E-rate A Review of the 2007 Application

November 2006 E-rate: A Review of the 2007 Application Cycle 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 Agenda 1. 2. 3. 4. Overview of the program What’s new for 2007 (and old reminders) Technology plans Review of the application process Videostreamed live, November 20, 3:30-5:45pm Archived: http://www.uwex.edu/ics/stream/dpi/ERate/index.htm PowerPoint: http://dpi.wi.gov/pld/erate.html 2 E-rate Program Overview  E-rate created by 1996 Telecom. Act  One of four FCC Universal Service programs administered by the Universal Service Administrative Company (USAC)   Schools and Libraries Division (SLD) manages E-rate E-rate funded at $2.25 billion annually; contributed by consumers  1. 2. 3. Get discounts on three eligible services Telecommunications Internet access Internal connections  1. Who is eligible? K-12 public and private schools 2. Public libraries 3 What Are E-rate Eligible Services?  Eligible services described in Eligible Services List   Lists Services which are conditionally eligible and ineligible 2007 list on SLD Website (www.usac.org/sl) Telecommunications services     Priority 1  Local and long distance Wireline and wireless Voice, video, data   Internet access Basic Net access Priority 1 funded first; then Priority 2 starting with highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.  Priority 2  Internal connections (switches, hubs, routers, wiring) 4 How Much Discount Can I Get?   Based on students eligible for free/reduced lunch Data entered on DPI’s Lunch Data Website  Website open: November 1 – December 1   Schools can use their own data, but DPI only verifies to SLD data reported via lunch Website Petitioning FCC to use ISES enrollment/poverty data ISES Issue for 2007 E-rate applications: DPI will decide in late November which school year data to use. —Either last year (2005-06) or the current (2006-07) school year. 5 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? (Nov – Feb 7)  Lunch data – 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 6 E-Rate Flowchart (Part 1) Write technology plan before filing Form 470. Plan approval needed by July 1. Applicant posts requests for services to SLD web site www.usac.org/sl using Form 470. Late December? SLD mails applicant 470 Receipt Notification Letter. Applicant waits 28 days while service providers submit bids to applicants. If no bids are received, applicant selects provider. Applicant sign contracts on or after Allowable Contract Date (29th calendar day after 470 is posted). SLD mails applicant and the service provider Receipt Acknowledgement Letter for each 471 received. Applicant submits Form 471 to request discounts to SLD during 471 window (Nov 14 - Feb 7, 2007) 7 E-Rate Flowchart (Part 1) Tech Plan before 470 Form 470 Posted Wait 28 Days RNL If no bids are received, applicant selects provider. Pick Vendor & Sign Submit 471 RAL 8 E-Rate Flowchart (Part 2) SLD’s PIA Team reviews every application, contacts applicant for verifications, more info, etc. SLD mails applicant and service provider funding commitment decision letters (FCDL) which indicate approval/denial of funding requests. Applicant can appeal a denial of funding to the SLD within 60 days of date on FCDL. Applicant submits Form 486 to SLD for each funding request to “turn-on funding” and certify CIPA compliance. Deadline often is Oct. 28 SLD mails applicant and service provider a 486 approval letter. Discounted Bills Applicant begins receiving discounted bills. Reimbursement Applicant pays full bill, submits Form 472 (BEAR) to SLD. SLD mails applicant and service provider a BEAR approval letter. Applicant submits Form 500 to release any unused funds (optional) 9 E-Rate Flowchart (Part 2) PIA Review FCDL - Decision Form 486 – Service Start Discount 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) 10 What’s New for 2007?      Election results will help ensure program’s survival Telecom issues will resurface in next Congress FCC still undertaking major review of whole application and fund dispersal process Form color is pink for FY 2007 SLD reorganized Website  Deadline tool   Friendly FCC appeal decisions (e.g., Bishop Perry) 2007 Eligible Services List (ESL) changes 11 Bishop Perry: Correcting Errors  Ministerial and clerical errors can now be corrected after applications are submitted  Missing certs can also be submitted after the close of window   Failure to meet Minimum Processing Standards no longer automatically cause for rejection PIA will contact you if errors are detected, or not  In general, 15 day deadline for you to respond  See Bishop Perry Order info on main SLD Website Review PIA requests for info carefully and respond! 12 Revised Letters    Form 470 Receipt Notification Letter (RNL) and Form 471 Receipt Acknowledgment Letter (RAL) Text reduced to two pages Easier correction of Ministerial and clerical errors  Fields that cannot be corrected are identified  Fields that can be corrected have space next to them for making corrections 13 2007 Eligible Services List (ESL)   More compact format, added index and glossary If it’s not in the ESL, assume it’s not eligible  When in doubt, break it out as separate funding request!  Components or services that are ineligible (e.g., filtering) must be removed to receive funding  But full funding may be provided (see ESL ancillary use guidelines) See SL News Brief (3-31-06) for more information  Funding requests must be cost effective  14 2007 Eligible Services List (ESL)  VoIP is now eligible (p. 19, 33)  Waiting for more FCC guidance   A Wireless Internet access service for portable devices (e.g., Blackberry-type services, p. 7) Emphasis on basic conduit access to the Internet  To be Internet eligible, packets must hit the boundary of public Internet space Generally, WANs and VPNs can only be provided by a telco  15 Contract Issues      FCC E-rate contract rules trump local policies 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 Both school and provider must sign and date contract before filing Form 471 Verbal agreements are not acceptable  Quotes are not acceptable   State Master Contracts  DPI will provide guidance on STS and cell phone contracts 16 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 17 Appeals  Funding denials can be appealed    Generally, appeal first to the SLD Can appeal to the FCC if SLD does not grant appeal DPI has appeal form template     Must be postmarked within 60 days of the SLD denial Recent major change: FCC now granting many appeals Contact DPI for appeal advice and template See Appeals Procedure info on SLD Website 18 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.   19 E-Rate Changes/Expiration Revision Timelines for Information and Technology Plans Plan Expires Developed prior to 470 Filing ** Plan to DPI by: Plan Dates June 30, 2007 Dec 31, 2007 Dec 2006 Dec 2006 May 1, 2007 May 1, 2007 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. 20 Technology Plans  Must cover five areas: 1. 2. 3. 4. 5. Goals / Strategies for using technology Professional development Needs assessment Sufficient budget Evaluation process  If missing something add it in an addendum 21 Technology Plans  Libraries are covered by Library System Plans and approved by DPI Public school plans are approved by DPI   http://dpi.wi.gov/imt/tekcert.html  Private schools by WCRIS or TEACH/DOA 22 www.sl.universalservice.org Forms are off the SLD home page. ` 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   Tues Jan 9, is drop dead 470 date, don’t wait that long Will get a 470 Receipt Notification Letter (RNL) from SLD Violating 28 day rule is #1 reason for denial of applications 24 Tips on Filing Form 470    Can file the 470 now for 2007 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 prospective providers  Document if you received no responses 25 Tips on Filing Form 470   Must file 470 every year for tariffed or MTM services Can file 470 once for multi-year contracts  470 and any bid documents must indicate length of contract, including any optional extensions Check both options in question #7    After 28 days, then file Form 471 Form 470 must be certified by close of Form 471 filing window 10:59 pm CST, Wednesday, February 7, 2007 26 Service Classification Types of Services Telecom Tariffed (#7a) MTM (#7a) Contracted (#7b)       Internet Internal 27 Show key 470 online form screens 28 E-rate Form 471    Wed., Feb 7, 2007 10:59PM CST 2007 Form 471 drop dead date: 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 Certifications for associated Forms 470 also must be filed online or postmarked before the close of the window.  29 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 online Form 471!!!! 30 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. 31 32 Block 1: Basic contact information 33 RECORD YOUR SECURTIY CODE!!!! 34 Block 2 or 3: Impact of services ordered 35 Block 4: Calculate Discount. Adding entities (schools) 36 Block 4: Calculate Discount. Adding entities (schools) 37 Block 4: Calculate Discount. Adding entities (schools) NCES Codes: http://nces.ed.gov/globallocator/ 38 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! 39 Block 5: Type of service. 470 Number Contract or Month-tomonth 40 Block 5: Service start and end dates OR Contract award and expiration date 41 Block 5: Item 21 Attachment 42 Block 5, Item 21 The 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 43 43 Item 21 Example Narrative description: Quantity Product or Service Description Extended Pre-discount Cost Unit Cost Recurring NonRecurring Total Additional Information: 44 44 Block 5: •Enter Amounts. •Add another block 5? 45 Block 6: Certifications Have necessary resources 46 Block 6: Certifications Have technology plan 47 Block 6: Certifications Send Signed Certifications or PIN 48 Block 6: 49 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 50 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  51 51 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 52 Application Review • Forms 471 are reviewed by Program Integrity Assurance (PIA) for compliance with program rules concerning areas such as: • • • • • • • Competitive bidding process Contracts Discount calculation Sufficient budget Establishing Form 470 Technology plan Children’s Internet Protection Act 53 53 Application Review • Provide information to PIA promptly • Work with your service provider to comply with information requests. Make sure your answers respond completely to the questions asked. • • Ask for more time to respond if you need it. • However, if you ask for more time, your PIA representative will work on other applications and you may wait longer for a decision. • Check the 471 Application Status Tool. 54 54 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. 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) 55 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 56 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 57 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 58 Where to Go For Help  On the Web: www.usac.org/sl/     Client Service Bureau: 888-203-8100 Via e-mail: question@slcfund.org Via fax: 888-276-8736 Fax on demand documents: 800-959-0733 59 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 60 November 2006 E-rate: A Review of the 2007 Application Cycle ? 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 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  62