October 24, 2005
The E-rate:
An Overview of Basics for 2006
Bob Bocher 608-266-2127 fax 608-266-2529
robert.bocher@dpi.state.wi.us
Steve Sanders 608-266-7112 fax 608-267-1052
stephen.sanders@dpi.state.wi.us
Agenda
1. 2. 3.
E-rate overview What’s new for 2006? Review of the application process
Fall 2005 E-rate Workshops:
Two identical sessions for experienced E-rate applicants: 1) Wednesday, Nov. 2, 3:30 – 5:45pm 2) Thursday, Nov. 3, 3:30 – 5:45pm
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E-rate Program Overview
Part of the 1996 Telecommunications Act
Funded at $2.25 billion annually; contributed by telcos Schools and Libraries Division (SLD) manages program Telecommunications Internet access Internal connections
1. 2. 3.
Get discounts on three eligible services
1. 2. 3.
Who is eligible?
K-12 public and private schools Public libraries NIFs (Priority 1)
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What Are E-rate Eligible Services?
Eligible services described in Eligible Services List
Lists Services which are conditionally eligible and ineligible 2006 list to be public in a few days? Telecommunications services
Priority 1
Local and long distance Wireline and wireless Voice, video, data
Internet access
Priority 1 funded first, then Priority 2 funded starting with neediest applicants (90%, 89%, 88%, etc.). Seldom funded below 80%.
Priority 2
Internal connections (switches, hubs, routers, wiring)
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How Much Discount Can I Get?
Discount based on students eligible for free/reduced lunch Data entered on DPI’s Lunch Data Website Lunch Website open: November 1 – December 6 lunch count for last operating day in Oct. Letter to be sent to all districts, but alert dist. staff now
For 2006 E-rate applications, DPI will use enrollment and lunch data from the fall of 2004.
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Discount Matrix
INCOME Measured by % of students eligible for School Lunch Program If the % of students in your school that qualifies for the Lunch Program is… Less than 1% 1% to 19% 20% to 34% 35% to 49% 50% to 74% 75% to 100% URBAN RURAL
Discount …and you are in an URBAN area, your discount will be… 20% 40% 50% 60% 80% 90%
Discount …and you are in a RURAL area, your discount will be… 25% 50% 60% 70% 80% 90%
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The Application Process
Technology Plan – What is my plan? Form 470 – What services do I want? Form 471 – What services did I order?
Lunch data – How much of a discount do I get?
Form 486 – When did services start? Form 472 or Form 474 – How do I receive reimbursements or discounts? Online filing/certification available for most forms
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Top Reasons for Denial
Form 470 not filed Form 470 not certified or certified late 28-Day Rule violation Competitive bidding violations Contracts not signed or not valid Insufficient support resources Invalid telecom provider Insufficient documentation Requests for ineligible products and services
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Document Retention
You must retain all records related to the application for receipt and delivery of discounted services for a period of five years after the last day of service This requirement started in 2004, but is being stressed more by the SLD Failure to maintain records or failure to make available required documentation is an FCC rule violation that may warrant recovery of funds
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Examples of Retained Documents
Pre-bidding process Bidding process
All
responses to bid
Notes from bid review meetings Contracts
Purchase and delivery of services Invoices Inventory All E-rate forms
Retain all documentation for at least five years!!
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What’s New for 2006?
Overall, issues of Waste/Fraud/Abuse driving most program changes
Greater Congressional scrutiny; Congressional W/F/A rpt out last week ADA bill in House
Funding suspension possible for 2005 or 2006?
Hurricane Katrina impacting opening of the 471 window
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What’s New for 2006 (cont)
Need to get FCC Registration Number
FCC site: https://svartifoss2.fcc.gov/coresWeb/publicHome.do Schools: http://nces.ed.gov/ccd/schoolsearch/ Libraries: http://nces.ed.gov/surveys/libraries/librarysearch/
Schools need NCES no.; libraries need FSCS no.
SLD will push out PINs to 2005 applicants and if you submit a Form 470 for 2006
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What’s New for 2006 (cont)
DPI comments to FCC E-rate Rule Notice
Eliminate Form 470 and use local procurement processes
Get reimbursed after the fact
Eliminate Form 486 Reduce max discount to 70% Support SECA and ALA comments You must file a Form 470 for STS services
STS/SCS contract expires June 30, 2007
Document retention
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Technology Plans
Not required for ―basic‖ phone service -(Rule of thumb- if you dial
a 9 or whatever to get out it is probably not basic; also not needed for voice mail.)
Technology plans must be ―developed‖ before the Form 470 is filed. Plans must be approved before service begins. Technology plans must cover the entire funding year for which service is being sought.
