october, 20081 e-rate year 2009 opportunities for michigan libraries don dietrich btu consultants,...
TRANSCRIPT
October, 2008 1
E-Rate Year 2009Opportunities
forMichigan Libraries
Don DietrichBTU Consultants, LLC
(Includes content from October, 2008 SLD Seminars, with permission)
October, 2008 2
E-Rate 2009 Agenda
9:30am – 12:30pmE-Rate ReviewTechnology Plans & Budgets
CIPA for LibrariesE-Rate Application Process
Discounts, Priorities & EligibilityFunding Years & Annual CyclesForms 470, 471, Item 21 Attachments
12:30 – 1:00pm Lunch
1:00pm – 4:00pmE-Rate Approval and Acceptance Process PIA Review Process Forms 486, 500, 472 BEARS vs Discounts Contract Extensions & Service Substitutions SPIN and other changesRecord Keeping, Appeals & Audit PreparationWhat’s new for 2009Michigan Library Resources
October, 2008 3
Library ResourcesMichigan E-Rate for Libraries
http://www.michigan.gov/erateforlibraries
October, 2008 4
Annual Cycle
Plan & File Form 470 September – October
Review / Update / Approve Technology Plan
Free & Reduced Lunch Counts
Competitive RFPs Developed (if required) October - November
Vendor Conference(s) October - November
Vendor Responses Received Early December
System / Vendor Selection Mid December
Contract Negotiation December - January
Forms Submission to SLD (Form 471) February
Implementation (Form 486 / 500 / 472) July – June
October, 2008 5
E-Rate History - Telecom Act of 1996
– Concept of Universal Service began in 1934– USAC (Universal Service Administrative Co) manages three
programs under FCC (High Cost, Rural Health, Low Income)– Local Service is opened to competition in 1996– Schools and Libraries Division of USAC created to administer
special ‘Education Rate’ fund to improve tech in learning– Amount recommended yearly by FCC / approved by congress– Original idea of funding only telecom and internet expanded in
1998 to include a growing list of internal connections– 1999 Carriers add charges to consumer telephone bills
October, 2008 6
E-Rate History - Telecom Act of 1996
– 2000-2008 Rules and guidelines constantly changing but basic legislation and administration is constant.
– Appeals and FCC Orders change the SLD’s operating guidelines:
• Definition of Educational Purposes• Clarification of “30% Rule”• Ministerial and Clerical Errors• Requirements for Signed Contracts• 2-in-5 Rule• …many others
October, 2008 7
E-Rate Funding Year Cycle
Yearly cycle of applications, awards and spending
Current Year funded at $ 2.25 Billion
All Priority One Requests (Telecommunications & Internet)
funded first regardless of need
Priority Two Requests (Internal Connections) awarded to poorest
applicants first, until all funds are exhausted
Year One (1998) funded down to 70+% level
Year Two (1999) all levels funded (money left over)
2000 – 2006 variable, always a cutoff, usually mid 80%’s
Year 2007 will go to at least 83%
October, 2008 8
E-Rate Program Rules
Discounts are based on NSLP and range from 20 – 90%
Competitive Process – requests must be posted for 28 days
All funds must be used for
Eligible goods and services (see handout)
Installed at eligible facilities
Provided by eligible service providers (SPIN numbers required)
Eligible goods and services divided into four categories
Telecommunications (carrier services)
Internet (ISP fees)
Internal Connections (switches, routers, cabling, servers…)
Basic Maintenance of Internal Connections
October, 2008 9
E-Rate DiscountsINCOME URBAN LOCATION RURAL LOCATION
Measured by % of students eligible for the National School
Lunch Program
Discount Discount
If the % of students in your school that
qualifies for the National School Lunch
Program is…
…and you are in an URBAN area, your discount will be…
…and you are 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%
October, 2008 10
E-Rate Eligible Items
• Telecommunications Services - includes basic phone service (local and
long distance), data networks, cell phones etc.
• Internet Access – includes student e-mail, web hosting etc.
