Year 2005 Suggestions
Document, document, document. Be prepared for audits and site visits. Read new and revised certifications carefully before signing. Follow rules to avoid Commitment Adjustments (COMAD). Consider CALNET options. Study CTF changes
FCC Registration Numbers
Required by the Federal Communications Commission (FCC) Fifth Order and Report and the “Red Light Rule” which flags applicants or service providers that have an unpaid debt to a federal program. All E-rate entities, including non-instructional entities, must obtain a FCC Registration Number. FCC Registration Numbers will replace Entity Numbers in 2006, but are required for Year 2005 funding.
Obtaining a FCC Registration Number
Need Taxpayer Identification Number (TIN), a.k.a. Employer Identification Number. The target date for obtaining FCC Registration Numbers is November 1, 2004. Program Integrity Assurance will contact applicants if the number is not on file. E-rate funding applications can be affected if a FCC Registration Number is not obtained. To obtain a FCC Registration Number, go to the FCC CORES Website at
(https://svartifoss2.fcc.gov/cores/CoresHome.html).
NCES Numbers for Form 471
National Center for Education Statistics (NCES) numbers for your school or district can be found at http://nces.ed.gov/ccd/search.asp Federal-State Cooperative System (FSCS) numbers for libraries can be found at http://nces.ed.gov/surveys/libraries/librarysearch Enter the information about your school, district, or library to search the database. Used for the Form 471 (dated October 2004) Block 4, Item 9a, Column 2.
NCES Numbers for Form 471
If the name search does not work, use district, zip, county, or state fields to narrow the search. If you have difficulty obtaining the NCES number, contact the SLD Client Service Bureau at 1-888-2038100 or http://www.sl.universalservice.org/overview/contact.asp.
Technology Plans
Form 470 must be based upon carefully thought out technology plan. Must detail specific services sought in a manner that would allow bidders to understand the specific technologies an applicant is seeking. Technology plans, Forms 470 and 471 must be aligned.
Technology Plans
Must be written by the submission of the Form 470. Must be approved by the start of services and the submission of the Form 486. Must address all five of the E-rate technology plan criteria. Must be accompanied with documentation that describes budget and access to resources needed to effectively use requested E-rate services and products.
Technology Plans
State approved EETT plans meet E-rate criteria when supplemented with an analysis of the applicant’s ability to secure resources to make effective use of Erate services. Plan must cover the entire funding year. If the plan expires during the funding year, the plan must can be updated before the submission of the Form 470 and approved before the start of services. Documentation of technology plan evaluation must be kept.
Technology Plan Content
Requests for E-rate funding commitments are limited to eligible telecommunications and information technology services that are within the scope of the technology plan. If the applicant desires to request E-rate discounts outside of the scope of the technology plan, the technology plan must be revised according the the adopted rules and timelines and must be reapproved.
Document Everything
The FCC Fifth Order and Report requires program participants to retain all documents necessary to demonstrate compliance with the statute and FCC rules regarding the application for, receipt, and delivery of services receiving schools and libraries discounts. Documentation must be retained for 5 years after the last date services are delivered.
Document Retention
Both applicants and service providers must retain all records related to the application for receipt and delivery of discounted services. Applies to Funding Year 2004 and after. Failure to maintain records or failure to make available required documentation is a rule violation that may warrant recovery of funds.
Other Documentation
Audits related to E-rate program or the NSLP. Financial statements and annual budgets. Records retention policy. List of E-rate team members. Payment of the undiscounted portion. Documentation on the services necessary to make effective use of E-rate discounts. Budget documentation. Letters of agency with consultants.
Site Visits
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Review E-rate site to help curb waste, fraud, and abuse. Gather information on the deployment and use of technology. Based on recent invoices. Provide one to two weeks notification, prior to visit. Provide a list of specific documentation to be reviewed. Conducted by consultants with an educational background and are not professional auditors.
Recovery of Funds
Framework for recovery of funds – Funds disbursed in violation of the statute or a substantive program goal must be recovered. – Full recovery may not be appropriate for violations of certain rules. – FCC will initiate and complete any inquiries within a five-year period after final delivery of service.
Recovery of Funds
E-rate funds can be recovered for “willful or repeated” violation of program rules. A commitment adjustment (COMAD) occurs when the SLD determines that funds were committed in violation of the statute or program rules and E-rate funds must be recovered or reduced from either applicants and service providers. USAC will make the determination to whom recovery should be directed by individual cases, either service provider or applicant.
Reasons for Recovering Funds
Failure to document that the applicant has the necessary resources to use the requested E-rate services and products. – Computers – Staff training – Internal connections – Maintenance – Electrical capacity
Red Light Rule
The FCC will not act on any application made by an entity that is delinquent in its non-tax debts owed to the FCC. The FCC will dismiss applications or requests if the delinquent debt is not resolved. Debt Improvement Collection Act (DCIA) and Red Light Rule bar beneficiaries or service providers from receiving E-rate if they have an outstanding obligation to repay monies to the fund.
Procurement Updates
State and local procurement rules – FCC rules apply IN ADDITION TO state and local procurement laws and competitive bidding requirements. – Example: State or local procurement law may permit an applicant to forego competitive bidding for products and services under a certain dollar threshold, but FCC rules require that applicants seek competitive bids on those products and services.
Cost Allocation Update
Ineligible products and services - In general, cost allocation may be used to determine the portion of the cost that may receive discounts. Allocating eligible and ineligible costs – A clear delineation can be made between eligible and ineligible components. – Must be the most cost-effective means of receiving the service. – Ancillary ineligible functionality need not be costallocated.
Eligible Services
References – Basic Maintenance » http://www.sl.universalservice.org/data/pdf/fcc %2003-323.pdf, paragraphs 20-24 – Technical Services » http://www.sl.universalservice.org/reference/eli gible.asp – Eligible Users and Locations » http://www.sl.universalservice.org/reference/ed ucational%5Fpurposes.asp
More References
Equipment Locations for Item 21 – See Form 471 instructions for 2005 Duplicative Services – http://hraunfoss.fcc.gov/edocs_public/attachmatch/ FCC-03-101A1.doc, paragraphs 22-24 Equipment Transfers – http://www.sl.universalservice.org/reference/EPSF AQ.asp
Eligible Services
Cost Allocations – http://www.sl.universalservice.org/reference/alpha betical.asp#c Service Substitutions – http://www.sl.universalservice.org/reference/Servic eSub.asp Wide Area Networks – http://www.sl.universalservice.org/reference/wan.a sp – http://www.sl.universalservice.org/reference/OnPr emP1.asp
References
Schools and Libraries Division
– http://www.sl.universalservice.org/
E-Rate Central
– http://www.e-ratecentral.org/
California Department of Education
– http://www.cde.ca.gov/ls/et/ft/eratemain.asp
Federal Communications Commission Orders
– http://www.e-ratecentral.com/FCC/
Sign up for the CDE E-rate email list
– http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp