jack o’connell state superintendent of public instruction 1 e-rate for california
TRANSCRIPT
JACK O’CONNELLState Superintendent of Public Instruction
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Agenda1. General Program Information2. Technology Plans3. Competitive Bidding and the Form 4704. Form 4715. PIA (Program Integrity Assurance)6. Form 486 & Invoicing7. Program Updates & Gotchas8. Audits, Appeals, Cost Effectiveness and Other Reviews9. USAC Tools – Training Materials, DRT10. California Teleconnect Fund11. Q and AAfternoon1. Form 471 Tour2. Tour of USAC Web Site3. Calnet 2
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The California Department of Education (CDE)
does not administerthe federal E-Rate program.
CDE has no statutory authority to administer the federal E-Rate program
CDE only provides general information about the E-Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources
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Discount Calculations
• Calculated based on two factors1. Percentage of students eligible for
National School Lunch Program http://www.usac.org/sl/applicants/step05/discount-matrix.aspx
2. Urban or Rural status of Entity http://www.usac.org/sl/applicants/step05/urban-rural/
Discount Matrix
% Eligible Students Urban Rural
Less than 1% 20% 25%
1% to 19% 40% 50%
20% to 34% 50% 60%
35% to 49% 60% 70%
50% to 74% 80% 80%
75% to 100% 90% 90%
http://www.usac.org/sl/applicants/step05/discount-matrix.aspx
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Discount Calculationsand Entities
• Instructional Facilities will have a discount that comes straight from Matrix
• Non-Instructional Facilities will use District Weighted Average (District Office, Maintenance, Bus Barn, Gardener’s Shed, etc)
–For use on Block 4 of the Form 471
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Eligibility
• Schools – Elementary, Secondary, Charters, Private, Religious, Adult Ed (conditional), Pre-K, Juvenile Justice
• Libraries – public, separate from school libraries
• Consortia – any combination of the above
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Non-Instructional Facilities (NIFs)
• Are eligible for Priority 1 services, telecommunications and internet access
• Are NOT eligible for Priority 2 services, internal connections, UNLESS they are essential for the effective transport of information to an instructional building of a school or to a non-administrative building of a library
JACK O’CONNELLState Superintendent of Public Instruction
Non-Instructional Facility (NIF)• Scenario One: NIF as a hub. This NIF is
essential for the transport of info to the Schools and is eligible for P2 funding
JACK O’CONNELLState Superintendent of Public Instruction
Ineligible for Priority 2 NIF• Scenario Two: NIF as an end-point. The
schools would maintain service if the NIF were removed, therefore the NIF is ineligible for P2 support
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Eligible Services - Categories
Four categories of service– Priority 1 (funded first)
1. Telecommunications Services
2. Internet Access
– Priority 2 (starts with neediest applicants)3. Internal Connections
4. Basic Maintenance of Internal Connections
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Eligible Services List• Posted on USAC website (
http://www.usac.org/sl/tools/eligible-services-list.aspx)
• Provides guidance to applicants and service providers on the eligibility of products and services under E-rate
• Organized by category of service• Revised and updated each year in
advance of the application window
JACK O’CONNELLState Superintendent of Public Instruction
FY09 Draft ESL updates
• Eligible: – Ethernet– VoIP user licenses
• Ineligible: – E-mail Archiving– Intranet Web Hosting– Video-on-Demand Servers– Softphones
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Telecommunications Service
• The transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received.– Examples: ATM, T-1, Centrex, Local and
Long Distance Telephone Service, Cellular Service and Paging Service
– Rule of thumb:• USAC funds the various types of services• USAC does NOT fund end-user equipment - e.g.,
telephone sets
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Internet Access• Basic conduit access to the Internet
• Examples: T-1, DSL, DS-3, and Wireless service– Rule of thumb:
• USAC funds the conduit to the Internet • USAC does NOT fund content
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Internal Connections
• Components at the applicant site that are necessary to transport information to the school or library.– Examples: Access Points, Routers,
Switches, Hubs, Wiring, PBXs and Codecs– Rule of thumb:
• USAC funds items that get the information to the classroom or room in the library
• USAC does NOT fund end-user equipment such as telephones (including IP telephones) or laptops
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2 in 5 Rule
• Applies to Internal Connections funding requests only– Is entity specific– Implemented in Funding Year 2005
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Basic Maintenance of IC• Ensures the necessary and continued
operation of eligible internal connection components at eligible locations.– Ex: Repair and upkeep of eligible hardware,
wire and cable maintenance.– Rule of thumb:
• USAC funds basic technical support of eligible hardware. (8 X 5, M-F)
• USAC does NOT fund end-user support or help desk
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Basic Maintenance of Internal Connections (BMIC)
• Not subject to 2 in 5 rule• Caution:
– If a contract goes beyond what the FCC defines as basic maintenance, the entire contract will be denied
– Eligible as recurring monthly services, i.e. – SmartNet
– Include the components that the BMIC Contract will cover on your Item 21 attachment
– BMIC can not be 24/7 coverage
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Manage the Cycle - Teamwork
• Authorized signer ( Legally Authorized Signer )
• Designated contact person (Will receive E-rate calls)
• Organize paper trail
– Written Technology Plan
– Assessment of existing Contracts, with signatures and dates (expiring contracts, etc)
– Prior years submitted applications
– Correspondence from SLD, Service Providers, etc.
– All bids received and evaluation documents
– Calendar of Deadlines
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Technology Plan Overview1. FFC rules require an “approved” technology plan when receiving E-
rate for more than basic telephone service.
2. Must be “written” prior to posting Form 470.
3. Must cover all 12 months of the funding year.
4. E-rate only plans should not cover more than 3 years; EETT tech plans that meet E-rate requirements can cover 5 years with progress review during 3rd year for E-rate purposes.
5. Must include all services that the E-Rate discount covers.
6. Must be approved by a “Certified Technology Plan Approver Locater Tool” Technology Plan approver locator tool: http://www.sl.universalservice.org/reference/tech/default.asp
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5 Required Elements of a Technology Plan
1. Goals
2. Professional Development
3. Needs Assessment
4. Budget
5. Evaluation
Tech Plans for E-rate:E-Rate Only Plan:1. Goals & a Realistic
Strategy2. Professional
Development3. Needs Assessment4. Sufficient Budget5. Evaluation Process
• Tech Plan Helpwww.usac.org/sl/applicants/step02/
EETT Plan for E-rate:• Executive Summary/Introduction• Stakeholders• Curriculum • Professional Development • Infrastructure• Adult literacy • Research • Funding and Budget• Monitoring and Evaluation• Must also include E-Rate
supplemental budget analysis … and also see:
www.cde.ca.gov/ls/et/rs/techplan.asp
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Tech Plan “Written”
• Written same as created: When a tech plan contains all required elements to support services requested on Form 470 – USAC considers the plan written.
• Must document and keep evidence of written date prior to filing Form 470 by e-mailing plan to Assistant Superintendent, memo with date announcing that tech plan is written, “date stamp”
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Documentation of Tech Plan Approval
1. E-rate only tech plan: – You can expect to receive an approval letter
from your COE or State Library as the USAC-certified technology plan approver. Ask your COE/State Library for projected approval date.
2. EETT tech plan: – You can expect to receive an approval message
via email from CDE that confirms your EETT tech plan has been approved.
– In general, CDE will make a determination regarding the approval of your EETT tech plan within 60 to 90 days of due date for review cycle (Cycles A, B or C).
View Tech Plan approval status at: http://www.cde.ca.gov/ls/et/rs/ap/county.asp
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EETT Tech Plan Approval
• Due dates (cycles) for submission of EETT Technology Plan to CTAP for approval:– Oct 3, 2008 Cycle A (Best practice)– Dec 5, 2008 Cycle B– April 3, 2009 Cycle C
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Important Tech Plan Reminders
• Include a supplemental budget analysis if using EETT plan as your approved E-Rate tech plan – form located at: www.cde.ca.gov/ls/et/rs/techplan.asp
• Ensure all E-rate requested services/products are included in your technology plan
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Technology Plan Help• SLD -
http://www.usac.org/sl/applicants/step02/• Libraries -
http://www.library.ca.gov/services/libraries/erate.html
• CDE - http://www.cde.ca.gov/ls/et/rs/techplan.asp
• CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp
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Contact Information• State Library: Rushton Brandis,
(916) 653-5471, [email protected]
• CDE: John Vardanega,
(916) 323-2241, [email protected] • CDE: Tech Plans: Bill Fong,
(916) 322-5898, [email protected]
• Department of General Services (CMAS): Mary Gilbert, (916) 375-4377, [email protected]
• K-12 HSN/Butte COE: Russ Selken, 530-532-5678, [email protected]
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Technology Plan Help• SLD - http://www.usac.org/sl/applicants/step02/
• Libraries - http://www.library.ca.gov/services/libraries/erate.html
• CDE - http://www.cde.ca.gov/ls/et/rs/techplan.asp
• Recent News Brief from SLD - http://www.usac.org/sl/tools/news-briefs/preview.aspx?id=116
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Preparation for Posting of Form 470
• Document ALL of your eligible existing services, contracts and their expiration dates
• Identify existing contracts and services
• Expected growth – (P1 and P2)• National School Lunch Program
(NSLP) data for discount percentage• Identify bidding restrictions (i.e.,
CMAS, geographic restrictions, etc.)