• Internal Connections - includes the wiring and network equipment needed
to bring information directly to end-user – only available 2 out of 5 years
• Maintenance (new in 2005) – very strict guidelines
ELIGIBLE SERVICES LIST & UPDATES ON SLD WEBSITE
October, 2008 11
What’s Covered
Eligible Items Include:– Local and long distance telephone usage, Cellular and Paging– Internet access costs, Web Hosting, Email Service– Cabling and hardware (switches, routers…) within buildings – UPS’s, equipment racks etc.– Network Servers for Internet access, E-Mail…– Telephone systems (PBX’s) including VoIP– Limited Software License Fees (Netware, some CALs)– Maintenance charges (strict guidelines)– VPN’s (2006)– Voice Mail Systems (2007)
October, 2008 12
What’s Not Covered
Not Eligible for E-Rate:
– Project management
– Computers, Telephone instruments, Video Cameras
– Power infrastructure within building
– Power service upgrade to building
– Physical security or construction
– Application Software
– Consulting Services, Training, Personnel Costs
October, 2008 13
E-Rate Eligible Items
ESL & UPDATES
http://www.usac.org/sl/tools/eligible-services-list.aspx
Eligible Services List - Schools and Libraries - USAC
October, 2008 14
www.sl.universalservice.org
http://www.usac.org/_res/documents/about/pdf/2008-ESL-FCC0-07-130.pdf
October, 2008 15
Eligible Services List – Changes 2009
Few changes for 2009:
October, 2008 16
• Michigan Library Eligibility
– Eligibility requirements for LSTA (E-Rate) are available on the Michigan Library website…
16
E-Rate Eligibility
http://www.michigan.gov/documents/hal/lm_LSTA-ErateEligibility_251911_7.pdf
October, 2008 17
E-Rate Eligible Locations
http://www.usac.org/sl/applicants/step01/
LibrariesLibraries must meet the statutory definition of library or library consortium found in the 1996 Library Services and Technology Act (Pub. L. 104-208) (LSTA) to meet eligibility requirements for Schools and Libraries support.
Libraries must be eligible for assistance from a state library administrative agency under that Act.
Libraries must have budgets completely separate from any schools (including, but not limited to, elementary and secondary schools, colleges and universities).
Libraries cannot operate as for-profit businesses.
October, 2008 18
E-Rate Eligible Locations
Library Non-Instructional Facilities (NIFs)
• Educational Purposes– Activities that occur on library or school property are presumed to be
integral, immediate, and proximate to the education of students or the provision of library services to library patrons and therefore qualify as educational purposes.
– Customary work activities of employees of a school or library are presumed to fall under the definition of education purposes.
Step 6: Educational Purposes - Applicants - Schools and Libraries - USAC
October, 2008 19
• Administrative buildings
• Bookmobile garages
• Interlibrary loan facilities
• Library technology centers
19
• Examples of Non-instructional Facilities (NIFs) that can receive Priority 1 services:
E-Rate Eligibility
October, 2008 20
• Example of Library Staff that can receive Priority 1 services regardless of location:
– Wireless Telecommunications Services used offsite such as cell phones for library staff providing library services on a library’s mobile library unit van
20
E-Rate Eligibility
October, 2008 21
• Educational Purposes – Priority 2
– Priority 2 services to NIFs are NOT eligible unless those internal connections are essential for the effective transport of information to an instructional building of a school or to a non-administrative building of a library.
21
E-Rate Eligibility
October, 2008 22 22
Conditional Eligibility
October, 2008 23 23
Priority 1 On-Premise Equipment
1. Must be an integral component of Telecommunications or Internet Access service
2. The same service provider that provides the telecommunications or Internet access service provides the equipment
3. Responsibility for maintaining the equipment rests with the service provider, not the school or library
4. The school or library may never own the equipment
October, 2008 24 24
Priority 1 On-Premise Equipment
5. Upfront, capital charges of the eligible on-premise equipment are less than 67% of total charges (recurring plus non-recurring) in the funding year.
