E-Rate Round Table Robert Rice, President, Triple R Consultants Jeannene Hurley, State of MI E-Rate

Coordinator Robert Frost, IS Coordinator Tuscola ISD,

Director of REMC 10

Program Compliance

Roles for All District, ISD, Consortia, Consultant, Vendor

Technology Plans Deadlines: Creation Date vs Approval Date

Forms 470 and RFPs 28-day rule violation

Competitive Bidding Vendor Selection Process: Bid Opening, Documentation Retention, Evaluation

Heightened Scrutiny

Understanding Program Integrity Assurance (PIA) Precommitment Corrections

Clerical Corrections – RAL and 20 days Can Do’s – MONEY or Discount Increase Deadlines, Deadlines Errors Detected During PIA Supporting Documentation

Understanding PIA (cont) PIA Review Levels of PIA Review Preparing for PIA Review Item 21 Attachments PreK, Adult Ed and Special Ed PIA Review Tips

Audit Response What is Audit Response?

Difference between and OIG Audit and SR Roles for All Document Retention

E-Rate Binder Guidance NSLP

Audit Timeline Findings and Other Matters Non-compliant Auditees Recovery Red Light

CIPA(Children’s Internet Protection Act) Technology Protection Measure Internet Safety Policy Public Hearing or Board Meeting

Documentation! Proof of filter – purchase or log

Protecting Children in the 21st Century

Invoicing Invoicing Process Deadlines/Extensions

Go back and get money!

Filing Invoices Online Follow-through w/ vendor Shortcuts – add vendor info in the comment field

Filing Correctly the First Time Invoice Review

Zero funded BEARs

Basic Eligible Services The Eligible Services List (ESL) Product/Service Eligibility

Priority One Telecommunications Internet Access

Priority Two Internal Connections (IC) Basic Maintenance of IC

Miscellaneous

Advanced Eligible Services On-Premise Equipment as Priority One Interconnected VoIP Web Hosting Basic Maintenance of Internal Connections

(BMIC)

Attachment C Documents Due in 15 days

ATTACHMENT C DOCUMENTS DUE TO ERNST & YOUNG WITHIN 15 BUSINESS DAYS (May 4, 2009)

Note: Electronic submission of the requested information (Word document, Excel spreadsheet, Adobe pdf, etc) is preferred.

1. Copies of your audited financial statements for the Funding Year(s) identified in the accompanying letter and a copy of the most recent statements.

2. If your organization is required to have a Single Audit, copies of the OMB Circular A-133 audit reports covering the Funding Year(s) identified in the accompanying letter through the most recent such report.

3. Completed Internal Control Questionnaires (see Attachment E). 4. General description of the information technology environment and a high-level network

diagram. (The description should include how Schools &Libraries (S&L) Program funding for internal connections is being used in the IT environment.)

5. Technology plan(s) covering the Funding Year(s) identified in the letter. (Not necessary if the FRNs are only for basic local and long distance telephone services.)

6. Approval letter(s) for the technology plans in item 5 above. 7. Technology budget(s) for the technology plans in item 5 above. 8. Copy of your Internet Safety Policy and other documentation supporting compliance with

the Children’s Internet Protection Act (CIPA). 9. Record Retention Policy that applied to and was followed for S&L Program

documentation. 10. Copies of local and state procurement regulations pertaining to contracting for the purchase

of telephone service, internet access, and internal connections. 11. Method used and documentation supporting the discount calculation. Please, identify each

entity included in your supporting documentation with the Entity Number assigned by USAC, as it is included in your FCC Forms 471.

12. Fixed asset inventory or other records, in electronic format if available, listing S&L Program funded equipment that was acquired and reimbursed under the Invoice(s) identified in the accompanying letter. (Not necessary if the FRNs related to services rather than equipment.)

This list should include the following elements: FRN SLC Invoice Number Make Model Serial number Physical location (including room number and any movement history) Date installed Beneficiary bill reference number(s)

13. Copies of all relevant contracts and written agreements with service providers and consultants for the period(s). (Include addendums and amendments.)

14. Completed Invoice_Disbursement Spreadsheet that provides details of the invoices comprising various submissions to USAC.

Attachment D, Documents due upon arrival

ATTACHMENT D DOCUMENTS DUE TO ERNST & YOUNG UPON ARRIVAL AT YOUR LOCATION

Note: Electronic submission of the requested information (Word document, Excel spreadsheet, Adobe pdf, etc) is preferred, if available.

1. Copies of the following forms (if applicable) for the Funding Year(s) and FRN(s) identified in the accompanying letter:

a. FCC Form 470 b. FCC Form 471 c. FCC Form 486 d. FCC Form 472 (BEAR), if used for reimbursement(s) e. FCC Form 500, if applicable

2. In association with the above FCC Form(s) 471, information related to the service provider selection process including, but not limited to:

a. RFPs or bidding specifications b. All bids received (both winning and losing) c. Correspondence (including informal communications) with potential selected service

providers (i.e. competitive bidding, service issues, etc.) d. Meeting minutes for discussions and selection of service provider(s)

3. If applicable, copies of contract(s) for the technology protection measure (i.e. Internet filter) and invoices for the Funding Year(s) under review.

4. Copies of the invoices included in the previously completed Invoice_Disbursement Spreadsheet.

5. All documentation associated with above FCC Form(s) 471 and selected FRN(s) including service substitution approval letters and equipment transfer notification letters to USAC.

6. When FCC Form 472s (BEAR) is used: a. Copies of canceled checks written to the service provider b. Copies of bank statements and any other supporting documentation to confirm receipt

of the discounted portion from the service provider. 7. When FCC Form 474s (SPI) is used, copies of canceled checks written to the service

provider for the non-discounted portion. 8. Copy of relevant meeting minutes during the period(s) being examined where the Schools

& Libraries (S&L) Program was an agenda item. 9. The following contract information (specific request of the FCC-OIG):

a. School board members’ names and telephone numbers b. Superintendent’s name and telephone number c. Principal’s name and telephone number (if the beneficiary is an individual school) d. CFO or controller’s name e. Consultant’s company name, address, and telephone number, as well as the individual

consultant’s name (if a S&L Program consultant is used)