E-rate A Review for 2008 -Session starts at 1pm-

November 9 and 29, 2007 E-rate: A Review for 2008 -Session starts at 1pm- Bob Bocher 608-266-2127 cell 608-212-2773 robert.bocher@wisconsin.gov Steve Sanders 608-266-3856 stephen.sanders@wisconsin.gov Agenda 1. 2. 3. 4. Overview of the E-rate program Eligibility and discounts Technology plans Review of forms and application process Video and PowerPoint: http://dpi.wi.gov/pld/erate.html 2 Overview   Created by 1996 Telecom Act $2.25 billion annually from interstate phone revenue   Can use rollover funds; $650 million in 2007 Wi averages $25 million/annually   FCC has regulatory and legal oversight SLD does program administration  SLD division of USAC K-12 public and private 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 elementary and secondary schools and public libraries.” 3  Eligible applicants   2007 Status of WI Funding Requests (2,384 requests as of Nov 27, 2007) FRs for P1 still pending, 10% FRs for P2 still pending, 4% FRs denied, 4.80% FRs funded, 81.20% Check your application status at http://www.sl.universalservice.org/FY3_form471/471StatusCheck.asp 4 What Are E-rate Eligible Services?  2008 Eligible Services List  Lists services which are eligible and ineligible Telecommunications services (telco’s only)   Priority 1  Local/long distance, wireline and wireless, voice, video, data   Internet access Basic access  Priority 2   Internal connections Basic maintenance of IC Priority 1 funded first; then Priority 2 starting with highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%. 5 How Much Discount Can I Get?  Discounts range from 20% to 90%   Based on free/reduced lunch eligible Enrollment and lunch data entered on ISES   Part of NCLB mandates Enter most accurate lunch data by ISES lockdown, Nov 6   DPI does not verify schools using their own data DPI posts public Excel file in mid-to-late Dec.  Sends file to SLD 6 Discounts  Calculating Discount Methods   Primary measure: NSLP Alternative discount mechanisms School districts use the weighted average of the discounts of individual schools in the school district Libraries use the simple average discount of the school district in which they are located  Shared Discounts    Consortia use the simple average of the consortium members 7 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% 8 Issues of Waste, Fraud, Abuse  W/F/A still problem in program   Eligible services used by eligible entities for eligible purposes 90% discount and complex program rules More certifications  W/F/A drives many FCC decisions    More PIA requests for info More audits leading to more COMADs Friday, Nov 2, 2007 Wash. Post. ―Andre Hornsby [Prince George's County MD dist. sup.] is accused of steering a consulting contract to a business associate to help the school system secure funds under a federal program known as E-Rate. Prosecutors allege that Hornsby expected kickbacks of $145,000. ‖ 9 Technology Plans  Technology plans must be ―developed‖ before the Form 470 is filed. (1st step in process) Plans must support requested services in your Form 470 Plans must be approved before service begins, usually July 1, 2008 Technology plans must cover the entire funding year for which a service is being sought. (Can’t expire before June 30, 2009) 10    Technology Plans Timelines for Information and Technology Plans Developed prior to 470 Filing ** Dec 2007 Dec 2007 Plan to DPI by: May 1, 2007 May 1, 2007 Plan Approved by: July 1, 2008 July 1, 2008 Plan Expires June 30, 2008 Dec 31, 2008 ** 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. 11 CIPA/NCIPA Compliance  Compliance with CIPA required for Internet access and internal connections; not telecommunications.  CIPA requirements include filtering and an Internet Safety Plan Children's Internet Protection Act 12 The Application Process    Technology Plan – What is my plan? (Before 470) Form 470 – What services do I want? (Oct – Dec) Form 471 – What services did I order? (Dec – Feb 7)  Lunch data in Dec. – How much of a discount do I get?   