6. Must only be used for the receipt of the eligible telecommunications or Internet access service
7. The Local Area Network of the school or library is functional without dependence on the equipment.
8. No limitations that would prevent the service provider from using its network equipment in part for other customers
October, 2008 25
Annual Cycle
Plan & File Form 470 September –
October
Review / Update / Approve Technology Plan
Free & Reduced Lunch Counts
Competitive RFPs Developed (if required) October - November
Vendor Conference(s) October - November
Vendor Responses Received Early December
System / Vendor Selection Mid December
Contract Negotiation December - January
Forms Submission to SLD (Form 471) February
Implementation (Form 486 / 500 / 472) July – June
October, 2008 26
Technology Plan
• Applicants must develop a technology plan
– Use telecommunications services and information technology to achieve educational goals and/or library improvements
• A plan is required for discounts on any products or services other than “Basic Telephone Service and voice mail.
Step 2: Technology Planning - Applicants - Schools and Libraries - USAC
October, 2008 27
Technology Plan
• Must be written before Form 470 is filed
• Must cover all 12 months of the funding year
• Must contain the five basic elements
• Should not cover more than 3 years
• Must be approved by a USAC Certified Tech Plan Approver (TPA) by the start of services or the filing of Form 486, whichever is earlier
October, 2008 28
Technology Plan
Technology Planning for USF E-Rate
Sonya Schryer NorrisTechnology Plan Advisor
Library of Michigan
Please download the Powerpoint Presentation:
October, 2008 29
CIPA Requirements
– CIPA compliance is only required if you are applying for Internet or Internal Connections
– CIPA is NOT required if only applying for Telcom
October, 2008 30
CIPA Requirements
– Must have an Acceptable Use Policy or Internet Safety Policy that contains specific elements
– Must have a public hearing or notice
– Must have technology protection (filtering) software in place to protect minots.
– All documentation supporting compliance with CIPA rules is maintained in E-rate binder.
October, 2008 31
CIPA Requirements
The Internet safety policy must address the following components:
– Access by minors to inappropriate matter on the Internet and World Wide Web.
– The safety and security of minors when using electronic mail, chat rooms, and other forms of direct electronic communications.
– Unauthorized access including "hacking" and other unlawful activities by minors online.
– Unauthorized disclosure, use, and dissemination of personal information regarding minors.
– Measures designed to restrict minors' access to materials harmful to minors.
October, 2008 32
CIPA Requirements
Record of a public hearing or notice.• Per the FCC’s CIPA Order, there must be reasonable public notice
and at least one public hearing or meeting to discuss the proposed Internet safety policy and technology protection measure. Keep Board meeting minutes, advertisements, etc.
Evidence a technology protection measure was in place during the audited Funding Year.
• Filter reports.• Documentation showing the purchase or renewal of filter
equipment, software and/or licenses. (Must cover the Funding Year(s) being audited.)
October, 2008 33
CIPA ResourcesAmerican Library Association website:
http://staging.ala.org/ala/aboutala/offices/wo/woissues/civilliberties/cipaweb/cipa.cfm
CIPA Rules from FCC http://www.fcc.gov/cgb/consumerfacts/cipa.html
CIPA Rules from SLD http://www.universalservice.org/sl/applicants/step10/cipa.aspx
CIPA Rules from IMLS http://www.imls.gov/about/cipa.shtm
Bob Bocher Wisconsin slideshttp://dpi.wi.gov/pld/ppt/cipa.ppt
October, 2008 34
Calculating Discounts
http://www.michigan.gov/hal/0,1607,7-160-17451_18668_18690-59509--,00.html
Use Chart on website for NSLP calculations for FY2009
October, 2008 35
Calculating Discounts
• E-rate discounts depend on:– The percentage of students eligible for the National School
Lunch Program (NSLP) or an equivalent measure of poverty
– The urban or rural status of the county or census tract in which the school or library building is located
• USAC may request third-party verification of student counts submitted by applicants
October, 2008 36
Calculating Discounts
• Library outlet/branch calculation:
– Calculate the percentage of students eligible for NSLP in the school district in which the library building is located
– Use the urban or rural status of the county or census tract in which the library outlet/branch is located
October, 2008 37
Calculating Discounts
• Library system calculation:
– Calculate the E-rate discount for each library outlet/branch in the library system
– Calculate the simple average discount
(Add together the discounts for the outlet/branches and divide by the total number of outlets/branches)
October, 2008 38
Calculating Discounts
• Consortium calculation:
– Calculate the E-rate discount for each individual member of the consortium
– Calculate the simple average of all the member discounts
October, 2008 39
Calculating Discounts
• If a library is under construction –– Use the simple percentage of NSLP
eligibility for the school district in which the library building is located to calculate the discount(Total number of students eligible for NSLP in
the school district divided by the total number of students in the school district)
October, 2008 40
Procurement Process
Plan Procure Implement
Tech Plan
Requirements
Design
Detail Specifications
Internal Approvals
Competitive RFP (if required)
Vendor Selection
Award Contracts
Submit Specific Requests
Coordinate Vendors
Monitor Installation
Resolve Upsets
Audit Financial Documents
Assure Completion
Recommend Acceptance
October, 2008 41
E-Rate Forms
Plan Procure Implement
Form 470
Notice of applicant’s intent to acquire goods and services (non-specific as to amounts or vendors)
Form 471
Specific request for goods and services by entity, category, detailed costs and vendor (requires signed contract with vendor)
Form 486
Notice of intent to accept funds awarded
Form 500
Change award amount or items
Form 472 (BEAR) – Recover discounts already paid to vendors for eligible goods and services.