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E-Rate Changes/Expiration Revision
Timelines for Information and Technology Plans
Plan Expires Developed prior to 470 Filing ** Plan to DPI by: Plan Dates
Dec 31, 2005 June 30, 2006 Dec 31, 2006 June 30, 2007 Dec 31, 2007
Nov 2004 Nov 2005 Nov 2005 Nov 2006 Nov 2006
Nov 1, 2005 May 1, 2006 Nov 1, 2006 May 1, 2007 Nov 1, 2007
Jan 1, 2006 – June 30, 2009 July 1, 2006 – June 30, 2009 Jan 1, 2007 – June 30, 2010 July 1, 2007 – June 30, 2010 Jan 1, 2008 – June 30, 2011
** E-Rate Note: A change in the E-Rate technology plan requirements occurred in August 2004. Technology plans must be “developed”, but not approved, before Form 470 is submitted.
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Technology Plans
Technology plans approved for the Ed Tech (EETT) program are acceptable for E-rate with one qualification:
The
plan must also include documentation ―that the applicant is aware of and will be able to secure the financial resources it will need to achieve its technology aims, including technology training, software, and other elements outside the coverage of the Commission’s support program.‖
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Technology Plans
Must cover five areas:
1. 2. 3. 4. 5.
Goals / Strategies for using technology Professional development Needs assessment Sufficient budget
Evaluation process
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Technology Plans
Libraries are covered by Library System Plans and approved by DPI Public school plans are approved by DPI
http://www.dpi.state.wi.us/dpi/dltcl/imt/techexp.html
Private schools by WCRIS or TEACH
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CIPA/NCIPA Compliance
Compliance with CIPA required for Internet access and internal connections; not telecommunications. CIPA requirements include filtering and an Internet Safety Plan Certification made on Form 471 and 486
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The Application Process
Technology Plan – What is my plan? Form 470 – What services do I want? Form 471 – What services did I order?
Lunch data – How much of a discount do I get?
Form 486 – When did services start? Form 472 or Form 474 – How do I receive reimbursements or discounts? Retain all documentation for at least five years!!
Online filing/certification available for most forms
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The Application Process
2005 2006 Dec – Feb?
AP waits 28 days, then picks service provider (SP) and posts Form 471 detailing funding requests.
Before 470
Applicant actions
Applicant (AP) requesting more than local/long distance telco service writes Tech Plan.
Oct - Dec
AP files Form 470 to describe services sought and open bid process.
May - Oct
AP tells SLD that services started, certifies Tech Plan & CIPA compliance.
June – Oct 06
AP requests reimbursement on Form 472 or SP requests payment on Form 474.
Form 472
or
Tech Plan
Form 470
SLD posts AP Form 470 to Web issues RNL to AP.
Form 471
SLD issues RAL. PIA reviews 471, contacts AP, then sends funding letter (FCDL).
Form 486
$$$
Form 474
SLD reviews invoice.
SLD actions
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www.sl.universalservice.org
Forms are off the SLD home page.
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E-rate Form 470
470 begins required request/bidding process for services
tariffed or monthly telco or Internet services, if you have no contract
new contractual services
470 must be posted on SLD Website for at least 28 days before you select a provider or sign a contract
Will get a 470 Receipt Notification Letter (RNL) from SLD
Violating 28 day rule is #1 reason for denial of applications
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Main Sections (Blocks) of Form 470
Block 1: Applicant Address and Identifications Block 2: Summary Description of Needs or Services Requested Block 3: Technology Resources Block 4: Recipients of Service Block 5: Certification and Signature
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Tips on Filing Form 470
You can file the 470 now for 2006 services File one Form 470 for all services, or file separate Forms for each service The 470 request for services must be open and fair
Bid document (RFP) helpful, but not required Do not get too close to vendors! 470 and any bid documents must indicate length of contract, including any optional extensions
Can file 470 once for multi-year contracts
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More Tips on Filing Form 470
Select the most cost-effective provider of the service
Does not have to be the least expensive, but cost must be the primary factor
File online, use ―Interview‖ form for easy applications After 28 days, then file Form 471 Early January 2006: Drop dead date for 470 filing
Maybe later in January for 2006?
Form 470 must be certified by close of Form 471 application filing window
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Block 1:
Basic contact info, type of applicant. Assigned 470# after completing Block 1.
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Block 2: Check if tariffed, month-to-month, or contracted service.
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Block 2: Describe your services; separate sections for the 3 eligible services. Added: Basic Maintenance of Internal Connections.
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Block 4:
List recipients of the service your requesting. I.e., number of schools in the district, the area code and their phone exchange (3 digit prefix).