Form 486 – When did services start? (May – Oct) Form 472 or Form 474 – How do I receive reimbursements or discounts? (July – Oct 08) Retain all documentation for at least five years!! Online filing/certification available for most forms 13 E-Rate Flowchart (Part 1) Tech Plan before 470 Form 470 posted Wait 28 Days RNL Select vendor, cost main factor. If no bids, applicant selects provider. Pick vendor, sign contract Submit 471 RAL 14 E-Rate Flowchart (Part 2) PIA Review FCDL - Decision Form 486 – Service Start Discount on bills BEAR (472) Applicant can appeal a denial of funding to the SLD within 60 days of date on FCDL. SLD mails applicant and service provider a 486 approval letter. SLD mails applicant and service provider a BEAR approval letter. Form 500 (optional) 15 Forms and Deadlines Form or Event Funding Year   Deadline or Dates July 1 through the following June 30; Current year is 2007. Starts request for services. Must be posted at least 28 days before the filing Form 471. Keep in mind (1) the timeframe for all bids (2) the Form 471 filing closing date. Will receive Receipt Acknowledgement Letter – RAL. 470 drop dead date for 2008 is Jan 10. Tells SLD what services you want to receive, the provider, costs, schools getting services, discount %, contract or MTM, etc. Can be filed from Nov 6 to 10:59 PM CST February 7, 2008. Will receive Receipt Notification Letter – RNL. SLD’s Program Integrity Assurance (PIA) staff review all applications, which can take over 8 months. PIA will contact you with questions. Starting late April, Funding Commitment Decision Letters sent to applicants. This continues for months. Confirms start of service. Must be received/postmarked within 120 days after FCDL date or 120 days after the Service Start Date, whichever is later. Get discounts on bills (#474) or reimbursements (#472). Received or postmarked no later than 120 days after the date of the Form 486 Notification Letter or 120 days after the last date to receive service, whichever is later. Must be received within 60 days of date on the FCDL. DPI can help you with any appeals. 16 Form 470 Form 471 PIA review FCDL sent Form 486 Form 472 / Form 474 Appeals       2008 Eligible Services List (ESL)    If it’s not in ESL, assume it’s not eligible Eligible Services Framework, has good overview Ineligible components/services must be removed  Full funding may be provided (see ESL Ancillary Use) See SL News Brief (3-31-06) for more information  Funding requests must be cost effective    Centrex is now basic phone service, no tech plan Internet access for distance learning clarified as eligible 17 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 18 Online Forms Training Site (http://usactrain.solixinc.com) See the Sept 21, 2007 News Brief for training site information. 19 Form 470 20 Form 470  470 begins request or 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 28 day minimum before you select a provider or sign a contract and file the 471  Thurs, Jan 10, 2008 is drop dead 470 date, don’t wait that long 21 Form 470 Filing Options  File 470 once for multi-year contracts or contracts with voluntary extensions  470 and RFP must indicate this  Check 7a and b and both options under b  In future years, site the original 470  Must file 470 every year for  tariffed or month-to-month services where you have a 1 year contract  Services 22 Form 470 and Competitive Bidding  Must have a fair and open bidding process   All bidders are treated the same All bidders have equal access to information Cost must be primary factor Based on cost of E-rate eligible products/services Non-eligible products/services not part of cost effectiveness Fully document your bid review process and any decision(s)   Must choose most cost-effective bid     Record dates of any decisions 23 Common Bidding Violations        Cost was not primary factor Provider involved with 470 and/or RFP Applicant’s consultant associated with service provider Consultant used with no Letter of Agency (LOA) Contract signed before RFP due date or before 28 days is up Failure to advise bidders that RFP was available Failure to provide bidding documentation  Requested as part of PIA review or audit 24 Tips on Filing Form 470   Can file the 470 now for 2008 services 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 all providers  Document if you received no responses 25 26 470 options 27 Checking all keeps all options open. 28 29 Check these boxes 30 Check all certifications 31 32 Form 471 33 E-rate Form 471  Provides specific information on services, service providers selected, and contracts and/or agreements, 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 Feb 7, 2008 Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window Thurs. February 7, 2008, 10:59PM CST 34 2008 Form 471 drop dead date: 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. 35 36 Block 1: Basic contact information 37 RECORD YOUR SECURTIY CODE!!!! 38 Block 4: Calculate Discount. Adding entities (schools) 39 Block 4: Calculate Discount. Adding entities (schools) 40 Block 4: Calculate Discount. Adding entities (schools) NCES Codes: http://nces.ed.gov/globallocator/ 41 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! 