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									E-rate - Get those dollars back to
        Process overview

                 Brett Hinton
             AZ Dept. of Education
            Mala Muralidharan
AZ State Library Archives and Public Records
      Modified from Train-the-Trainer Workshops

 Video Tutorials at
 General information about E-rate
1. Technology planning
2. Request services (Form 470)
3. Competitive bidding
4. Choose/contract for services (Form 471)
5. Application review & funding commitments
6. Start services (Form 486)
7. Invoice USAC (Form 472 or Form 474)
                    General information
 Federal Communications Commission
  (FCC), an independent U.S. government
  agency, oversees the E-rate program
 Universal Service Administrative Company
  (USAC), a not-for-profit, administers E-rate
  along with three other programs
 Schools and Libraries Division (SLD) is the
  part of USAC with responsibility for E-rate
                     General information
 FCC sets rules and policies through orders
  – Rules are compiled in the Code of Federal
    Regulations (CFR)
  – Policies are defined in the text of orders
 USAC/SLD sets procedures for specific
  actions, such as how to process
  – USAC sends its procedures to the FCC for
    approval each year
             E-rate? What is it?
 E-rate Program provides reimbursements to
  eligible schools and libraries for
     1. Telecommunications Services
     2. Internet Access,
     3. Internal Connections
     4. Basic Maintenance

 Applicants must apply each year
 Reimbursements are based on the poverty
  level and the maximum one can get back is
  90% of your billed amount
 Funding cap each year is $2.25 billion
                                Internal connections
                                IC Maintenance
   $2.25 Billion

Submitted each Quarter

 Form 470: File from April before the Window to
  28 days before the Window closes
 Form 471: Must be filed during the Window,
  generally mid-November to early February before
  the start of the funding year
 Funding waves: Groups of funding decisions
  issued after USAC review – waves generally start
  in April before the start of the funding year
 Invoices: Can file after services are received for
  the funding year.
                   General information
 Who can apply?
  – Schools and school districts
  – Libraries and library systems
  – Consortia – groups of eligible entities
    that band together to aggregate demand
    and negotiate lower prices

                          General information
 How large are the discounts on eligible
  products and services?
  – Discounts: 20% to 90% of eligible costs
  – Discount for a school or library depends on:
     • Percentage of eligibility of students for National
       School Lunch Program (NSLP) in:
        – (for a school) the school
        – (for a library) the school district in which the
          library is located
     • Urban or rural location of the school or library
                     General information
What services are eligible?
 Priority 1 (funded first)
  – Telecommunications Services
  – Internet Access
 Priority 2 (funded beginning with neediest
  applicants first)
  – Internal Connections
  – Basic Maintenance of Internal Connections
                   General information
 How do I file a program form?
  – In general, you have three options:
     • File online, certify online
     • File online, certify on paper
     • File and certify on paper
  – USAC encourages you to file online
     • Online filing speeds processing and
       reduces errors
     What is sent ……and received
       Applicant to USAC   ->    Letters received from USAC

            Technology plan created but not sent

Form 470
                            Receipt Notification Letter (RNL)

Form 471                   Receipt Acknowledgment Letter
                            Funding Commitment Decision
                             Letter (FCDL)

Form 486
                            Form 486 Notification Letter (486NL)

                            BEAR Notification Letter — Form
Form 472                    472 only

                   1. Technology planning

 You must write a technology plan that contains
  the following elements:
  1. Goals and strategies for using technology to improve
     education or library services
  2. Staff training/ Professional Development
  3. Needs assessment
  4. Budget
  5. Evaluation plan
 Note: if you are only requesting basic telephone
  service, a technology plan is not required
                     Necessary Resources
 Does the applicant have the resources needed to
  provide the service
   – Are there end user computers?
      • Must have reasonable plans to fully utilize all
        internal connections for which you are
        requesting discounts
   – Do you have software to run on the computers?
   – Staff trained on how to use the technology?
   – Electrical capacity?
   – Can you maintain the eligible and ineligible
 This is an important part of the Tech plan
  and the purpose is to show USAC that the
  applicant can fund their share
 Operating budget (or draft) has dates that
  cover the funding year (July – June)
 Budget documentation should have clear
  expense line items not all bundled together
 If budgets are not passed at that time, can
  provide letter for reasonable expectation
  that funds will be secured by 7/1
                 Non-Discounted portion
 Obligation to Pay Non-discount Share
   • Applicants are required to pay their share of the cost
     (the ―non-discount‖ portion or share) — this share
     cannot be donated, forgiven or ignored.
   • Service providers cannot waive or credit the
     applicant’s share.
   • Service provider must bill the applicant for non-
     discount share of services. If applicant can’t show
     proof of payment during invoice review; invoice may
     be denied.
   • Deferred payment plans that allow the applicant to
     pay after USAC has paid will jeopardize a funding
     request.                                                 16
              Free Goods and Services
• Applicants and service providers are prohibited
  from using E-rate to subsidize the procurement
  of ineligible or unrequested products and
• E-rate cannot be used to get free stuff or kick-
  backs. The value of ineligible products that are
  needed to run the service have to be backed out
  in your vendor selection process.
• Cost of eligible goods and services cannot be
  inflated to cover the―free‖ ineligible stuff