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E-rate Form 471
Provides specific information on services, service providers selected, and contracts and/or agreements Provides discount calculation information Must be filed for each funding year
Applicant certifies compliance with rules, including securing access to resources to make effective use of discounts Must be postmarked on or before the last day of the Form 471 application filing window
2006 Form 471 drop dead date:
?????, 2006 10:59PM CST 31
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Tips on Filing Form 471
Points to Remember:
WAIT
AT LEAST 28 DAYS from the posting of the Form 470 before
selecting
a service provider
executing
signing
a contract or agreement
and submitting Form 471
Use
the new Form 471!!!!
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Tips on Filing Form 471
File
separate Forms 471 for Priority 1 and Priority 2 services
Remove
ineligible costs and document or estimate eligible costs carefully (30% Rule)
online speeds processing and reduces errors correct, and save Receipt Acknowledgement Letter
Filing
Examine,
(RAL)
Paper
forms and instructions: http://www.sl.universalservice.org/form/
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Form 471 Online Interview
You can use the interview form if you meet the following conditions: 1. You are one of the following: • An individual school • A school district • An individual library • A library system.
2. You have National School Lunch Program student counts - or equivalent data using an alternative discount mechanism - for each school (individual schools and school districts) or for all school districts in which your outlets/branches are located (individual libraries and library systems).
You are strongly encouraged to print a copy of the Form 471 Interview Filing Guide to use for reference.
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Block 1:
Basic contact information
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RECORD YOUR SECURTIY CODE!!!!
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Block 2 or 3: Impact of services ordered
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Block 4: Calculate Discount. Adding entities (schools)
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Block 4: Calculate Discount. Adding entities (schools)
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Block 4: Calculate Discount. Adding entities (schools)
NCES Codes: http://nces.ed.gov/globallocator/
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Block 5: One for each funding request. Adding entities (schools)
Spin search tool http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp But VERIFY with service provider!
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Block 5: Type of service. 470 Number
Contract or Month-tomonth
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Block 5: Service start and end dates OR
Contract award and expiration date
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Block 5: Item 21 Attachment
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Block 5: •Enter Amounts. •Add another block 5?
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Block 6: Certifications Have necessary resources
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Block 6: Certifications Have technology plan
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Block 6: Certifications Send Signed Certifications or PIN
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Block 6:
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Application Review
Review of Applications
Review by PIA, which may include:
Competitive bidding process Contracts and agreements Discount calculation Sufficient budget Establishing Form 470 Technology Plan
Bills from previous year
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Funding Commitments
Funding Commitment Decision Letter (FCDL) FCDL reports status of individual funding requests:
Funded Not
Funded
As
Yet Unfunded (Internal Connections)
Canceled
May
receive more than one FCDL
Use
the information on the FCDL to prepare the Form 486
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E-rate Form 486
Form 486
Notification that services have started and the SLD can pay invoices Certifies that Tech Plan (if required) has been approved and covers the entire funding year. Certifies 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)
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Filing Form 486 (cont)
Form 486 Deadline
Form 486 must be postmarked no later than 120 days after the Service Start Date featured on the Form 486
OR
120
days after the date of the Funding Commitment Decision Letter
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Invoices
Invoices — Form 472 or Form 474
BEAR (Billed Entity Applicant Reimbursement) Form 472 filed by the applicant and certified by the service provider after the applicant receives services and pays for the services in full
OR
SPI (Service Provider Invoice) Form 474 filed by service provider after providing services and billing applicant for its non-discount share
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Invoice Deadlines
Invoice (Form 472) Deadline
Invoices must be postmarked no later than
120 days after the last date to receive service OR 120 days after the date of the Form 486 Notification Letter
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Appeals
Decisions of the SLD can be appealed to the SLD or to the FCC
Generally, appeal first to the SLD
Can appeal to the FCC if SLD does not grant the appeal
Can be filed electronically or on paper Must be postmarked within 60 days of the SLD decision See Appeals Procedure in Reference Area for specific guidance Requests for waivers of rules must be filed with the FCC
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Where to Go For Help
On the Web: www.sl.universalservice.org
Client Service Bureau: 888-203-8100
Via e-mail: question@slcfund.org Via fax: 888-276-8736 Fax on demand documents: 800-959-0733
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DPI Help
DPI E-rate Web site:
dpi.wi.gov/pld/erate.html send message to: imailsrv@dpi.listserv.wi.gov leave subject blank in body type: subscribe wierate Steve Sanders
608-266-7112; fax 608-267-1052 stephen.sanders@dpi.state.wi.us
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DPI’s WIERATE email list
DPI Staff:
Bob Bocher
608-266-2127; fax 608-266-2529 robert.bocher@dpi.state.wi.us
The E-rate:
An Overview of Basics for 2006
Questions ?
Bob Bocher 608-266-2127 fax 608-266-2529
robert.bocher@dpi.state.wi.us
Steve Sanders 608-266-7112 fax 608-267-1052
stephen.sanders@dpi.state.wi.us