Understanding E-rate
Aleck Johnson EdTech Strategies, LLC
U.S. Virgin Islands September 2008
Introduction to E-rate
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What is E-rate? Who is eligible for E-rate? What is eligible for E-rate? How can you participate in E-rate?
What is E-rate?
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Schools and Libraries Program
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Part of the larger Universal Service program Provides discounts to eligible schools and libraries for Telecom Services, Internet Access, Internal Connections, and Basic Maintenance Connections Applicants can be schools, libraries, or consortia, but only eligible recipients of service can receive discounts Applicants must apply for discounts each year (Form 471 application filing window) Funding cap each year is $2.25 billion
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Who is Eligible?
• Eligible Entities - 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,that provides elementary or secondary education, as determined under state law. • Must not be operating as a for-profit business. • Must not have an endowment exceeding $50 million.
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Eligibility
• Educational Purposes
• Activities that occur on library or school property are presumed to be integral, immediate, and proximate to the education of students or the p 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.
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Eligibility
• Eligible Entities - Libraries
• Must meet the statutory definition of library or library consortium in the Library Services and Technology Act ( gy (LSTA) of 1996. ) • Must be eligible for assistance from a state library administrative agency under LSTA. • Budget must be completely separate from that of any schools. • Must not be operating as for-profit businesses.
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What is Eligible?
• Priority 1 – funded first
• Telecommunications Services
• Basic telephone service — wireline or wireless phone service (local, cellular/PCS, and/or long distance) • Voice mail • Transmission services (T-1, DSL)
• Internet Access
• Basic conduit access to the Internet
• Basic Maintenance
• Basic maintenance of eligible internal connections
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Eligible Services
• Priority 2
• Internal Connections (switches, hubs, routers, wiring) • Basic Maintenance on Internal Connections
• 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.
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Eligibility
• Service Providers
• Service providers must register with the SLD • Telecom providers must be registered as telecom providers in the VI with the VI Public Service Commission
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How: Application Process • Application process
• • • • • • • Technology planning Competitive bidding / Form 470 Calculating di C l l i discounts Funding requests / Form 471 Application review / Funding commitments Starting services / Form 486 Invoicing USAC / Form 472 or Form 474
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Application Process
• Forms and Related Documents
• • • • • Technology plan Form 470 Form 471 Form 486 Form 472 or Form 474
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Application Process
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Key
AP or SP SPIN RNL RAL FCDL 486 NLtr BEAR or SPI Qtrly Disb Rpt Applicant or Service Provider Revised August 2002 Service Provider Identification Number Form 470 Receipt Notification Letter Form 471 Receipt Acknowledgment Letter Funding Commitment Decision Letter Form 486 Notification Letter Billed Entity Applicant Reimbursement or Service Provider Invoice Quarterly Disbursement Report
Application Process Flow Chart
Wait at least 28 days!
Develop a Technology Plan After Form 470 / RFP is posted, negotiate a contract (or arrangement for tariffed or month-to-month services) Program Integrity Assurance (PIA) review Technology Plan approved by certified approver
Invoice review (BEAR) Correct errors and resubmit if needed
Receive discounts on bills or reimbursement by check or credit
Form 470
Services Requested
Form 471
Services Ordered
Form 486
Services Confirmed
Applicant
RNL RAL FCDL AP Ltr AP 486 N Ltr
(AP copy)
BEAR
N Ltr
Qtrly
Disb Rpt
BEAR or SPI
Service Provider
Form 498
Apply for SPIN (if not done previously)
RAL
SP Ltr
FCDL SP Ltr
SP 486 N Ltr
N Ltr
Form 472
BEAR Form
BEAR reimbursement to AP
Form 473
Annual Cert
OR
Form 474
SP Invoice Form
Check filed Forms 470, contact applicants and respond with bids
Negotiate a contract (or arrangement for tariffed or month-tomonth services)
Assist with Program Integrity Assurance (PIA) review
Invoice review (SPI) Correct errors and resubmit if needed
Receive USAC remittance statement and payment October 2006
Technology Planning
• Overview
• Not required for basic telephone service • Must be written before Form 470 filing (keep a copy for the file) • Must be approved by a certified approver before discounted services start • Must cover all 12 months (or all months of service) • Must cover five specific elements
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Technology Planning
• Five Elements of Technology Plans
• • • • • Goals / Strategies for using technology Professional development Needs assessment Sufficient budget Evaluation process
• Technology Plan must be approved before services start (CCUE or other)
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Technology Planning
• Tech Plan Tips: • Have a DATED copy of your technology plan that shows it was “written” prior to filing the Form 470 • Use each required area as a heading in your plan and address that area under the heading. heading • PRINT A DATED COPY of your certified approval for your records. • Make sure your technology plan is approved for the entire period (usually 12 months) that discounted services will be delivered.