           Technology plan approval

– Technology Plan Approver (TPA) – the
  agency certified by USAC that approves
  your technology plan
– It has to be written (drafted) before the
  filing of the Form 470, finalized and
  approved before the start of services.
– Can be multi-year but major changes
  have to be re-approved
                   Tech Plan Validity
   Tech plan
    drafted                            No longer valid for E-Rate

    Tech plan
   for approval

    Approved       Year 1              Year 2            Year 3

Major change
                   Must submit another plan
years 1 & 2

                  Approved              Year 1           Year 2
Technology Planning: Do’s and Don’ts
 draft your technology plan before Form 470.
 verify that it contains all five required elements.
 make sure your technology plan covers at least
  12 months
 make sure that your technology plan approver is
  certified by USAC.
 verify that plan is approved before services begin
  and before your Form 486 is filed.
 PRINT A COPY of your Tech Plan for your
 PRINT A COPY of your approval for your records.

DO NOT ask the service provider direct advice on
 technology planning.

            2. Request services (470)

 You post a Form 470 to:
  – Open a competitive bidding process
  – Notify potential bidders (service
    providers) of the types and quantities of
    services that you need
  – Define the scope of your needs (e.g., a
    school building, a library system, a state
                 2. Request services (470)
 Acronyms and terms
  – Billed Entity Number (BEN) – an identification number
    assigned by USAC to each school or library building
  – Personal Identification Number (PIN) – a code assigned by
    USAC to applicants for use in certifying program forms online
      • USAC issues a PIN to every new authorized person filing
        a paper Form 470, 471, or 486
  – Request for Proposals (RFP) – a bidding document (not
    required by E-rate) that provides detailed information about
    your services, locations, bid submission requirements, etc.
  – Allowable vendor selection/contract date (ACD) – the date 28
    days after the Form 470 is posted to the USAC website

                3. Competitive bidding

 When you open a competitive bidding
  process for your services:
  – Potential bidders have the information
    from your Form 470 and RFP and can
    respond to your requests
  – You must ensure that the competitive
    bidding process is open and fair
  – You must be prepared to evaluate bids
                       3. Competitive bidding
 After you close the competitive bidding process for
  your services (on or after the ACD):
   – You can evaluate the bids received
   – You can choose your service provider(s)
   – You can sign a contract
   – You can post a Form 471

  Price as the primary factor – In evaluating bids, the price
    of the eligible products and services must be the most
    heavily-weighted factor in your evaluation of bids
                     Calculate the discounts
Reimbursements are based on
Discounts calculated using
• Percentage of students           % Eligible Students   Urban   Rural
    eligible for National School   Less than 1%           20%    25%
    Lunch Program (NSLP)
• Urban or rural status of         1% - 19%               40%    50%
    county in which school or
    library is located (see
                                   20% - 34%              50%    60%
    USAC web site)                 35% - 49%              60%    70%
    cants/step05/urban-            50% - 74%              80%    80%
    rural/default.aspx             75% - 100%             90%    90%
These two pieces of information
are carried into the Discount
                 4. Choose services (471)

 You post a Form 471 to:
  – Report information on the service providers and
    services you have chosen
  – Provide a list of the schools and libraries that will
    receive services
  – Include discount calculation information including
    student NSLP counts
  – Certify your compliance with program rules

                    4. Choose services (471)
 Acronyms and terms
   – Funding Request Number (FRN) – the identification number
     assigned to a Form 471 Block 5 funding request
   – Service Provider Identification Number (SPIN) – the
     identification number assigned by USAC to a service provider
       • Service providers may have more than one SPIN in order
         to identify separate business units, different states in
         which they operate, etc.
   – Non-instructional facility (NIF) – a school building with no
     classrooms or a library building with no public areas
       • NIFs are eligible for Priority 1 services
       • NIFs are eligible for Priority 2 services only if necessary to
         provide effective transport of information to classrooms or
         public areas of libraries

              4. Choose services (471)
– Item 21 Attachment (Item 21) – the description of
  services associated with a funding request (Item
  21 on Form 471)
    • Item 21 attachments can be submitted online or
      on paper
    • USAC encourages online filing, especially for
      simpler applications
– Form 471 Receipt Acknowledgment Letter (RAL) –
  a letter issued by USAC to the applicant and the
  service provider that summarizes the information
  provided in the Form 471
    • Many of the entries on the form can be
      corrected after submission by using the RAL    29
                              5. Application review
 USAC reviews your Form(s) 471 to:
   – Check the eligibility of the schools and libraries and their
     discount levels
   – Verify that the services you requested are eligible for discounts
   – Give you an opportunity to make allowable corrections to your
   – In some cases, ask for additional verification of your compliance
     with program rules
   – Program Integrity Assurance (PIA) – the USAC group that
     reviews and makes funding decisions on program applications
   – Funding Commitment Decision Letter (FCDL) – a letter issued by
     USAC to the applicant and the service provider that contains
     commitment decisions on funding requests

                          6. Start services (486)

 You post a Form 486 to:
   – Notify USAC that services have started and invoices for those
     services can be processed and paid
   – Provide the name of the TPA that approved your technology plan
   – Report your status of compliance with CIPA
 Acronyms and terms
   – Form 486 Notification Letter – a letter issued by USAC to the
     applicant and service provider after a Form 486 has been
   – Children’s Internet Protection Act (CIPA) – a law with specific
     requirements on Internet safety policies and filtering
   – TPA Tech plan approver

              7. Invoicing USAC (472/474)

 Applicants have a choice of two invoicing methods to receive
  discounts on eligible services:
   – Billed Entity Applicant Reimbursement (BEAR) Form 472
   – Service Provider Invoice (SPI) Form 474
 BEAR Form is filed by the applicant and approved by the service
  provider after the applicant has paid for the services in full
 SPI Form is filed by the service provider after the applicant has been
  billed for the non-discount portion of the cost of eligible services
 Acronyms and terms
   – BEAR Notification Letter – a letter issued by USAC to the
       applicant and service provider after a BEAR has been processed
   – Quarterly Disbursement Report – a report issued to the applicant
       detailing all invoicing activity (BEARs and SPIs) during the
       previous quarter

Eligible Services List
             Eligibility - Schools
• Must meet the statutory definition of elementary or
  secondary school found in the No Child Left Behind Act
  of 2001.
• Must be a non-profit institutional day or residential
  school, including a public charter school, that provides
  elementary or secondary education, as determined
  under state law eg Pre-kindergarten( Sp Ed. Only),
  Adult Education, Juvenile Justice students facilities
  may be eligible.
• Must not have an endowment exceeding $50 million.
• USAC requests updated eligibility information from
  state departments of education every two years.

               Eligibility - Libraries

• Must meet the statutory definition of library or library
  consortium in the Library Services and Technology Act
  (LSTA) of 1996.
• Must be eligible for assistance from a state library
  administrative agency under LSTA.
• If they are a joint use facility (school + public library)
  each can apply separately for their portions provided
  budgets are completely separate.
• Must not operate as for-profit business.

                  Eligibility - Consortia
 Eligible schools and/or libraries may form consortia with
       • Other eligible schools and/or libraries
       • Certain health care providers
       • Public sector (governmental) entities
 Helps bring the prices down
 May even help bring higher band-width or better service
 May bring more competition to your area
 Only eligible entities can receive discounts
 Be careful about consortial applications –
   – not easy to administer
   – there are consequences and responsibilities.
          Eligible Services - Priority 1
Priority 1 – funded first
• Telecommunications Services
  – Basic telephone service — wireline or wireless phone
    service (local, cellular/PCS, and/or long distance);
    Voice over IP- PBX and Centrex; Radio loop
 Internet Access
  – Basic conduit access to the Internet including but not
    limited to: Broadband over Power Lines (BPL), Cable
    Modem, Digital Subscriber Line (DSL), Satellite
  – T-x, DS-x, OC-x . E-mail service, and web hosting

            Eligible Services – Priority 2
• Priority 2
    – Internal Connections (switches, hubs, routers, wiring,
    – Basic Maintenance on Internal Connections
   NOTE: End user equipment - such as
   computers, monitors, or phone sets - is NOT
• Priority 1 funded first, then Priority 2 begins with neediest
  applicants (90% first, then 89%, 88%, etc.).
• Internal Connections funded in only two out of five
  funding years.

Special Eligibility Conditions
Internal Connections Example 1

Internal Connections Example 2

Classroom Internal Connections

Classroom Internal Connections Ex. 2

            On-Premise Equipment 1
 This leased router may be eligible for P1 funding if all
  conditions are met.
 Single demarcation – If the router is removed, the
  LAN would continue to function.

            On-Premise Equipment 2
 This leased router is NOT eligible for P1 funding.
 Multiple demarcations – If the router is removed, the LAN
  would cease to function which violates program rules for
  Priority One eligibility. Router may be eligible in IC.

    Internal Connections Maintenance
 Ensures the necessary and continued operation of eligible
internal connection components at eligible locations.
       Ex: Repair and upkeep of eligible hardware, wire and
       cable maintenance, and configuration changes.

 Basic technical support of eligible hardware is Eligible but
end-user support such as a student calling a help desk for
technical assistance is NOT Eligible.

 BMIC is a Recurring service - Delivery must be within July 1st
– June 30th

 BMIC is exempt from the Two-in-Five rule
 Must be for Educational Purpose only
   – 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.