JACK O’CONNELLState Superintendent of Public Instruction
Forms 470• Indicates the services and categories
of service which you are seeking discounts
• Must be based on tech plan• Must be posted for 28 days • Indicates if you are planning/have
issued RFP– Can only correct this by posting new
Form 470
• Indicates any special requirements and/or disqualification factors
• Indicates who will be receiving the services
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File Online!
• Once the Form 470 is posted you must1.Certify online using a PIN, OR2.Print the certification page, sign and
mail• Mail this form immediately
• View form online to get the Allowable Contract Date
– Also provided in the Receipt Acknowledgement Letter
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Special Notes for Form 470 Processing
• When does the 28 day bidding period begin?1. The day that ALL material for public
viewing (i.e. RFP) is made available
AND
2. The day the Form 470 is posted online
– If RFP is released AFTER the posting of the Form 470 the 28 day bidding period begins with the day the RFP was released
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Form 470 Reminders
• Allow adequate time– Competitive Bidding – minimum of 28 days– Local Procurement– Board Approval– Signing Contracts
• CMAS - Letter of Intent (LOI)• CALNET 2 – 3 signatures needed
• Understand– Your existing services– Products and services you will need in the coming year
• Identify E-rate category for each product and service, P1 or P2
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Receipt Notification Letter (RNL)
• GOLDEN Opportunity to review application and correct minor errors
• http://www.universalservice.org/_res/documents/sl/pdf/sampleletters/470RNL.acc.pdf
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Competitive Bidding• Fair and open competitive bidding
process• Avoid conflicts of interests
–Independent Consultant vs. Service Provider
–Applicant vs. Service Provider• Follow the rules – FCC, State and local• Read the contract fine print• Document the process!!!
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Competitive Bidding and Program Compliance
• http://www.sl.universalservice.org/reference/BestPractices.asp
– Keep copies of all bids, winning and losing– Documentation on the award process and the
rationale for the bid award– Complete copies of all related contracts
• Best Practice: Use standard evaluation process for all bids. Keep evaluation documentation for each bid.
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Program Compliance
• If you get NO bids – document this for audit purposes
–Same is true if you get only ONE bid
• You may need to be proactive in soliciting for bids (If not using CMAS)
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Evaluation CriteriaPrice must be the most heavily weighted factor•Do not include Intent to Award or Evaluation Criteria in CMAS Request for Proposal•Can choose most responsive and responsible response, but must DOCUMENT the choice and process•Have District official SIGN and DATE the completed rubric as acknowledgement
Vendor A Vendor B
Raw Weighted Raw Weighted
Selection Criteria
Weight* (%) Score** Score*** Score Score
Prices/Charges 40% 1 0.4 2 0.8
Understanding of Needs 15% 2 0.3 1 0.15
Prior E-Rate Experience 10% 2 0.2 1 0.1
Prior District/Service Prov experience
10% 2 0.2 1 0.1
Completeness of Response 15% 2 0.3 1 0.15
References 10% 2 0.2 1 0.1
Overall Ranking 100% 1.6 1.4
SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE
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Form 470 – Multi Year Contracts
• You may not need to file Form 470 every year if:
– The language on the Form 470/RFP covered all services on the contract AND
– The applicant indicated on the Form 470 that a contract was being sought AND
– The applicant indicated on the Form 470/RFP that a multi year contract (perhaps w/voluntary extensions)
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Contracts
• Must be signed AFTER 28 days have elapsed but BEFORE you file your Form 471
• Must be signed and dated by BOTH parties – applicant and service provider– CALNET 2 ATO must have three signatures to
be binding contract
• Be prepared to explain documents that don’t look like a traditional contract.
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Form 471 – Your application for Funds
• Must be filed every funding year:• This is your actual funding request• Based on posted on Form 470(s)• One or more funding requests• This is your Who, What, When, Where, &
How–Service providers chosen–Services being requested–Dates for services–Service Delivery locations– Signed contracts or tariffed services
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Form 471 Filing Deadline
• The Window for the Form 471 filing window has not been announced yet.
• If you are on CDE E-rate List SERV, you will be notified when FCC determines filing deadline, which then determines Form 471 filing deadline
• If you receive USAC weekly newsbriefs, notification will be published there.
• Must be submitted BEFORE close of window• [email protected]• http://www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp
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Form 471 Filing Deadline
– Submit BEFORE close of window
• DEADLINE DATE = ??
