have access to P2 funding Should the 2/5 rule be replaced with another rule, such as a 1/5 rule? Should P2 be funded on a rolling-funding cycle? Should there be different priorities established, such as a

broadband/Internet P1 category and other service (such as voice) become Priority 2 (or some other priority)?

4) Allocating funds through a fixed dollar amount before the funding year begins (¶ 149)

How would this amount be calculated for libraries? How would it be calculated for schools? How would this work with consortia? What would the reporting requirements be?

Change Discount Calculations

The FCC proposes 2 major revisions to E-Rate discount calculations:

Changing the E-Rate discount calculations to be based on a simple average of the District’s NSLP enrollment whereby a district would receive a straight matrix discount.

The current formula is a weighted average approach that uses each school building’s discount as part of the calculation) (¶ 126)

Districts would apply for all services (P2/P2) using district-wide discount; no building discounts would apply.)

Changing the definition of rural to ensure greater funding to truly rural areas by using NCES codes.

Should the definition be based on ‘rural’ or ‘remote-rural’ areas? (¶ 130) Should the rural schools and libraries receive a greater discount than they

currently receive and should the rural factor also be incorporated into the highest discount bands? (¶ 133);

Increase Funding Cap

The FCC seeks comment on whether to increase the $2.25 billion E-Rate cap (temporarily or permanently) to ensure high-capacity broadband connectivity to and within schools and libraries. (¶ 173)

Increase Transparency

The FCC proposes to increase the transparency and seeks comments on the following:Transparency of E-Rate spending.

◦ How can the FCC increase transparency with respect to how E-Rate funds are allocated and spent?

Transparency of prices available for E-Rate supported services. ◦ How can the FCC best increase the transparency of prices for E-Rate

supported services?Transparency of prices being bid for E-Rate supported services.

◦ Should the FCC consider making bid responses public or at least accessible to other E-Rate applicants?

Transparency of actual purchase prices. ◦ As an alternative to requiring public disclosure of all bids to provide E-

Rate services, should the FCC make available the prices applicants are paying for E-Rate supported services?

Direct Payments to Applicants

The FCC proposes to permit schools and libraries to receive BEAR reimbursement checks directly from USAC and not have to pass through the respective service providers (¶ 259).

Should invoicing deadlines be more rigid in order to recapture and reuse unspent funds?

Permit Multi-year 471s

• The FCC proposes to have PIA only review the first year of a 3-year contract allow applicants, provided there was no changes to the contract or recipients of service in the second and third years of the contract. *

• In the second and third years, applicants would still have to request E-Rate funding via the Form 471, but their contracts would not be subject to PIA review.

Should the FCC also consider multi-year funding commitments?

Should applicants only be permitted to sign contracts up to 3-years in length? (¶ 241)

New FCC Forms 470 and 471

Proposed FCC Form 470 Updates


• Consolidated the Telecommunications and Internet access categories of service into the field Priority One Services

Applicants must still distinguish services between Telecommunications and Internet access on the FCC Form 471


• Block 2, item 8a, 10a and 11a text addition

–8a, 10a, 11a. YES, I have released or intend to release an RFP for one or more of these services. It is available or will become available on the Internet at:


• Document retention certification Block 5, Item 19 update

– “I certify that I will retain required documents for a period of at least five years (or whatever retention period is required by the rules in effect at the time of this certification) after the last day of service delivered.”

New FCC Forms 470 and 471



• Block 2 has been removed and a new data gathering section has been added to Block 5


• Additional Block 5 reporting requirements–For Broadband and other connectivity services only

• E.g. T-1, fiber, DSL, cable, cellular wireless hotspots, satellite

–Does not apply to non-broadband or other connectivity services

• E.g. Cellular service, web hosting and email service

–Complete information for every applicable funding request


• If you are not requesting broadband or other connectivity services for the individual funding request, check the box


• If you are requesting broadband or other connectivity services, fill out Block 5, Item 24

• For example, if you request one T-1, six fiber connections that average 150 Mbps and one gigabit connection:


• Item 25 b, 1 - For applicants if the Internet service is available to students or patrons in more than just a single location or office

– If the access is provided by wired connections, approximately what percentage of the school classroom or public library rooms included in the Block 4 worksheet for this FRN will have access to wired drops? _____?