                    Non-instructional Facilities
 Non-instructional facilities are school buildings with (few
  or) no classrooms or library buildings with no public areas
Non-instructional Facilities
 Eligible for Priority 1 services
   – Telecommunications
   – Internet Access
 Eligible for Priority 2 services only if the services are essential for the
  effective transport of data to classrooms or public areas of a library

   School examples:                    Library examples:
      – Administration buildings           – Administration buildings
      – Bus barns                          – Bookmobile garages
      – Athletic stadiums                  – Technology centers

        Non-instructional Facilities (NIFs)
NIFs can receive Priority 1 services. Examples are
          Administrative buildings
          School bus barns and                  Administrative buildings
                                                 Bookmobile garages
          Cafeteria offices
          Facilities associated with            Interlibrary loan facilities
           athletic activities                   Library technology centers
          Teachers accompanying
           students on a field trip

NIFs – Priority 2
    NOT eligible unless it is essential for the effective transport of
    information to an instructional building of a school or to the patrons of a

          Eligibility- Service Provider
What should you know about your Service Providers
 Must be an authorized Telecom Carrier and
  supply on a common carriage basis.
 Must file form 498 (Service Provider Information
 Must have a Service Provider Identification
  Number (SPIN)
 Must file Form 473, Service Provider Annual
  Certification (SPAC) Form
 Must contribute to the Universal Service Fund.

Website and Links
Eligible Services List

                                               What are we?
What are the following services? P1, P2, or Not Eligible

Telephone Handsets
                                     Not Eligible

Internet Access

                                     P1 / P2


                                     P1 / P2



 Basic discount calculations
 Alternative discount mechanisms
 Non-instructional facilities
 Snapshots
 New construction

                      Basic Calculations
 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
                       Discount Matrix
Percent of Eligible   Urban   Rural
Less than 1%          20%      25%
1% - 19%              40%      50%
20% - 34%             50%      60%
35% - 49%             60%      70%
50% -74%              80%      80%
75% -100%             90%      90%
                                     Basic Calculations
    Individual school calculation:
       – Calculate the percentage of students eligible for NSLP in that
       – Use the urban or rural status of the county or census tract in
         which the school is located
    School district calculation:
School– E-Ratedistrict E-rate discount for each individualDiscountthe x C)
                Discount# of Students Weighted school in (B
        Calculate the
A                    70%              2000
      – Calculate the weighted average discount                      1400
B         • For each50% multiply the E-rate discount by the total 350
                      school,           700
            student population of the school (the weighted product)
C                    25%              1500
          • Add all weighted products and divide by the total number of
        Totals                        4200
            students in the school district                          2125
        District Average (D/C)                                        51%
                                  Basic Calculations
 Library outlet/branch calculation:
    – Calculate the total 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
 Library system calculation:
    – Calculate the E-rate discount
Library E-Rate Discount for each library outlet/branch in the
      library system
A – Calculate the simple average discount                    70%
B                                                            50%
        • Add together the discounts for the outlet/branches and divide
C         by the total number of outlets/branches            25%
 Consortium calculation:
    – Calculate the E-rate discount for each individual member of the
   Library District or Consortium Average (B/3)
      consortium                                                     48%
    – Calculate the simple average of all the member discounts        59
                        Alternative Mechanisms
 Head Start (NSLP)
   – Head Start is a federal program that provides comprehensive
     developmental services for low-income children ages three to five
       • Head Start students meet free lunch guidelines under NSLP,
         so Head Start entities automatically qualify for 90% discount
       • Children under age three are never considered eligible and
         must be cost-allocated out
       • Home based Head Start is not eligible
 Direct certification (NSLP)
   – State social services agency works with local educational
     authority to directly certify students for NSLP based on
     household participation in other poverty-based programs
       • USAC will accept the student counts determined using this
         method if the school can demonstrate participation in direct
         certification                                                60
                        Alternative Mechanisms
 Other alternative discount mechanisms measure a level of poverty in
  a household equivalent to that required by NSLP
   – Income Eligibility Guidelines (IEGs) are published each year by
     the U.S. Department of Agriculture (USDA)
   – Students from households whose income is at or below 185% of
     the federal poverty guideline are eligible for the NSLP
 Examples
   –   Medicaid, Food stamps
   –   Supplementary Security Income (SSI)
   –   Section 8 (federal public housing assistance)
   –   Low Income Home Energy Assistance Program (LIHEAP)
 Other programs can be used as mechanisms ONLY IF their
  requirements are at least as stringent as IEGs
   – Examples of programs that do not automatically qualify
       • Temporary Aid to Needy Families (TANF)
       • Title 1 eligibility, Scholarship programs                61
             Alternative Mechanisms- Survey
 Applicants can conduct surveys to establish eligibility (see sample
  survey on USAC website)
   – Survey requirements:
        • Must be sent to all families whose children attend the school
        • Must contain names of family and students
        • Must contain size of family
        • Must contain income level of family
        • Data must not be more than two years old
 Surveys can request information on household income level or
  participation in eligible alternative mechanisms or both
 With one exception, applicants must be able to provide data on an
  individual student basis
   – Exception: if a school sends a survey to the households of all of its
     students and at least 50% of the surveys are returned, the school
     may project a percentage of eligibility based on the percentage of
     eligibility in the returned surveys
 Retain copies of all surveys for your records                      62
                                       Other Sources
 Applicants can match siblings or collect data from other
  existing sources
   – Example: if a elementary school student from a
     household participates in NSLP, an older sibling in that
     household can be counted as eligible
 Multiple entities
   Discount is based on the total enrollment for the entity
     and NSLP data and each location receives the same
   Obtain an entity number for each facility if the facility has a
     different address or a public right-of-way crosses the
   Maintain adequate documentation                            63
              Non-instructional Facilities