October, 2008 42
http://www.usac.org/_res/documents/sl/pdf/application-process-flow-chart.pdf
October, 2008 43
E-Rate Form 470
Step 3: Form 470 Filing Information - Applicants - Schools and Libraries - USAC
October, 2008 44
E-Rate Form 470
• Filing Form 470 opens a competitive bidding process.
• Can also issue a Request for Proposals (RFP).
• Applicants are responsible for ensuring an open and fair process and selecting the most cost-effective provider of the desired services.
• RFP is not required under FCC rules.
• Even if you have an RFP, you must describe the services you desire on your Form 470.
October, 2008 45
E-Rate Form 470• Applicants must choose the most cost-effective solution to
their Form 470 or RFP, with price as the primary factor
• Other factors can be considered, but price must be the most heavily weighted.
• Evaluation process should be carefully documented and that documentation must be maintained.
• Must indicate willingness for a multi-year contract or contract with extensions if appropriate.
http://www.usac.org/sl/tools/required-forms.aspx
October, 2008 46
E-Rate Form 470
• File online or on paper
• Online Filers can use Interview Mode or Form Fill-out
• You will need to know how many entities you are applying for and the area-code, prefix of each
• You will need the general descriptions for each service that you are requesting
Training Website SLD Training Site
October, 2008 47
E-Rate Form 470
• You must wait at least 28 days from the submission date before entering into a contract for services
• If filed online, the form will calculate this date for you
• If you are under a multi-year contract from a previous year, you do not need to file a Form 470 every year
• If you are under Month-Month or Tariff rates, you must file a Form 470 every year
October, 2008 48
E-Rate Form - 470
Applicant Personal Identification Numbers (PINs)
• Will be automatically issued to any new authorized persons filing paper Forms 470, 471 and 486 on or after November 1 of the funding year.
• After accepting Terms and Conditions, can be used immediately to certify online.
October, 2008 49
RFP Evaluation
http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-vendor-selection-worksheet.pdf
October, 2008 50
Annual Cycle
Plan & File Form 470 September – October
Review / Update / Approve Technology Plan
Free & Reduced Lunch Counts
Competitive RFPs Developed (if required) October - November
Vendor Conference(s) October - November
Vendor Responses Received Early December
System / Vendor Selection Mid December
Contract Negotiation December - January
Forms Submission to SLD (Form 471) February
Implementation (Form 486 / 500 / 472) July – June
October, 2008 51
E-Rate Form - 471
Step 7: Form 471 Filing Information - Applicants - Schools and Libraries - USAC
October, 2008 52
E-Rate Form - 471
Form 471• Provides specific information on services, service
providers selected, and contracts• Provides discount calculation information• Must be filed for each funding year• Contains certifications of compliance• Includes one or more funding requests• Each FRN must reference a specific Form 470
October, 2008 53
E-Rate Form - 471
Form 471 Deadline
• Must be filed online or postmarked on or before the close of the Form 471 application filing window.
• Forms 471 filed after the close of the window will be considered after all Forms 471 filed in-window.
• Certifications for associated Forms 470 also must be filed online or postmarked before the close of the window.