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Form 471 Best Practices–Get a Partner–Do your own Timeline of milestones–File Online–Certify BEFORE close of window
•Online if using PIN•By trackable mail if you do not use your PIN
–File EARLY!!–Do everything before Deadline–Allow enough time to fully complete
process & paperwork–Organize your paperwork
JACK O’CONNELLState Superintendent of Public Instruction
Keep Your Dates in Order
• Remember the correct order for dates:– Allowable Contract Date (28 days after
470)THEN
– Contract Award DateTHEN
– Form 471 filingTHEN
– Form 471 Certification dateALL BEFORE
– Window close
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Form 471
• Apply Online = http://www.sl.universalservice.org/menu.asp
• Form 471 Test page = http://usactrain.solixinc.com/TrainingSiteWarning.asp?
JACK O’CONNELLState Superintendent of Public Instruction
FORM 471 DON’TS
•DON’T file Priority One and Priority Two funding requests on the same Form 471•DON’T forget to wait at least 28 days after any mandatory processes associated with your competitive bidding before selecting a service provider or signing any contracts•DON’T submit your Form 471 BEFORE signing all related contracts•DON’T forget to CERTIFY your submitted application (whether electronic or paper certification)
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Form 471 Reminders• Separate your Priority 1 and Priority 2
funding requests onto separate Form 471s.
• Verify that you are using correct establishing Form 470 number on each Block 5 Funding Request.
• Choose the correct category of service (e.g., Telecom, Internet, etc.)
• Check your math, check it again• Review your application• Validate the information
JACK O’CONNELLState Superintendent of Public Instruction
Pre-Commitment Review
Things to do before PIA contacts you
• Submit your Item 21 Attachments online or paper.
– Place application number(s),FRN(s), Attachment ID, and page numbers on Item 21 Attachments
– Indicate Bandwidth when you are requesting telecom or Internet access
– Indicate the entities receiving services and locations
– Clearly label ineligible items and costs– Indicate product make and model for each product
requested– Provide a detail product or service description
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Item 21 Attachment
• Samples available on USAC website– http://www.sl.universalservice.org/
reference/Form471item21Attachments.asp
• Remove ineligible costs – be careful– 30% rule –30% or more of funding
request dollar value cannot be for ineligible products and services. the entire request may be denied unless…
– Can be rectified during your PIA process: Remove it-Split it up- separate FRN
• Work with service provider(s) to create your Item 21 attachment(s)
JACK O’CONNELLState Superintendent of Public Instruction
Reciept Acknowledgment Letter Process
• Opportunity to verify information one more time
• Three weeks from date of letter to submit corrections
http://www.usac.org/_res/documents/sl/pdf/sampleletters/471RAL.pdf
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One Last Chance….
• ** Bishop Perry Order – 15 day grace period for certifications made after the deadline http://www.usac.org/_res/documents/sl/pdf/List-of-Correctable-Ministerial-and-Clerical-Errors.pdf
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Program Integrity Assurance (PIA)
• Applications are reviewed for compliance with program rules concerning areas such as:
– Properly executed contracts– Discount calculation– Establishing Form 470– Eligibility of services being requested– Eligibility of entities requesting discounted
services– Proper completion of all of blocks/item 21
JACK O’CONNELLState Superintendent of Public Instruction
PIA Reviewer
• Be nice to your reviewer – even if they are not nice to you!!!
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Be Responsive• Respond promptly, be sure to answer
questions in their entirety• Document communication with PIA,
send e-mail to PIA as a confirmation of your phone conversations
• Ask for more time if you need it– Be advised that if you ask for more time
the Reviewer will move on to another application
• Don’t assume that Reviewer has all of the information you sent in as part of your Item 21 attachment.
JACK O’CONNELLState Superintendent of Public Instruction
If corrections are needed• Services Cost Allocations
– Work with the service provider to identify the ineligible services, so they are clearly identified
– On the Item 21 Attachment identify the ineligibles services and associated costs
– Prepare a “revised” Form 471 Block 5 to reflect the cost allocations
• Best Practice – Break out FRN with PIA’s assistance
• Entity Removal– On the “original” Form 471 Block 4 worksheet
identify the entities to be removed– Prepare a “revised” Form 471 Block 4 worksheet if
new discount calculations and student counts– On the Block 5 funding request, indicate your
revision to the dollars requested based on the share of the funding request for the entities being removed
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What Happens After PIA Review
• A Decision – FCDL (Funding Commitment Decision Letter)
– Funded– Not Funded– As Yet Unfunded (Priority 2 requests)– Cancelled – IMPORTANT – Check all entries in the
FCDL carefully to make sure there are not data entry errors.