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Application Process: Form 470
• Filing Form 470 opens a competitive bidding process.
• Can also issue a Request for Proposals (RFP).
• Applicants are responsible for ensuring an open and fair process and selecting the most cost-effective provider of the desired services. • Form must be posted for 28 days prior to filing Form 471
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Application Process: Form 470
• Competition
• Goal is to have as many bidders as possible • Promotes better service and lower prices
• Fair and open process
• • • • All bidders treated the same No advance knowledge of RFP information No secrets in the process All bidders know what is required of them.
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Application Process: Form 470
• Selecting service providers
• Applicants must choose the most cost-effective solution to their Form 470 or RFP, with price as the primary factor • Other factors can be considered, but price must be the most heavily weighted. • Evaluation process should be carefully documented and that documentation must be maintained.
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Discount Calculation
• For most applicants, discounts are calculated using
• % of students eligible for National School Lunch Program (NSLP) g ( ) • Urban or rural status of county in which school or library is located (from web site)
• These two pieces of information are carried into the Discount Matrix
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Discount Calculation Discount Matrix
% 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%
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Discount Calculation
• Calculation for USVI
• Written into NSLP legislation that USVI schools can use territory-wide poverty survey for F&RPL calculations • That survey currently gives every school in the USVI the deepest possible discount (90%)
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Application Process: Form 471
• Form 471 • Filed after contracts/agreements are put in place for provision of services • Provides specific information on services, service providers selected, and contracts • Provides discount calculation information • Must be filed for each funding year • Contains certifications of compliance with program rules made under penalty of law
• Includes certification of sufficient resources, meaning at least a draft budget for technology for the coming school year must be written
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Application Process: Form 471
• Form 471 Deadline
• Form 470 must have been filed for 28 days prior to filing 471. • Must be filed online or postmarked on or before the close 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. • Deadline is typically in late Jan. or early Feb.
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Application Process: PIA Review
• Forms 471 are reviewed by Program Integrity Assurance (PIA) for compliance with:
• • • • • • • • Competitive bidding process Contracts Discount calculation Sufficient budget Establishing Form 470 Technology plan Children’s Internet Protection Act Other program rules
• PIA review is difficult and time consuming unless you are well prepared
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Application Process: Form 486
• Form 486
• Notifies USAC that services have started and invoices can be paid • Certifies that Tech Plan (if required) meets program requirements. • Certifies the 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).
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CIPA Compliance
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CIPA Requirements:
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Technology Protection Measure (filter)
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Must monitor activity of minors (log) Access to inappropriate materials over the web Safety of minors using email, chat rooms, and other online direct communications Unauthorized access (“hacking”) Unauthorized disclosure of personal information regarding minors Measures to restrict minors’ access to “harmful” materials Allow public comment on measures taken to comply with CIPA Can be at a board meeting, etc.
Acceptable Use Policy (AUP)
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Public Meeting
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Invoicing / 472 or 474
• BEAR (Billed Entity Applicant Reimbursement) Form 472 is filed by the applicant and certified by the service provider a te t e app ca t ece ves se v ces a d after the applicant receives services and pays for the services in full. • SPI (Service Provider Invoice) Form 474 is filed by the service provider after providing services and billing the applicant for its nondiscount share.
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Tips and Hints
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Tips and Hints
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Rules compliance is VERY important Document everything
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Forms, correspondence, tech plans, draft budgets, CIPA compliance, bills, installations, bids, bid evaluations, bid summaries, etc. l i i Must be able to produce EVERYTHING in the event of an audit Electronic (scanned) copies are acceptable SLD “Binder” Keep backups if possible
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Keep well organized files of materials
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Read the instructions and ask questions
Questions?