Discounts for NIFs without classrooms
 In general, the discount for a NIF on the same
  campus as a school or library is the same as the
  discount of the school or library

 A NIF shared by more than one school in a
  school district or library in a library system is
  eligible for the shared discount for that school
  district or library system

Non-instructional Facilities- snapshot

 Separate NIFs (not a part of the campus) that are
  used by a class should use the snapshot method
   – Choose a specific day
   – Determine the percentage of students eligible
     for NSLP for the student population that
     attends class on that day
   – Use that percentage and the urban/rural status
     to find the discount in the Discount Matrix
   Save your documentation
             New Schools and Libraries
 Is it really a new school or library?
  – Does the State consider this a replacement
    facility for the same school or library?
     • If yes, use current discount information
  – Does the State consider this a new school or
     • If yes, the may use New School Construction

                                 New Constructions

 If a school is under construction –
    – If the student population is known, use the percentage of NSLP
        eligibility of those students to calculate the discount
    – If not, do a pre-enrolment survey
 If a library is under construction –
    – Use the discount for the school district in which the library
        building is going to be located
 Charter and Private Schools
    If population is unknown use 20% discount . You cannot use
        school district average
    If population is known - Must be able to provide supporting
        documentation. Use that data to calculate discount rate


   Form 470 &
Competitive Bidding

            Competitive Bidding / 470
• Filing Form 470 opens a competitive bidding
  process, which is fair and open.
• The Goal is
    – to have a healthy competition
    – to promote better service and lower prices
• Avoid conflicts of interest
   – Independent consultant Service
   – Applicant  Service Provider

         Competitive Bidding / 470

• Fair and open process
   – All bidders treated the same
   – No advance knowledge of RFP
   – No secrets in the process
   – All bidders know what is required of them
     including the selection criteria.
• Follow all rules – FCC and state/local

               Pre-bidding Discussions
 Applicants may:
  – Discuss their product offering with SPs
  – Learn about new technologies from SPs
 Applicants may NOT accept/use the
  following from service providers:
  – Vendor-specific language for RFP or the 470
  – Template RFPs or Forms 470
  – Assistance with tech plan
  – Assistance with RFP
                       Vendor Involvement
 Service providers cannot:
  – Determine the types of service the applicant
    will seek on a Form 470
  – Assist applicants with the filling out of the FCC
    Form 470 which requires an applicant’s
  – Influence or run the competitive bidding
    process for the applicant
  – Be privy to information about the bid not
    shared with other potential bidders
              Competitive Bidding / 470

 Request for Proposal (RFP)
   – Not required under FCC rules, but a good practice
   – Must comply with local and state procurement
     laws (check for limits on sealed bid requirements
   – Describes your project scope, location, other
     requirements in detail
   – Even if you have an RFP, you must describe the
     services you desire on your Form 470.

             Competitive Bidding / 470
Form 470
    Must indicate a multi-year contract or contract with
     extensions if appropriate.

    Must list services sought in the correct category of
     service. If you are not sure put it in both categories
     (Telecom and Internet). You can decide when
     doing Form 471

    Must indicate if it is for a single entity or multiple
     entities and if there are likely to be changes in the
     middle of the contract period

              The 28 day rule
•   WAIT 28 DAYS after your Form 470 is posted and
    your RFP is issued before you evaluate the bids
•   No hard deadline for filing Form 470 but is based
    on Form 471 window closing

•    RFP handed out at walk through
    -28 day clock starts after last of the RFP issued

•   Clock for 28 days restarts when
       • If you issue a new RFP, then your 28 days
       starts again (do not have to post a new 470)
       • Changed services sought
       • Make other cardinal changes to RFP
       • Post new Form 470                              76
             Qualifying factors
• Qualification Factors
  – Can require that potential bidders meet minimum
    number of qualification factors
• Disqualification Factors
  – Can require that potential bidders that meet any
    disqualification factors are not considered
• Ensure that all potential bidders have adequate
  notice of these items
• If no bids received after 28 days, you may
  contact vendors to seek bids