JACK O’CONNELLState Superintendent of Public Instruction
Post-Commitment
• Review the FCDL for Accuracy– Read the FCDL comment to
determine if modifications have occurred to the FRN to ensure you invoice for the correct services.
– Verify SPIN, discount, fund request, start and end dates, and contract number (if applicable)
– If you disagree with the decision, you may file an appeal.
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What next?
• FCDL should be your “trigger” to file subsequent forms
• Starts deadline clock for appeal on denial(s)
– Note: Appeals must be done within 60 days of the date of FCDL
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Purpose of 486• Notifies USAC that entity is ready to receive
services, services have started or are scheduled to start and invoices can be paid
• Certifies that Tech Plan is approved and meets program requirements
• Certifies status of compliance with Children’s Internet Protection Act (CIPA)
• Do NOT miss Form 486 deadline for your district; LATE FILINGS WILL LOSE $$
– http://www.universalservice.org/sl/applicants/step10/form486-filing-information.aspx
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What is the Form 486 deadline?
– Filed AFTER receipt of FCDL – Form 486 must be filed online or postmarked no
later than• 120 days after the Service Start Date OR• 120 days after the date of the FCDL
– Whichever is later
– Grace period from USAC – SLD will send letter giving reminder to file Form 486 – (Alaska Gateway order)
• Take this letter seriously; you have 20 days from date of the SLD letter to take action!
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Form 486 Compliance Review
• USAC may review Form 486 for compliance with program requirements for technology planning before the form is successfully processed.
• If Form 486 undergoes review, USAC does not issue a Form 486 Notification Letter until all compliance issues have been resolved. (i.e. Approved Tech Plan)
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Form 486 Notification Letter (486NL)
• Letter received after filing of Form 486
– Verify that ALL FRNs are on letter– Verify service start dates for each FRN
• USAC is now ready to begin receiving invoices for payment on these FRNs
– Form 472 – filed by Applicant OR– Form 474 – filed by Service Provider
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Receipt of Funds
• One of two ways:– Applicant pays entire bill up-front and
gets reimbursed• Form 472 (BEAR) – BEAR submitted by
Applicant– Service Provider applies discounts to bills
and submits invoices to USAC for reimbursement
• Form 474 (SPI) – filed by Service Provider
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Special Note on Form 472
• Note – Form 472 (BEAR) cannot be filed if applicant is also receiving California Teleconnect Fund (CTF) discounts on same services.
• Applies only to Telecommunications (data-voice)
– Internet services may also be eligible for CTF discounts
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Important Reminders•Print and retain copies of everything
•Keep E-Rate files organized
•Create a timeline of E-Rate deadlines
•Share this information with others at your site
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Forms• Form 470
– Be careful when specifying services – Understand the categories of service– Can combine all services that cover Priorities
1 and 2 on the same Form 470
• Form 471– File separate forms for Priorities 1 and 2– File separate forms for different discount
bundles
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California Pre-K and Adult Ed
• These student populations are eligible for E-Rate discount in California except
• Adult Ed. enrichment VS secondary curriculum• Children under age of 3
• Treat same as traditional classrooms or facilities
• Obtain entity numbers and establish poverty level
• Head Start is 90%• May use alternative discount methods
• Be sure to add their plans to your District technology plan to ensure compliance
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Non-Instructional Facilities Priority Two GOTCHA
Educational Purposes – Priority 2–Priority 2 services to Non Instructional
Facilities (NIFs) are eligible ONLY IF those internal connections are essential for the effective transport of information to an instructional building of a school or to a non-administrative building of a library.
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2 in 5 Rule for IC• Determined on an individual entity basis or
shared worksheet (bundle)• All entities on a Block 4 worksheet that
utilize approved funding for IC, are counted as taking a year
• 2009 is the fifth year for the rule (if applicant applied in 2005)
• Must file Form 500 to cancel FRN if approved and not utilized
• Establish a matrix for tracking the UTILIZATION of funds for approved goods or services
• USAC tool does not track pending or utilized, just funded
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October Important Deadlines
• Complete your BEAR for 07-08 prior to Oct 28th, 2008
• Pay attention to 486 deadlines, Due 120 days after FCDL (Note: this is due Oct 28th if you received your FCDL for 08-09 on or prior to July 1st)
• Have your tech plan written PRIOR to posting your Form 470 for 09-10 if it expires June 30th 2009 or sooner
• File your Form 470 for 09-10 NOW!