October, 2008 54
E-Rate Form - 471
Form 471 Block 1 & 3
• Block 1 - Billed Entity Information
• Block 2 (schools only)
• Block 3 - Impact of Services Ordered for Libraries
• Block 4 - Discount Information
• Block 5 - Detailed Funding Requests
• Block 6 - Certifications and Signature
http://www.usac.org/sl/tools/required-forms.aspx
October, 2008 55
E-Rate Form - 471
Contracts
• Applicants and service providers must sign contracts for services that are not provided under tariff or under month-to-month arrangements
• Contracts can cover more than one year or contain extensions, but applicant must have indicated these options in the Form 470
Step 4: Contract Guidance - Schools and Libraries - USAC
October, 2008 56
E-Rate Form - 471
• Don’t combine Priority 1 and Priority 2 requests on the same Form 471.
• Review of Priority 2 requests may hold up Priority 1 commitments.
• File (and certify) online
• Reduces errors and speeds processing
• USAC will issue you a PIN after successful certification of your Form 471 if you do not already have one.
October, 2008 57
E-Rate Form - 471
• Remove ineligible costs from funding requests
• Document ineligible costs carefully
• 30% rule – if 30% or more of the dollar value of the request is for ineligible products and services, the entire request will be denied
• Work with your service provider(s) to create your Item 21 attachment(s)
• File Item 21 Attachments online
Training Website SLD Training Site
October, 2008 58
E-Rate Form – 471 – Item 21
• You must attach a description of goods and services
• Include breakdown of components, costs, manufacturer, make and model
• Examples on SLD website
• Clarity and completeness will prevent PIA questions
• Use Online version if possible
October, 2008 59
Form – 471 – Item 21 - Example
Step 7: Item 21 Attachments for Form 471 - Applicants - Schools and Libraries - USAC
Training Website SLD Training Site
October, 2008 60
B R E A K
October, 2008 61
E-Rate 2009 Agenda
9:30am – 12:30pmE-Rate ReviewTechnology Plans & Budgets
CIPA for LibrariesE-Rate Application Process
Discounts, Priorities & EligibilityFunding Years & Annual CyclesForms 470, 471, Item 21 Attachments
12:30 – 1:00pm Lunch
1:00pm – 4:00pmE-Rate Approval and Acceptance Process PIA Review Process Forms 486, 500, 472 BEARS vs Discounts Contract Extensions & Service Substitutions SPIN and other changesRecord Keeping, Appeals & Audit PreparationWhat’s new for 2009Michigan Library Resources
October, 2008 62
SLD E-Rate Resources
Sources of Information:
• Service Provider’s Manual (online)
• SLD Website Schools and Libraries Program - USAC
• Service Provider Hotline (1-973-428-7335)
• User Hotline (1-888-203-8100)
• Online “Submit a Question” www.slforms.universalservice.org
• Email Questions to: [email protected]
October, 2008 64
SLD E-Rate Resources
Sources of Information:
• Search Reference Area – Reference Area - Tools - Schools and Libraries - USAC
• SLD Newsbriefs News-briefs - Schools & Libraries – USAC
• Training Website SLD Training Site
• SLD Training Presentations http://www.usac.org/sl/about/training-presentations/training-presentations-archive/training-2008/fall/materials.aspx
October, 2008 65
E-Rate – PIA Review• Forms 471 are reviewed by Program Integrity Assurance
(PIA) for compliance with program rules concerning areas such as:
• Competitive bidding process• Contracts• Discount calculation• Sufficient budget• Establishing Form 470• Technology plan• Children’s Internet Protection Act
Step 10: Children's Internet Protection Act (CIPA) - Applicants - Schools and Libraries - USAC
October, 2008 66
E-Rate – PIA Review
• Ministerial and Clerical Errors (M&C)– Correcting minor errors due to data entry– Applicants get opportunity to correct information once data
entered by USAC• Form 470 Receipt Notification Letter• Form 471 Receipt Acknowledgment Letter
– Make corrections to the letter you receive and return to USAC in timeframe specified in the letter to get corrections processed
October, 2008 67
E-Rate – PIA Review
• PIA will verify items with you more than before
• At the end of the review, will give you one more opportunity to fix modification and denial reasons
• Applicants can split out PIA-detected services or entities into separate funding requests.
