November 2008
E-rate Basics:
Overview for 2009
Bob Bocher
608-266-2127
robert.bocher@dpi.wi.gov
Steve Sanders
608-266-3856
stephen.sanders@dpi.wi.gov
Video and PowerPoint: http://dpi.wi.gov/pld/erate.html
Agenda
1. 2. 3. 4.
Overview of the E-rate program Eligibility and discounts Technology plans Review of forms, application process and timeframe
Video and PowerPoint: http://dpi.wi.gov/pld/erate.html
Advanced workshop on Nov 24, 1:00pm – 3:30pm.
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Overview
Created by 1996 Telecom Act $2.25 billion annually from interstate phone revenue FCC has regulatory and legal oversight Schools and Libraries Division (SLD) does program administration
E-rate one of four Universal Service programs administered by USAC K-12 public and non-public schools, CESAs, Head Starts Public libraries, library systems
The Telecom Act created a program to enable “access to advanced telecommunications and information services for all K-12 schools and public libraries.”
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Eligible applicants
What Are E-rate Eligible Services?
Eligible Services List
Lists services which are eligible and ineligible 2009 list will be on SLD Website (www.usac.org/sl) Telecommunications services (telco’s only)
Priority 1
Local/long distance, wireline and cell, voice, video, data
Internet access
Basic access Priority 1 funded first; then Priority 2 starting with highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.
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Priority 2
Internal connections Basic maintenance of IC
How Much Discount Can I Get?
Discounts range from 20% to 90%
Based on free/reduced lunch eligible
Enrollment and lunch (poverty) data entered on ISES
Part of NCLB mandates
Enter most accurate lunch data by ISES lockdown
DPI does not verify schools using their own data DPI posts public Excel file in mid-to-late December
Send file to SLD
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Discount Matrix
Percent of Eligible Students Less than 1% 1% - 19% 20% - 34% 35% - 49% 50% -74% 75% -100% Urban 20% 40% 50% 60% 80% 90% Rural 25% 50% 60% 70% 80% 90%
State average is 53%
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Technology Plans
Technology plans must be ―developed‖ before the Form 470 is filed. (1st step in process) Plans must support requested services on Form 470 Plans must be approved before service begins, usually July 1, 2009
Technology plans must cover the entire funding year for which a service is being sought. (Can’t expire before June 30, 2010)
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Technology Plans
Timelines for Information and Technology Plans
Developed prior to 470 Filing **
Dec 2008 Plan to DPI by: May 1, 2009 Plan Approved by: July 1, 2009
Plan Expires June 30, 2009
** 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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CIPA/NCIPA Compliance
(Children's Internet Protection Act)
Compliance with CIPA required for: o Internet access o Internal connections o But not telecommunications CIPA requires filtering and having an Internet Safety Plan New law will require Internet safety policy to include educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response. See DPIs CIPA FAQ at: http://dpi.wi.gov/pld/cipafaq.html
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The Application Process
Form 470 – What services do I want? (Oct – Dec)
Tech Plan must include services requested before filing 470
Form 471 – What services did I order? (Nov? – Feb?) Form 486 – When did services start? Form 472 – How do I receive reimbursements? (No form for discounts on bills) (by Oct 28, 2010) Retain all documentation for at least five years!!
Online filing/certification available for most forms
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E-Rate Flowchart (Part 1)
Tech Plan before 470
File Form 470 (wait minimum 28 days)
SLD sends you Receipt Notification Letter - RNL If no bids, you select provider. If you received bids, evaluate them, cost being main factor. Sign contract, if needed. SLD sends you Receipt Acknowledgement Letter – RAL
Select vendor
Submit 471
Detailed flow chart: http://www.usac.org/_res/documents/sl/pdf/application-process-flow-chart.pdf
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E-Rate Flowchart (Part 2)
PIA Review
(Program Integrity Assurance )
PIA reviews all applications, will likely contact you. Contact DPI if you have questions on any PIA request.
FCDL - Decision
SLD sends you Funding Commitment Decision Letter – FCDL. You can appeal any denials of funding.
Form 486 – Service Start
SLD mails applicant and service provider a 486 notification letter.
Discount on bills
BEAR (472)
SLD mails applicant and service provider a BEAR notification letter.
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Telecom provider issue 470/471 service 3% mismatch Other 4% 6% Service provider involvement 4% Tech plan issues 4% Budget issues 5% 471 filing issues 9% No 470 posted 9%
Common Reasons for Denial of Funding
Contract issues 24%
Insufficient documentation 17% 30% rule 15%
http://dpi.wi.gov/pld/eratedenials.html
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Contract Issues
Must follow both FCC E-rate contract rules and state contract law Telecom and Internet may/may not be contracted services On Form 470, always check #7, options a and b
Caution on multiyear contracts and any RFP
Verbal agreements are not acceptable
You must sign and date contract before filing Form 471
Quotes are not acceptable
DPI provides guidance on STS and cell contracts
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State Master Contracts
2009 Eligible Services List (ESL)
If it’s not in the ESL, assume it’s not eligible
When in doubt, break it out as separate funding request!