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8. Audits, Appeals, Cost Effectiveness and Other Reviews
JACK O’CONNELLState Superintendent of Public Instruction
Compliance Attestation Examination
• AKA “The Big Audit”
• Directed by the FCC’s Office of Inspector General (OIG)
• Randomly selected by FCC
• Annually between November and July 1st
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JACK O’CONNELLState Superintendent of Public Instruction
Compliance Attestation Examination
• Examine payments made during a single fiscal year – May include examination of MUTIPLE funding years!
• Conducted by third party auditing firms who may be on-site 2 to 8 weeks
• Purpose: Did applicant comply with FCC rules? (not just looking for waste, fraud, and abuse)
• Applicant must be able to prove compliance with rules
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JACK O’CONNELLState Superintendent of Public Instruction
Examples of Rule Violations that Warrant Recovery of Funds
• Insufficient documentation of the competitive bidding process
• Lack of necessary resources – equipment not fully utilized
• Service substitutions not meeting criteria established in the rules
• Failure to pay (or show proof of payment) of non-discounted share
• Failure to complete services within funding year
• Discount calculation violation
• Technology Plan not approved and/or not containing required elements and requested services
• More specific examples located on USAC Audit training slides located at:
http://www.universalservice.org/sl/about/training-presentations/training-presentations-archive/training-2008/fall/
materials.aspx86
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How To Prepare For The Audit
• Follow All E-rate Rules• Retain – Retain – Retain – Lessen your
pain!!• Document, Document, Document!
• Plan ahead for an audit by documenting every step of the process
• Create an E-Rate Binder for EACH funding year
• USAC Compliance Documentation Checklist for audits
• http://www.usac.org/_res/documents/sl/pdf/CompDocChecklist.pdf
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Who Should Be Available During Audits?
• Person(s) who – filed the E-rate forms– managed the bidding and award process– reviewed and approved invoices– prepared E-rate invoices– is responsible for budget (CBO)– Is responsible for NSLP documentation– is knowledgeable about the network and the
location of equipment• Appoint a single contact person who can manage
interactions between auditors and staff members
JACK O’CONNELLState Superintendent of Public Instruction
Document Retention Requirements
• Keep for 5 years after last date of service– Be aware of contract dates and extensions as
the 5-year minimum may be extended– All USAC correspondence, including
Quarterly Disbursement Reports
• Make sure all departments understand documentation retention requirements for E-Rate
• Align Board policy with E-rate requirements
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Technology Plan Documentation
• Copy of Technology Plan that covers entire year being audited (should be part of your ANNUAL e-rate documentation)
• Copy of Draft and creation date documentation
• Proof of approval of Technology Plan• Supplemental Budget analysis (if using
EETT Plan)• Summary of the technology
environment and a high-level network diagram
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Bidding Documentation
• Copy of State and Local procurement policies• Form 470 and all request for bid documentation
• RFP/RFB/RFQ, announcements, advertisements, addendums, etc…
• ALL correspondence between applicant and service providers (email, phone log, job walk sign-in sheet, etc…)
• Copy of all bids received (winning and losing)• Document if NO bids are received
• Bid evaluations• Notice of Award to winning vendor
• Contract• Board Award• Copy of any change orders
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Invoicing Documentation
• Proof of payment to service providers• Copies of warrants or cancelled checks, check register
• Auditors will ask for reconciliation of payment by invoice
• Copies of all invoices, phone bills •Invoices should be detailed
• Copies of BEAR Forms• Reconciliation (by FRN) of service provider
invoices to BEARs submitted to SLD (removal of all ineligible costs)
• Copy of reimbursement check from service provider to prove receipt of E-rate funds if applicable
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Priority Two Services Documentation
• Equipment purchased using E-Rate• Detailed vendor invoices• Packing slips showing date of delivery• Walk through or sign off that shows when
services were delivered• Asset register see detailed USAC example
• http://www.usac.org/_res/documents/sl/pdf/2007_training/samples-checklist-inventory-list.pdf
• Well-marked equipment• Service Substitution• Equipment Transfer documentation
• Basic Maintenance• Maintenance log
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CIPA Documentation
• Internet safety policy• Local governing board adoption of the
Internet safety policy• The date and a copy of the minutes of the
public hearing regarding the Internet safety policy [Local Board adopted policy]
• Internet filtering reports• Copies of invoices for Internet filtering
services• Copies of Forms 479 and/or Forms
486, if applicable
JACK O’CONNELLState Superintendent of Public Instruction