October, 2008 68
E-Rate – PIA Review
• FCC has clarified that the 30% Rule does not apply to entities, only services
• Applicants must comply with state & local procurement regulations
• Applicants must retain documentation for five years from the last date to receive service.
October, 2008 69
E-Rate – PIA ReviewTop Reasons for Denial
No PIA Response from ApplicantYou MUST respond within 7 days or request extension
Form 470 not certifiedthere is NO DEFENSE except Fedex Receipt
District checked box for “No Tech Plan Req’d”PBX’s and T1’s are not “Basic Telecom”
Internet vs Telecom ServicesMost ISP’s are NOT Telecom Providers
Invalid ContractsPurchase Orders are not always acceptable
October, 2008 70
E-Rate – PIA Review• Provide information to PIA promptly
• Work with your service provider to comply with information requests.
• Make sure your answers respond completely to the questions asked.
• Ask for more time to respond if you need it.
• However, if you ask for more time, your PIA representative will work on other applications and you may wait longer for a decision.
• Check the 471 Application Status Tool (SLD website)
Form 471 Status Check Selection Criteria
October, 2008 71
Annual Cycle
Plan & File Form 470 September – October
Review / Update / Approve Technology Plan
Free & Reduced Lunch Counts
Competitive RFPs Developed (if required) October - November
Vendor Conference(s) October - November
Vendor Responses Received Early December
System / Vendor Selection Mid December
Contract Negotiation December - January
Forms Submission to SLD (Form 471) February
Implementation (Form 486 / 500 / 472) July – June
October, 2008 72
E-Rate Approval & Acceptance
Funding Commitment Decision Letter (FCDL)– Cover page of important reminders– Reports status of individual funding requests:
• Funded• Not funded• As yet unfunded (Priority 2 requests)
– Service provider does not receive this status• Cancelled
– May receive more than one FCDL Step 9: Funding Commitment Decision Letter - Applicants - Schools and Libraries - USAC
October, 2008 73
E-Rate Approval & Acceptance
Funding Commitment Decision Letter (FCDL)
ALWAYS Appeal a decision you don’t agree with
Call Hotline for assistance
October, 2008 74
E-Rate Approval & Acceptance
• Check all entries on the FCDL carefully to make sure there are no data entry errors.
• Use the information on the FCDL to prepare your Form 486.
• Service Providers all receive copies of FCDL and should call to move forward.
October, 2008 75
E-Rate Form 486
Step 10: Form 486 Filing Information - Applicants - Schools and Libraries - USAC
October, 2008 76
E-Rate Form 486Form 486
• Notifies USAC that services have started and invoices can be paid
• Certifies that Tech Plan (if required) meets program requirements.
• Certifies the status under Children’s Internet Protection Act (CIPA).
• Lead members of consortia may be required to collect CIPA certifications from consortium members on a separate form (Form 479).
October, 2008 77
E-Rate Form 486
Children’s Internet Protection Act (CIPA)
• Applicants must certify compliance with requirements:
• Internet safety policy
• Public notice or meeting
• Technology protection measure (filter)
• CIPA does not apply to BASIC Telecommunications Services, but applicant must still certify that it receives only those services
Training Website SLD Training Site
October, 2008 78
E-Rate Form 486
Form 486 Deadline• Form 486 must be filed online or postmarked no later
than• 120 days after the Service Start Date OR• 120 days after the date of the FCDLwhichever is later.
• If the Form 486 is late, the date 120 days before the Form 486 online filing or postmark date will become the start date for discounted services and funding may be reduced.
October, 2008 79
E-Rate Form 486Form 486 Service Start Date
• USAC may adjust the Service Start Date in order to comply with program rules:• Form 486 filed after the deadline• Technology plan approval issues• CIPA compliance issues• Conflict with Form 470 allowable contract date
• The adjusted date is the earliest date that discounted services may be provided.
• Invoices for services provided before that date will not be paid.
October, 2008 80
E-Rate Form 486
Form 486 Service Start Date
• Cannot be before July 1 of the funding year.