           Sham bid process
 ―I want to stay with my incumbent‖
 Avoid appearances of a ―done deal‖
 Must respond to all legitimate inquiries.
  Need not respond to spams
 Cost to transfer to another provider alone
  is not by itself a good enough reason to
  stay with incumbent, but can be one of the
  bid evaluation criteria
           Competitive Bidding
If you wait until the last date to file a Form 470, the
following must all occur on the last day of the window for
Form 471:
     Bid Evaluation
     Selecting a service provider
     Signing and dating a contract
     Submitting Form 471 online or mailing the manual paper
     Certifying, signing and dating
Retain your documentation
  Retain, retain, lessen your pain
      Competitive Bidding / 470 – Tips
• Retain worksheets, bid evaluation criteria, winning AND
  LOSING bids
• Prepare a memo to file if you received only one bid or no
• File online to reduces errors and speed processing
• Read the contract’s fine print

Personal Identification Numbers (PINs)
 • Will be automatically issued to any new authorized persons
   filing Forms 470, 471 and 486 after at least one wet signature.
 • Do not use the pin that was issued to a former staff (Pins are
   electronic signature of the individual)

                 Competitive Bidding / 470

 Form 470 Receipt Notification Letter (RNL)
   – Cover page of important reminders
   – Notifies applicant that Form 470 has been posted to
     the USAC web site
   – Contains Allowable Vendor Selection / Contract
     Date (ACD)
   – Use the calendar tool on the website rather than
     calculating it yourself.
   – Remember if you posted your RFP after posting
     form 470 – you will have to wait 28 after posting the
     RFP even if you have a ACD on your RLN.


Video Tutorials at

  Vendor Selection,
Contracts, & Form 471

            Selecting a vendor
• Applicants must choose the most cost-
  effective solution to their Form 470 or RFP.
• Price has to be the primary factor – the one
  with the most weightage (next slide)
• See Rubric on how to do the bid
• Bid evaluation process should be carefully
  documented and filed - winning and losing
• If only one bid or no bids are received – make
  a memo for your files
                         Vendor Selection
 Applicants must retain all vendor selection
  – This includes winning and losing bids
 Price of the eligible goods and services
  must be the primary factor in all rounds
 Applicants determine remaining vendor
  selection criteria and relative weighting
 USAC sample evaluation matrix available

• Solution must be cost-effective
     • Routers priced at two or three times greater than
       the prices available from commercial vendors
       would not be cost-effective, in the absence of an
       explanation of extenuating circumstances.
     • Receiving only one bid does not automatically
       make it cost-effective
     • Service Providers may work with the applicant to
       help them understand the technical needs for
       this expensive solution.

                        Selecting Factors
 Selecting the winning bidder
  – Price of the ELIGIBLE goods and services
    must be the primary factor.
  – Other factors, including other price factors,
    can be considered as well but they cannot be
    weighted equally or higher than cost of the
    eligible goods and services
  – See Step 4: Construct An Evaluation for
    weighting samples

USAC bid evaluation template

 Once you have selected your vendor applicants and
  service providers must sign contracts for services that
  are not provided under tariff or month-to-month
 Contracts have to be signed by the applicant before
  filing form 471
 It is a good practice for the applicants to get the
  vendors to sign the contracts too, to make it legally
 Contracts can cover more than one year or contain
  extensions, but applicant must indicate these options
  in the Form 470.
 TIP: You may want to add some contract language
  that allows the contract to be extended into another
  program year in the event you are awarded late in the
  funding cycle and an opt out clause in case of funding
  denial                                                89
                   Funding Requests / 471
Form 471
    • Provides specific information on services, service
      providers selected, and contracts
    • Provides discount calculation information
    • Details itemized services – item 21 attachments
    • Must be filed for each funding year even if you do not do
      a Form 470
    • Contains certifications of compliance
    • Has a hard deadline date.
    • You can do multiple form 471s (Block 5s ) by breaking it
    • File Priority 1 and Priority 2 requests separately. Review
      of Priority 2 requests may hold up Priority 1
                  Funding Requests / 471

 Form 471 Deadline
   • Must be filed online or postmarked on or before the
     close of the Form 471 application filing window.
     (midnight Eastern on the date of the deadline).
   • Be prepared for a logjam and software timeouts
     closer to deadline.
   • Good practice to file Certifications for associated
     Forms online or postmarked by deadline.
   • Certifications and Item 21 attachments are
     accepted even after the close of the window.

                Funding Requests / 471

• Remove ineligible costs from funding requests
   • Document ineligible costs carefully and cost
     allocate it out
   • 30% rule – if 30% or more of the dollar value of the
     request is for ineligible products, services, or
     entities you will get called during PIA review and
     asked to remove it.
• Work with your service provider
       • to help you unbundle the services and products
       • to break out eligible and ineligible costs
       • to create your Item 21 attachment(s)

              Funding Requests / 471

 Enter recurring and non-recurring costs
  carefully in the cost summary of each
  Funding Request
   • Recurring costs ALWAYS must be received by
     June 30 of the Funding Year.
   • Non-recurring costs must be received by
     September 30 following the Funding Year, and
     this deadline can be extended under certain

           Funding Requests / 471
• Form 471 Receipt Acknowledgment Letter
   – Cover page of important reminders
   – Provides confirmation of certain information
     entered from Form 471
      • Data entry errors may be corrected within
        three weeks by using the RAL (including
        Block 4 worksheets)
      • Applicants can request funding changes


Video Tutorials at

PIA Review

         Application Review - PIA
All Forms 471 are reviewed by Program Integrity
Assurance for compliance with program rules
concerning areas such as:
• Competitive bidding process, contracts,
  discount calculation, sufficient budget,
  establishing form 470, Technology plan, CIPA
• Some errors can be corrected during PIA
  review but not all.
• All certifications and attachments (esp item 21)
  will be scrutinized.

               PIA Reviews
• Initial & Final Review
   • Applications always start in Initial Review.
   Reviewer contacts the applicant with
   questions, gives them 15 days to answer.
   • Final Reviewer reviews the Initial
   Reviewer’s comments.
• Quality Assurance (QA) Review
   • Some Form 471 applications are selected
   for QA review
   • QA has Initial and Final review levels as
                        Clerical Corrections
 Bishop Perry Order allows applicants to make
  corrections to Forms 470 & 471 - known as
  ministerial & clerical corrections.
 Applicants have additional time to certify Forms 470
  & 471, make corrections that do not require the
  Form 470 to be reposted or the Form 471 to be re-
  filed, and do not violate FCC regulations and/or
  program rules.
 USAC, with FCC guidance, developed a list of
  correctable items. List of Correctable M & C
 Subsequent FCC Orders issued identified more
  corrections allowable during PIA review.
                         Clerical Corrections
 Entered the incorrect amount (i.e., data entered
  $100 instead of $1,000)
 Omitted an entity from the Block 4
 Provided the incorrect Form 470 number on the
  Form 471
 Selected the wrong category of service
 Submitted an unsigned contract to PIA
 Omitted an FRN
 Did not include all of the required elements in the
  written tech plan

                  PIA Review : Tips

 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.
    Ask for everything in writing, respond in writing
 Check the 471 Application Status Tool on the web.
                    Deadlines, Deadlines
15 Day Rule
  – PIA corrections MUST be submitted 20
   calendar days (5 days for mail receipt + 15
   days) from the date of USAC’s letter
    • Receipt Notification Letter (RNL) – 470
    • Receipt Acknowledgment Letter (RAL) – 471
  – Mail, email or fax corrections to USAC
  – RAL doesn’t contain Block 4 information, so
    include the corrected Block 4 worksheet with
    your RAL corrections
  – 7 day reminder                             102
                     RNL/RAL Corrections
 Corrections submitted after the deadline in
  the letter:
   – Requests to increase funding will not be
   – PIA will work with applicants to make
     clerical error corrections until the FCDL is
     • PIA will request documentation to support the
       correction, such as contract, invoice, bill, etc.
                PIA Identified Changes
• Errors may be detected during PIA review
• PIA may contact you and allow corrections
  if they find certain discrepancies:
  – Item 21 doesn’t match Block 5
  – Discount for single entity doesn’t match
    discount reported on different application
  – Item 21 includes entities missing from your
    Block 4
  – Tech Plan is missing one or more required

      Funding Commitments
After PIA review is successfully completed you get a
   Funding Commitment Decision Letter (FCDL)
    – Cover page has important date-reminders
    – Reports status of individual funding requests:
       • Funded
       • Not funded
       • As yet unfunded (Priority 2 requests)
    – May receive more than one FCDL

 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.


Start of services Form 486
 Invoicing Form 472/474
       Starting Services / 486
• Notifies USAC that services have started and
  invoices can be paid
• Certifies that Tech Plan (if required) meets program
• CIPA compliance – file proof of
      Internet safety policy
      Public notice or meeting
      Technology protection measure (filter)
       CIPA does not apply to Telecom Services
       Local and Long distance.

• But if you apply for cell phones and blackberries or
 any data transmission services – you must be CIPA

         Starting Services / 486
• Form 486 Deadline
      • Form 486 must be filed no later than
         • 120 days after the Service Start Date OR
         • 120 days after the date of the FCDL
         whichever is later.
If you file late your funding commitment will be adjusted
    to reflect the new start date corresponding to 120
    days before the filing date.

Form 486 Notification Letter (486NL)
   – USAC will accept invoices once the Form 486 is
    Invoicing BEAR or SPI? Why?
Why would you choose one or the other?