Discount Documentation• NSLP Method
– Proof of discount calculations including source data and reports
– Auditors may ask for a sampling of actual NSLP applications
– USDA and FCC agreementhttp://www.fns.usda.gov/cnd/Governance/Policy-Memos/
2008/SP_29-2008.pdf
• Alternative Methods– Keep copies of every survey and a summary
report– Source data and annual poverty guidelines
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Other Documentation
• SPIN change requests including copy of notice to original service provider
• School closure, consolidation or construction documentation
• ALL communication regarding E-Rate• Service Providers• SLD/USAC
• Case Numbers• PIA questions and responses
• Documentation of other services necessary to make effective use of E-rate discounts, such as
• Training• End user equipment
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Other Documentation
• Reports from any other audits conducted that relate to either E-rate program or the NSLP
• Eligible Services List for every funding year• Board minutes and policies relating to
document retention or other E-rate related issues
• Financial statements and annual budgets
JACK O’CONNELLState Superintendent of Public Instruction
Other Levels of Scrutiny
• Site Visits
• Selective Review Information
Request (SRIR)
• Cost Effectiveness Review
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JACK O’CONNELLState Superintendent of Public Instruction
Site Visits• Single FRN reviewed• On-site 4 hour visit• Review of
– Asset register– Equipment in the field– Staff development– Invoices/payments– Technology plan approval– Competitive bidding
• Best practices feedback100
JACK O’CONNELLState Superintendent of Public Instruction
Item 25 Selective Reviews
• PIA on steroids• Intensive review of the “Item 25” Block 6
certification from Form 471• Complete documentation of necessary
resources • hardware, software, professional development, retrofitting, maintenance
• Competitive bidding documentation• Technology Plan• Budget – matching funds and support for non
E-rate items
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JACK O’CONNELLState Superintendent of Public Instruction
Cost Effectiveness Review
• Occurs during PIA• Must be able to justify that the selected solution is ‘cost effective’, not just the MOST cost effective• Bright line test:
•Routers that cost two to three times the commercially available price
• Single bid received does not equal cost effective• Think about reasons why the price may be inflated
• Location• Structural challenges• Anticipated growth of student population, etc
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Appeals
• Submitted to USAC if you feel program rules were not upheld by the denial of funds
• Submitted to FCC if you are questioning the existing program rules or if USAC denies the initial appeal
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USAC Appeals –Approved for Limited
Circumstances• When the appeal makes it clear that USAC
erred in its initial review• When the applicant provides USAC with
information it did not provide when the original request was made
• When USAC obtains policy clarification or new policies that impact the original decision
• http://www.usac.org/sl/about/appeals/appeals-guidelines.aspx
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9. Tools – Data Retrieval Tool and Other
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Data Retrieval Tool
• Comprehensive data regarding status of applications, past and present– Search by Funding Year, Entity number, State, Type of
Service, etc– Provides deadline information for forms– Columns to look at on the DRT for deadline information
• B: 471 Status• E: 470 Status• P: Commitment Status (If funded then look at R to
see if 486 has been filed)• R: 486 SSD (If blank, no 486 on file)• T: FCDL date (this date + 120 calculates the
deadline for the Form 486)• AX: BEAR or SPI
– www.usac.org/sl
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View Prior Years’ Applications
• www.usac.org/sl– Apply Online
• Form 470 – Search Posted• Form 471 –
– Application Status (if you don’t know the application number)
– Display (must have application number)
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Contact Information• State Library: Rushton Brandis,
(916) 653-5471, [email protected]
• CDE: John Vardanega, (916) 323-2241, [email protected]
• CDE: Tech Plans: Bill Fong, (916) 322-5894
• K-12 HSN/Butte COE: Russ Selken, 530-532-5678 [email protected]
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CALNET 2 - What is it and how does it fit with E-rate?
• Contract (s) held and administered by State– CALNET 2 Contract effective date:
1/30/2007– CALNET 2 contract expiration date:
1/29/2012• Master contract purchasing vehicle for all
telecom services• Available to all “Public Sector” Customers• Competitively bid contract - Result of an 18
month bid process (already bid)• Full range of products and services• Service Level Agreements
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CALNET 2 MSAs• All four MSAs were signed on January 30, 2007
• Each MSA is for a 5-Year Term (to January 29, 2012) with the Potential for 2 One-Year Extensions at the State’s Option (2014)
• Each MSA is a separate contract called CALNET 2, along with their MSA number. They are also collectively called CALNET 2.