• Can be as early as the date that the service provider ships the product to the applicant — or earlier, depending on the arrangements between the applicant and the service provider and/or the terms of the contract.
October, 2008 81
E-Rate Implementation Deadlines
Service delivery deadlines
• Recurring Services (June 30)
• Non-recurring Services (September 30)
• Deadline automatically extended to September 30 of the following year for FCDLs, service substitution approvals, and SPIN change approvals dated on or after March 1 of the funding year.
• Applicants can also request extensions for specific reasons involving difficulties with delivery of services by service provider.
October, 2008 82
E-Rate Reimbursements
Don’t Stop Here – you have to ask for the money
• Applicants must use SPI (Service Provider Invoicing) or BEAR (Billed Entity Application for Reimbursement) process to actually GET THE MONEY.
• Contact your vendor
• Call our Hotline if you need help
October, 2008 83
BEARs vs Discounts• BEAR (Billed Entity Applicant Reimbursement) Form 472
is filed by the applicant and certified by the service provider after the applicant receives services and pays for the services in full.
• DISCOUNTS (SPI Service Provider Invoice) Form 474 is filed by the service provider after providing services and billing the applicant for its non-discount share.
• Form 472 or 474 must be filed online or postmarked no later than
• 120 days after the last date to receive service OR
• 120 days after the date of the 486 NL
October, 2008 84
BEARs vs Discounts
• Form 471 allows you to specify your preference
• Service Providers will receive this notice and should comply – but are not required to unless specified in your contract
October, 2008 85
E-Rate Form 472 - BEAR
Form 472 and Instructions - Tools - Schools and Libraries - USAC
October, 2008 86
E-Rate Form 472 - BEAR
• If using paper - must use New Form (April 2007)
• File Annually, or Quarterly
• Filing Online is MUCH easier and faster
• Must have copies of invoices
• Expect delays in processing 30-60 days (paper)
Training Website SLD Training Site
October, 2008 87
E-Rate Changes – Form 500
• Change FRN Start Date
• Contract Extensions
• FRN Reductions
• FRN Cancellations– Unused Funds
October, 2008 88
Form 500
• Required to make changes to Funding Requests
• Service Start Date
• Contract Expiration Date
• Amount of Funding (reductions only)
• No ONLINE version (yet) – must print / fill out / mail
October, 2008 89
E-Rate Changes – Other
• FRN Extensions
• Service Substitutions
• SPIN Changes
Use Online “Submit a Question”
October, 2008 90
FRN Extensions (Service Delivery Extension Request)
• Only applies to Internal Connections
• Must be requested if work cannot be finished by 09/30 deadline
• Must be requested prior to deadline
• Will be granted only in certain cases
• No FORM exists, just use SLD guidelines
• Must also file FORM 500 to extend contract date
Step 11: Service Delivery Deadlines and Extension Requests - Applicants - Schools and Libraries - USAC
October, 2008 91
Service Substitutions
• Use if you change (buy) anything that varies from what you described on your 471 & Item 21
• No FORM, just follow instructions
• File Online using “Submit a Question”
• Depending on specifics, may not need to wait for approval
Service Substitutions - Schools and Libraries - USAC
October, 2008 92
SPIN Changes
• If you change Vendors from your 471
• CORRECTIVE vs OPERATIONAL
• No FORM, just follow instructions
• File online using “Sumbit a Question”
• Usually approved in a few weeks
• Vendors will be notified
(SPIN) Change Guidance - Schools and Libraries - USAC
October, 2008 93
Record Retention
• Setup an electronic and paper file for each funding year
• Make a checklist of included items
• Make a spreadsheet across years
• Monitor at least monthly
October, 2008 94
Record Retention
• USAC E-Rate Binder Table of Contents
– Downloadable Table of Contents Guide– Downloadable Table of Contents (Word document
preformatted for Avery© Ready Index 10) – Located in USAC web site Reference Area http://www.usac.org/sl/tools/reference-area.aspx#c
October, 2008 95
Record Retention
• Retain documents to show your compliance:– Letters of agency and any agreements with all consultants– Technology Plan and Plan Approval letter– RFP, including evidence of publication date– Any and all bids (winning and losing)– Documents describing bid evaluation criteria and
weighting– Any correspondence with potential bidders– Documents related to the selection of the service
provider(s)– Signed and dated copies of contracts.