• Item 25 b, 2 - For applicants if the Internet service is available to students or patrons in more than just a single location or office

– If the access is provided by Wi-Fi connections, approximately what percentage of the school classroom or public library rooms included in the Block 4 worksheet for this FRN will have access to Wi-Fi drops? _____?


• Item 25 c - For consortia and statewide applications, do the connections in this FRN include the last mile connection to the school or library? Yes No

– If no, are these connections only for backbone connections? Yes No


• Document retention certification Block 6, Item 33 update– “I certify that I will retain required documents for a period

of at least five years (or whatever retention period is required by the rules in effect at the time of this certification) after the last day of service delivered.”

E-Rate Program

New FCC Forms 486Proposed Changes

Proposed 486 Changes

• Proposed changes to FCC Form 486

– Name changed to Receipt of Service Confirmation and Children’s Internet Protection Act and Technology Plan Certification Form

– Item 6C, CIPA Waiver for Libraries in FY2004, consolidated with Item 6B, the general checkbox for CIPA waivers

– Item 8, technology plan certification, updated– Item 10, document retention certification updated– Minor text edits

Proposed 486 Changes

• Item 8, technology plan certification, updated to reflect that technology plans only need to be prepared if required by program rules.

– For example, currently technology plans do not need to be prepared if applicants are seeking Priority One services only.

E-Rate Program

New FCC Form 472

Overview

• Changes to FCC Form 472, Billed Entity Applicant Reimbursement (BEAR) Form

– Reimbursement Form Number moved to top and renamed Applicant Form Identifier

– Reimbursement Date to USAC moved to Block 3– Discount column added to Block 2– Some form items renumbered due to the above

changes– Extraneous or confusing text removed– Certification language added

FCC Form 472 Login

FCC Form 472 Block 1

BEAR Form Block 1

BEAR Form Block 2

Note: The total of each line from Block 2 should display up in Item 6. If the system continues to show $ 0.00, click on “Save” located at the bottom of the screen.

Example:

BEAR Form Block 3

Item 27 is new. Enter the Name, Title, and the Address of the person who should receive the check. If it’s the same as the person listed in Block 1, you must re-enter the information.

Block 3 Certifications

Avoid the Dirty Dozen MistakesFall 2013 Applicant Trainings

E-Rate Program

1. Submitting paper forms containing errors

2. Missing deadlines

3. Not following competitive bidding rules

4. Not communicating with service providers after the competitive bidding process

5. Mixed bucket funding requests

6. Incorrect discount calculations

Overview

Avoid the Dirty Dozen Mistakes

7. Incomplete PIA responses

8. Missing or incomplete Item 21 attachments

9. Ignoring USAC letters

10. Poor invoicing practices

11. Inadequate document retention

12. Not managing your E-Rate process

Paper Forms

Unsigned, undated FCC Form 486 paper certification

Paper Forms

FCC Form 472 – service provider certification page 4 signed by same applicant

FCC Form 472 – applicant certification page 3 signed by applicant

Mixing Priority 1 (Telecommunications Services and Internet Access) and Priority 2 (Internal Connections and Basic Maintenance) on the same funding request or the same application causes delays.

• Mixed bucket funding requests filed as Priority 1 must be separated out by your PIA reviewer, and you will be asked to confirm the separation.

• Mixed bucket funding requests filed as Priority 2 may not be reviewed until Priority 2 reviews start.

Mixed bucket funding requests

Mixed Bucket Funding Requests

Problems with applicants not using NSLP data to calculate their discounts:• Using NSLP forms as surveys.

• Not keeping copies of surveys or your discount calculation source documentation (i.e. Monthly Site Claim Form or report generated by Food Services)

• Projecting discounts from surveys with a return rate below 50%.

• Using Community Eligibility Option (CEO) data to validate the reported discount.

– NOTE: CEO schools use NSLP data from the year before they started participation in CEO. The FCC has not indicated whether it will provide a waiver for FY2014 applications to use old data.