• Until CALNET I expires you will see “I” and “II” or “1” and “2” after the word CALNET to try to avoid “Contract Confusion”
• In some cases you will see just “CALNET” - that will mean both CALNET I and CALNET II as applicable; as CALNET I phases out, it will mean CALNET 2
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CALNET 2 MSAsMSA 1 – Voice, Data & Video Services – AT&T
MSA 2 - Long Distance and Network Based Services – AT&T
MSA 3 – Internet Protocol Voice, Data, and Video Services – Verizon Business (VzB)
MSA 4 – Broadband Fixed Wireless Access Data Services – VzB
10% Lower Pricing Overall From CALNET I
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CALNET 2 MSAs
Transition of Existing CALNET Services to MSAs I & 2 – No Cost Transition Out Will Eventually Impact Your Agency; CALNET I Expires by 12/03/08 based on Individual ATO Agreements
CALNET 2 – Each ATO is for a Two Year Term – When Term is Up, Can Use the MSAs Without another ATO For Those Services on the ATO; Adding Services Requires New ATO, New term
New Pricing Starts Within 120 Days of Each Approved CALNET 2 ATO
http://www.dts.ca.gov/stnd/calnet-transition.asp
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CALNET 1 to CALNET 2• State Posted Form 470 267290000544188 on Sept 15,
2005– Includes Telecommunications Services– Did NOT Include ISP – Limited Internal Connections (extended demarc)– CALNET 2 Contract was signed on January 30th, 2007
(State Master Contract)
– CALNET 2: http://www.dts.ca.gov/stnd/calnet-II/calnetII.asp – RFP: http://www.dts.ca.gov/stnd/calnet-II/revised-calnetII-rfp.asp
• May wish to post your own form 470 for all services you will apply for (See additional hand-outs)
• Do your own analysis to determine best choice for your agency
• Three Signatures are required on a CALNET 2 contract
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CALNET 2 MSAs 1 and 2 includesMSA 1• High Speed Optical
Services (Enhancements and Additional Services) – ATM– Opt-e-MAN – CSME
• Enhanced Data Services– MPLS (AVPN)– Remote VPN (Anira)– Interlata Data Services
• Internet Services• Unified Messaging• Enhanced Centrex Features
– VoIP• Business Centrex lines • Voice mail • Local trunks • Frame relay
MSA 2• Enhanced Toll
Free• Long Distance
Voice• Audio
Conferencing• Net Conferencing• Complete Suite of
Call Center Capabilities– ACD– IVR
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IP Voice, Data, and Video Services (MSAs 3 & 4)
Internet Protocol (IP) based solutions to provide voice, video, and data services
• Voice Over IP (VOIP) Services
• Converged Services – VOIP
• Converged Services - IP Transport
• Converged Services - Required Premise Equipment
• IP Contact Center Services
• Other IP Services• Wiring and Support
Services
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SLD Guidance for E-rate Yr 11
• See Page 5 of SLD Decision Grid for SLD guidance (handout and next slide)
• Clients either: – post own Form 470 OR – use State’s Form 470
#267290000544188, posted on 9/15/2005.
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How to decide if schools/libraries should post their own Form 470?
1.Are the services you are seeking included in State’s RFP?
2.Are services you are seeking included in State’s Form 470? A. Telecommunications services (Priority 1 services)B. Limitations to State’s Form 470:
• Form 470 did not include Internet Access• Form 470 included Internal Connections defined as:
Service or Function: Extended D-Marc • Form 470 did NOT include Basic Maintenance on
Internal Connections (Priority 2 services)• You can do a specific form 470 if the service
you need is not covered by the state form 470 (see the limitations described above as examples)
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Moving from CALNET to CALNET 2 “Steps in Ordering”
Work with your Account team to sign ATO & create product list attachment
• To be legal binding contract, CALNET 2 contract requires 3 signatures: customer + AT&T + State – ATO – Attachment to ATO (product list attachment for
svcs to be covered by ATO) has to be initialed by customer
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CALNET 2 – Multiple SPINS
CALNET 2 awarded to two service providers
•Each Service Provider may have multiple SPINs
•Verify SPIN with service provider BEFORE filing the Form 471
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CONTACTS• CALNET Transition Questions and Requests for
Information – Phone: (916) 657-9150– Email: [email protected]
• CALNET Transition Homepage– URL: www.dts.ca.gov/stnd/calnet-transition
• Statewide Telecommunications and Network Division Homepage – URL: www.dts.ca.gov/stnd
• Department of Technology Services Homepage – URL: www.dts.ca.gov
DTS-STND and Contractor’s CALNET Homepages, etc. www.calnet.ca.gov
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CALNET 2 Contract Resources AT&T
www.CALNETII-Info.com• Customer Sales & Support Center:• 877-972-6279
• CALNET Billing:• 877-9-CALNET, 877-922-5638
• Account Team:– Contact your account team– Bev Agron, E-rate Specialist (925) 824-
0615
• calnet.ca.gov (select AT&T logo)