42 Block 5: Type of service. 470 Number Contract or Month-tomonth 43 Block 5: Service start and end dates OR Contract award and expiration date 44 Block 5: Item 21 Attachment 45 Block 5 — Item 21 Attachment  ―You MUST attach a description of the service, including a breakdown of components, costs, manufacturer name, make and model number….‖ are provided in the document ―Item 21 Attachments for Form 471‖  Examples http://www.sl.universalservice.org/reference/ Form471item21Attachments.asp 46 46 Block 5: •Enter Amounts. •Add another block 5? 47 Block 6: Certifications Have necessary resources 48 Block 6: Certifications: Have Technology Plan 49 Block 6: Certifications: Send Signed Certifications or PIN 50 Block 6: 51 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://usac.org/sl/tools/required-forms.aspx 52 Receipt Acknowledgement Letter  Form 471 Receipt Acknowledgment Letter (RAL)   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 reductions but not funding increases  53 53 Contract Issues    FCC E-rate contract rules trump local policies Telecom and Internet may/may not be contracted services As noted, on the 470, always check #7, options a and b  Caution on multiyear contracts and any RFP Verbal agreements are not acceptable Quotes are not acceptable DPI provides guidance on STS and cell contracts 54  You must sign and date contract before filing Form 471    State Master Contracts  State Master Contracts  DOA cell and BadgerNet contracts   DOA filed Form 470 Applicant files 471 for cell service using DOA 470  Wait to file for 2008  DOA/TEACH files 471 for BCN   DOA now doing ISP bid DOA STS contract   File Form 470 and 471 every year 471, #18, Contract Award Date (CAD) is date you selected SMC as winning bid  Must be after 28 days 55 Other Statewide Issues  DOA cell contract now finalized  Still working on July 1 funding issue    Bandwidth options paper VoIP and DOA/TEACH circuit issue Preps-on-the-Net issue   Webhosting and advertising DPI and TEACH/DOA: Video streaming is content; can’t get E-rate on content Issue sent to SLD for resolution  FCC prohibits E-rate services being "transferred in consideration for money or any other thing of value." 56 Program Integrity Assurance (PIA) Application Review  PIA reviews all applications    To ensure that funds are used for eligible services/products To ensure that funds go for eligible uses by eligible entities To annoy you by asking for same documents multiple times Need more info on requested services Competitive bidding process and contracts Discount calculation Establishing Form 470 ―please provide the Form 470 that established the bidding for the contract extension.‖ 57 57  Common PIA requests to applicants     Program Integrity Assurance (PIA) Application Review  Respond within 15 days to PIA requests     Work with service provider if needed Respond completely to PIA questions, but no more Ask for more time or for clarification if needed; contact DPI 17% of all WI denials: No response or insufficient info 10% of FRNs move to ―Selective Review”  PIA initial review   Check 471 status at 471 Application Status Tool 58 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 info on FCDL to prepare Form 486 59 Appeals  Funding denials can be appealed  Generally, appeal first to the SLD  Then appeal to FCC if SLD denies appeal     Must be postmarked within 60 days of denial on FCDL Major change: FCC now granting many appeals Contact DPI for appeal advice and template See Appeals Procedure info on SLD Website 60 E-rate Form 486  Notification that services have started and that 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 service starts –OR– 120 days after date of Funding Commitment Decision Letter date, whichever is later  Late    October deadline for FCDL before July 1 61  Online version continues to have issues 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 providing services and billing applicant for its non-discount share 62 Where to Go For Help  On the Web: www.usac.org/sl/  Fall 2007 training slides Enter your BEN and get info on your application  E-rate Central, Wisconsin site      Client Service Bureau: 888-203-8100 Via e-mail: question@slcfund.org Via fax: 888-276-8736 Fax on demand documents: 800-959-0733 63 DPI Help  DPI’s E-rate Web site:  dpi.wi.gov/pld/erate.html dpi.wi.gov/pld/wieratelist.html  DPI’s WIERATE email list:   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 64 November 2007 E-rate for 2008 ? 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