Incorrect discount calculations

Discounts

Program Integrity Assurance (PIA) reviews applications for compliance with program rules. If PIA emails or faxes questions but receives incomplete responses, or no response, the funding decision is based on the information at hand. Incomplete responses include:• A response that does not directly address the PIA questions.

• A response that addresses some but not all of the PIA questions.

• A response that does not include documentation when documentation was specifically requested.

Incomplete responses to PIA

Responses to PIA

Responses to PIA

Insufficient response

To avoid delays and/or denials:• If PIA emails or faxes questions to you, read them carefully.

– If you understand the questions and the documentation requested, respond promptly.

– If you do not understand what is being requested, contact the initial reviewer immediately for clarification and document such contact.

• If you need more time, ask for it.

• If you feel you are not communicating successfully with your initial reviewer, ask to speak to a manager.

Incomplete responses to PIA

Responses to PIA

The Item 21 attachment is a detailed description of the services in each funding request and an FCC Form 471 will be considered incomplete until the Item 21 attachment is submitted. PIA uses this information in its review. Common problems include:• Missing Item 21 attachments. If an Item 21 attachment is not

submitted by the deadline, the associated funding request will be denied.

• Incomplete information. PIA will reach out for additional information or clarification if needed. Without this information, PIA must make its funding decision based on the information provided.

Missing or incomplete Item 21 attachments

Item 21 Attachments

Item 21 Attachments

Item 21 attachment missing information

To avoid delays and/or denials:• Review the funding report in the Receipt Notification Letter and

Receipt Acknowledgment Letter for ministerial or clerical errors you can correct.

• Take note of the next steps and any deadlines described in the letter and be prepared to act on them.

• Note any changes from your original submission (e.g., an adjusted service start date in the FCC Form 486 Notification Letter) and take action as appropriate.

USAC Letters

USAC receipt acknowledgment and notification letters

Adjusted Service Start Date

USAC Letters

USAC must be invoiced – either through the applicant FCC Form 472 (BEAR Form) or service provider FCC Form 474 (SPI Form) – for discounts on services actually delivered and installed. Delays or denials can occur if:

• Invoices are filed after the invoicing deadline.• Invoice-related forms are not filed first (FCC Form 473 for

service providers, FCC Form 486 for applicants).• Invoice entries are incomplete or inconsistent.• If the invoice undergoes review, requested documentation

(e.g., proof of payment, copy of contract) is unavailable.

Poor invoicing practices

Invoicing

To avoid delays and/or denials:

• Review the E-Rate Binder guidance for a suggested checklist of documents to retain and how to organize them.

• Store your documents in such a way that you – or your successor – can find them easily if needed.

• Remember that even if your local or state regulations require a shorter time period for document retention, you must follow the FCC program rule for documents related to E-Rate.

• Keep in mind that some documents (e.g., multi-year contracts, notice of public hearing or meeting for CIPA) must be kept for five years after the latest funding year they affect.

Inadequate document retention

Document Retention

http://www.usac.org/_res/documents/sl/pdf/samples/samples-checklist-E-Rate-table-contents.pdf

Document Retention

Response to additional selective review question

To avoid delays and/or denials:• Stay informed.

– Review the guidance information on the USAC website.

– Subscribe to the SL News Brief.• Plan ahead.

– Create a timeline of your E-Rate activities and follow it.– Submit required forms and requests well before the

deadline.

Managing your E-Rate process

Managing the Process

http://www.usac.org/sl/tools/news-briefs/Default.aspx

To avoid delays and/or denials (cont.):• Track your submissions.

– Call CSB for the status of paper form data entry.– Familiarize yourself with the tools on the Search Tools

page to verify postings and certifications, and to track the progress of reviews and requests.

• If you need it, request an extension before the deadline.• Ask questions.

Managing your E-Rate process

Managing the Process

http://www.usac.org/sl/tools/default.aspx

Questions?

education.oConhio.gov

E-Rate Support and Information

Lorrie Germann: 740-253-1153

E-mail: [email protected]

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welcome to fall 2013 e-rate training. agenda introduction to e-rate understanding eligible services...

Documents

erate fall

erate training slide

fcc capped erate funding

program information

program form

students eligible

eligible products

funding year fy