By law you must retain all records for 5 years
October, 2008 96
Appeals
• USAC decisions can be appealed to USAC or to the FCC.• Generally, appeal first to USAC.• Can appeal to the FCC if USAC denies.
• Can be filed electronically or on paper.• Must be filed within 60 days of the USAC decision.• Requests for waivers of rules must be filed with the FCC.
File an Appeal - Schools and Libraries - USAC
October, 2008 97
Audits
• Why me?
– Applicants and service providers certify and agree to be audited for up to five years – from end of service.
– Some are random.
– Some are not (whistle-blower complaints).
– You will receive advance notice of the audit
– Auditors can be from USAC, the FCC or external auditors
Understanding Beneficiary Audits - Schools and Libraries - USAC
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Audit Preparation
• Make sure that your documentation is in order. See website for complete list of documents that you should have available to support your applications.
• Make sure that your physical inventory lists are in order so that you can quickly identify equipment
• Financial records – including cancelled checks - will be required
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Audit Results
• Findings
– An internal control or other observation that is not a program rule violation.
• Exceptions
– A program rule violation. This can result in taking back a commitment
Any results can be appealed. Comments or complaints can be emailed to SLD: [email protected]
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Changes for Year 2009
• Many more audits cause more funding delays
• Fiscal Year Audits versus E-Rate Year Audits
• “Attestation Examinations”
• Reduced amounts for Internal Connections and
Maintenance
October, 2008 101
Changes for Year 2009
• Document everything - “Email yourself”
• Build and retain an “E-Rate Binder”
• Plan for eventual audit
• New guidance on new, merged and closed
libraries
• New guidance on State Master Contracts
October, 2008 102
Changes for Year 2009
NPRM (Notice of Proposed Rule Making) could result in
more eligible services in future funding years…
• Interconnected VoIP
• Filtering Software
• Dark Fiber
• Anti-Virus Software
• Scheduling Software
• Telephone Broadcast Messaging
http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-08-173A1.doc
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FY 2009 Window
471 Filing Window:
opens at noon (EST) on
closes at 11:59pm (EST) on
LAST DAY FOR Form 470 is
October, 2008 104
Library ResourcesMichigan E-Rate for Libraries
http://www.michigan.gov/erateforlibraries
October, 2008 105
Library Resources - Listserve
http://www.michigan.gov/hal/0,1607,7-160-17451_18668-142297--,00.html
October, 2008 106
Library Resources
ALA E-Rate Pages: http://staging.ala.org/ala/aboutala/offices/wo/woissues/techinttele/erate/erate.cfm
Institute of Museum and Library Services: http://www.imls.gov/
Libr of MI Interactive Library Directory: http://envoy.libraryofmichigan.org/isapi/4disapi.dll/directory/search.html
Michigan Library Listserve:http://www.michigan.gov/hal/0,1607,7-160-17451_18668-142297--,00.html
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Library Resources
EDLINC (Education & Library Networks Coalition): http://www.edlinc.org/
Funds for Learning: http://www.fundsforlearning.com/content/blogcategory/0/89/
E-Rate Central: http://www.eratecentral.com/
SLD Home Page: http://www.usac.org/sl/
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Information & AssistanceMichigan Libraries E-Rate Support Hotline
888-307-6569
Our Goals:
Answer all questions on first call
Followup and call back if required
Escalate or provide references and contacts
October, 2008 109
Information & AssistanceE-Rate Support Hotline
We Can Provide Advice on:Overall program compliance
SLD forms 470, 471, att 21, 486, 472, 500 Eligibility of goods, services and locations
How to prepare a SPIN change letterHow to prepare a Service Substitution letterStrategy for writing an appeal
We Cannot:Prepare, complete or submit FCC forms
Act on behalf of your library
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Information & Assistance
BTU Consulting, LLC
Toll Free Support Hotline – 888-307-6569
Email to:
Carol Underriner: [email protected]
Lori Thompson: [email protected]
Don Dietrich’s email: [email protected]
Don Dietrich’s Cell Phone: 314-378-1667