Aleck Johnson EdTech Strategies, LLC ajohnson@edtechstrategies.net 202-352-5364 (voice) 815-366-8131 (fax)
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Guide to E-Rate Binder Table of Contents 1. USAC Forms & Certifications
1.1. 1.2. 1.3. 1.4. 1.5. 1.6. Form 470 & delivery confirmations Form 471 & delivery confirmations Form 472 & delivery confirmations Form 479 (Consortium members & consortium leaders only) Form 486 & delivery confirmations Form 500 & delivery confirmations
2. USAC Letters
2.1. 2.2. 2.3. 2.4. 2.5. 2.6. 2.7. 2.8. 2.9. Form 470 Receipt Notification Letter (RNL) Form 471 Receipt Acknowledgment Letter (RAL) Form 471 Out Of Window Letter (OOW) Funding Commitment Decision Letter (FCDL) Form 486 Notification Letter Form 500 Notification Letter BEAR Notification Letter Quarterly Disbursement Reports (QDR) Other USAC letters
3. Technology Plan & Approval Letter
3.1. 3.2. 3.3. 3.4. 3.5. 3.6. Written Technology Plan with Creation Date Approved Technology Plan Approved Technology Plan updates Certified Technology Plan Approver Letter (or screen print if approval is maintained online) Professional Development Training Log (Sample Available) Technology Plan Training Sign In Sheet (Sample Available)
4. Competitive Bidding, Vendor Evaluation & Contracts
4.1. 4.2. 4.3. 4.4. 4.5. 4.6. 4.7. 4.8. 4.9. 4.10. State and Local Procurement Regulations (printout or website reference) RFP/ Public Notice/ Advertisement All Vendor responses & Bids received (winning and losing) Bid Evaluation criteria, Evaluation Matrix & Bid ratings (Sample Available) Notice of Award letters Miscellaneous documents (memorandums, board minutes, notes to file) Signed and Dated Contracts/ Service Agreements/ Notice of Award Letters Contract Amendments/Addendums/Extensions State Master Contracts (printout or website reference) Vendor Correspondence
5. PIA Review
5.1. 5.2. 5.3. 5.4. 5.5. 5.6. Letter of Agency (LOA) consortium (Sample Available) Consultant agreement or LOA Responses to PIA inquiries (email, faxes, case numbers) Entity eligibility documentation (state website printout, matching records, etc.) Discount eligibility calculation documentation (Sample Available) Item 21 Attachment (online or paper) (Samples Available)
There have been many requests for USAC to provide guidance with respect to what documents should be retained. Here is a guide that may be helpful. In addition, retaining this type of information will be very helpful if USAC requests this information in the future. This guide is not mandatory or intended to serve any other purpose than to respond to requests for guidance. Page 1
E-Rate Binder Table of Contents Guide
5.7. 5.8. 5.9. Product Service Eligibility (warranties, product descriptions, network diagrams etc.) Budget (Final approved, Superintendent Letter, draft budget, Grant Letters) Request to Cancel Services
6. CIPA (Children’s Internet Protection Act)
6.1. 6.2. 6.3. Undertaking Actions to comply with CIPA (e.g., public notice, public meeting or hearing minutes, etc.) Filtering Documentation (purchase, installation, use) Internet Safety Policy
7. Service Delivery & Inventory Management
7.1. 7.2. 7.3. 7.4. 7.5. 7.6. Inventory/Asset Registry (Sample Available) Schematic of equipment Receipt of service/ product and installation log (work orders) Replacement Log (replacement or upgrades) Maintenance Log Equipment transfer log
8. Invoicing & Payments
8.1. 8.2. 8.3. 8.4. 8.5. 8.6. Customer Bills Reconciliation Worksheet Service Certifications Proof of Payment of discount and non-discount amounts (cancelled checks, bank statements) Reimbursement from vendor verification (BEAR only) Miscellaneous (memos to vendors, notes to file, emails)
9. Change Requests & Appeals
9.1. 9.2. 9.3. 9.4. 9.5. 9.6. 9.7. 9.8. Appeal Request (Checklist Available) Appeals Delivery Receipt (proof of postmark, fax confirmation) Service Substitution Request (Sample & Checklist Available) SPIN Change Request (Checklist Available) Documentation of Funds Returned to USAC Invoice Deadline Extension Request Service Deadline Delivery Request Transfer of Equipment Notification
10. Miscellaneous
10.1 PIN mailer (For the authorized user) 10.2 Site Visit documentation 10.3 Audit documentation
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Revision 2/2008