Ineligible components/services (e.g., filtering) must be removed Funding requests must be cost effective
See SL News Brief (3-31-06) for more information
Centrex is now basic phone service, no tech plan needed DPI supports VoIP, filtering and having all telecom services be exempt from tech plan requirement
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Main SLD Website
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Online Forms Training Site
(http://usactrain.solixinc.com)
See SLD Sept 21, 2007 News Brief for training site information.
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Form 470 Basics
470 begins bidding process and must be filed if: You are requesting a service for which you have no contract
Usually tariffed or monthly telco or Internet service
Your
contract expires on June 30, 2009
470 must be posted on SLD Website for at least 28 days before you select a provider or sign a contract
Form 470 drop dead date is likely late December or early January
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Tips on Filing Form 470
Can file the 470 now for 2009 services
Be certain to have draft Tech Plan
File one 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
Don’t let providers consult or complete the form Keep all info received from prospective providers
Document if you received no responses
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Form 471 Basics
Provides specific information on services, service providers selected, contracts, costs, etc. Provides discount calculation information Must be filed each funding year
Applicant certifies compliance with all program rules
Must be postmarked or filed online by deadline Form 470 certifications must also be filed online or postmarked by 471 filing deadline (15 day grace period)
Form 471 drop dead date is likely in late January or early February 2009
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Tips on Filing Form 471
Wait
minimum 28 days from posting of Form 470
Review
paper form or online training site before doing ―live‖ form. File online.
Do
separate 471 for Priority 1 and P2 services
ineligible costs, document/est. eligible costs
description of the service and costs (item 21)
Remove
Attach
Examine,
correct, and save Receipt Acknowledgement Letter (RAL)
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Program Integrity Assurance (PIA)
Application Review
PIA reviews all applications, contacts applicants
Documentation on costs Contract language, dates, services, etc. Establishing Form 470
Tech Plan
Work with service provider if needed
Respond to PIA requests promptly (14 days)
Respond completely to questions, but no more
Can ask for more time to respond; if needed, contact DPI
22 22
Check 471 status on Application Status Tool
Funding Commitment Decision Letter (FCDL)
FCDL
reports status of individual funding requests:
Funded
Funded
Not
As
Yet Unfunded (Internal Connections)
Canceled
May Use
receive more than one FCDL
the info on FCDL to prepare Form 486
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E-rate 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. Form 486 Deadline is 120 days after the service start date or Funding Commitment Decision Letter date, whichever is later
Late
October deadline for FCDL before July 1
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E-rate Form 472/474 (Invoices)
Invoices — Form 472 or Form 474
BEAR (Billed Entity Applicant Reimbursement) Form 472 filed by applicant and certified by service provider after receipt and payment for services
Form often due late October, 120 days after last day of services on June 30
or 120 days after date of Form 486 Notification Letter
-OR
SPI (Service Provider Invoice) Form 474 filed by service provider after billing applicant for its non-discount share
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Appeals
Funding denials can be appealed
Generally, appeal first to the SLD Can appeal to the FCC if SLD denies appeal
Must be postmarked within 60 days of SLD denial FCC has been granting many appeals
But can be a year or more No appeal form
Contact DPI for appeal advice and template
See Appeals Procedure info on SLD Website
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Where To Go For Help
On the Web: www.usac.org/sl/
Reference: http://www.usac.org/sl/tools/reference-area.aspx
Client Service Bureau: 888-203-8100
Via e-mail: question@slcfund.org Via fax: 888-276-8736 SLD News Briefs: http://www.usac.org/sl/tools/newsbriefs/Default.aspx
E-rate Central (non-SLD): http://www.eratecentral.com/us/stateInformation.asp?state=WI
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DPI Help
DPI’s E-rate Web site:
http://dpi.wi.gov/pld/erate.html
DPI’s ERATE email list: http://dpi.wi.gov/pld/wieratelist.html DPI Staff:
Bob Bocher
608-266-2127; fax 608-266-2529 robert.bocher@dpi.state.wi.us
Steve Sanders
608-266-3856; fax 608-266-2529 stephen.sanders@dpi.state.wi.us
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November 2008
E-rate Basics for 2009
? Questions ?
Bob Bocher 608-266-2127 fax 608-266-2529
robert.bocher@dpi.state.wi.us
Steve Sanders 608-266-3856 fax 608-266-2529
stephen.sanders@dpi.state.wi.us