• Form 472, Billed Entity Applicant Reimbursement
  (BEAR) Form
    – Applicant pays for services in full and then requests
      reimbursement from USAC
    – The form is submitted through the SP and they
      have to certify the invoices
• Form 474, Service Provider Invoice (SPI) Form
    – Service provider discounts customer (applicant)
      bills and then requests discount amount from
    – The applicant pays only the non-discounted share
How do reimbursements or BEARs
How do discounted bills or SPIs work?
                        Review of Invoices
• Service providers and applicant must review
  BEAR/SPI to ensure:
  – Only eligible services are being billed
  – Only services that were approved on the
    application are being billed
  – Services were delivered consistent with the FCDL
    and any agreements
  – Any service interruptions are accounted for

Follow through and ensure that Service
  providers sign off all months and all invoices
            Invoicing / 472 or 474: TIPS
Form 472 (BEAR Form)
     • DO NOT wait till the last day to file. Remember that the Service
        provider has to sign off on these.
     • DO keep checking that your service provider has signed off on
        your 472 online
     • DO check your calculations.
     • Do make sure you have paid your non-discount share.
Invoicing deadlines
     • Form 472 or 474 must be filed online or postmarked no later than
         • 120 days after the last date to receive service
         • Can be monitored online to ensure that vendors have certified.
         • File for invoice extension if needed
You will receive a BEAR Notification Letter after your BEAR filing read it
   to see if you have submitted successfully

Program Compliance

                                   Know Your Role
 Applicants
   – Write tech plan, file Form 470 and write RFP, evaluate bids,
     select provider, document the process, file Form 471, get
     tech plan approved, file Form 486, select invoice method, file
 Service Providers
   – Respond to 470/RFPs, assist with preparing Item 21
     attachments, provide technical answers on questions
     regarding specific goods and services requested, but NOT on
     competitive bidding; file SPIs and/or approve BEARs; file
 Consultants
   – Follow the role of their client – either applicant or service
 Applicants certify that:
   – Have secured access to necessary resources
   – Have complied with all FCC, state and local competitive
     bidding and procurement regs
   – Non-discount portion of the costs for eligible services will
     not be paid by the service provider
   – false statements on this form can be punished by fine or
 Failure to comply with program rules could result in
  civil or criminal prosecution
   – Persons who have been convicted of violations in the
     program are subject to suspension and debarment from
     the program

Selective Review and Heightened Scrutiny

These reviews will take additional time and will hold up
  commitments until they are completed
Selective Review Information Request (SRIR) contains
  some of the questions that may be ask
 May include review of:
   – Budget
   – Necessary Resources
   – Competitive Bidding and Contracts
   – Pattern Analysis
   – Targeted questions based on potential violations
                        Document Retention
• Document retention timeframes:
  – 5 years from last date to receive service
     • FY 2010 – this is at least June 30, 2016
  – Any document from a prior year that supports
    current year must be kept until 5 years from last
    date to receive service as well
  – Eg. Contract from 2004, used to support FY 2010
    FRNs, must be kept until at least June 30, 2016
  – Applicants must retain all pre-commitment
    documents that show compliance with all FCC

         Document Retention and Audits

 Audits are done by an external agency
   – to ensure compliance to rules,
   – To ensure that there is no waste, fraud and abuse
   – To ensure that there are no improper payments made.
 It is easier to keep track as you go along than to scramble
  when auditors are knocking on your door.
 Appearances are important
 If you are listed as the contact - you need to keep all
  documents – don’t expect the accounts to keep
  documents or archives to trace them for you.
 Applicants have been asked to pay back what they have
  received, sometime years later.
                      Retain, retain, retain
 Retain documents to show your compliance:
  – Letters of Agency and any agreements with all
  – Technology Plan (both draft and final approved
    version) and TPA Plan Approval letter
  – RFP, including evidence of publication date and
    any solicitation you did
  – Any and all bids (winning and losing)
  – Email to yourself if you get no or one bid

                     Retain, retain, retain
 Applicants retain documents to show compliance:
  – 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
  – Also, see further list on USAC website under
    document retention

 USAC decisions can be appealed to USAC or to the
   • Generally, appeal first to USAC.
   • Can appeal to the FCC if USAC does not grant
     the appeal.
 Can be filed electronically or on paper.
 Must be filed electronically or postmarked within 60
  days of the USAC decision.
 Requests for waivers of rules must be filed with the

       SL News Briefs
   Emailed each week
   Subscribe from website
   Cover topics of current interest
   Archive of past issues
   Search by topic or date
 One-page high-level guidance documents on major program
 Contain links to guidance documents
 Available on website and during site visits
 Video Tutorials and

Viewing Options
USAC Tutorials at – For slower connections; can be viewed by most
USAC Blog – Higher quality; requires latest Flash player.
USAC Tutorials at MotionBox – Higher quality. Click "View All" to see all available
tutorials. You should have latest version of your browser, and select "SD -
Standard Definition" if not already selected.
Video Tutorials:
Presentation slides:
         Scan topics alphabetically

            E-rate resources for AZ
 Arizona Department of Education (ADE)
 Arizona State Library Archives and Public Records
 Arizona State Procurement Office (AZSPO)

 E-rate Central
 • E-rate resource center

                 USAC Resources
• USAC Homepage

• USAC Reference Page

• USAC tools

• USAC Outreach and Training

• Use the ―Submit a Question‖ link on the web site

• Fax toll-free at 1-888-276-8736
• Telephone toll-free at 1-888-203-8100
Always ask in writing and insist on a written response.
  AZ Contact Information

 Brett Hinton 602-542-4214
 Brenda Wright 602-542-4214
 Mala Muralidharan 602-926-3601


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