E-rate - Get those dollars back to Arizona! Process overview

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Brett HintonAZ Dept. of EducationMala
MuralidharanAZ State Library Archives and
Public Records Modified from Train-the-Trainer
Workshops

• E-rate - Get those dollars back to Arizona!
• Process overview

Video Tutorials at http//usac.blip.tv/

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Overview

• General information about E-rate
• Technology planning
• Request services (Form 470)
• Competitive bidding
• Choose/contract for services (Form 471)
• Application review funding commitments
• Start services (Form 486)
• Invoice USAC (Form 472 or Form 474)

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General information

• Federal Communications Commission (FCC), an
  independent U.S. government agency, oversees the
  E-rate program
• Universal Service Administrative Company (USAC),
  a not-for-profit, administers E-rate along with
  three other programs
• Schools and Libraries Division (SLD) is the part
  of USAC with responsibility for E-rate

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General information

• FCC sets rules and policies through orders
• Rules are compiled in the Code of Federal
  Regulations (CFR)
• Policies are defined in the text of orders
• USAC/SLD sets procedures for specific actions,
  such as how to process applications
• USAC sends its procedures to the FCC for approval
  each year

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E-rate? What is it?

• E-rate Program provides reimbursements to
  eligible schools and libraries for
• Telecommunications Services
• Internet Access,
• Internal Connections
• Basic Maintenance
• Applicants must apply each year
• Reimbursements are based on the poverty level and
  the maximum one can get back is 90 of your
  billed amount
• Funding cap each year is 2.25 billion

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Telecomm Internet Internal connections IC
Maintenance
FCC
2.25 Billion
USAC
Funding Waves
Submitted each Quarter
Schools
Library
Vendors
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Timetable

• Form 470 File from April before the Window to 28
  days before the Window closes
• Form 471 Must be filed during the Window,
  generally mid-November to early February before
  the start of the funding year
• Funding waves Groups of funding decisions issued
  after USAC review waves generally start in
  April before the start of the funding year
• Invoices Can file after services are received
  for the funding year.

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General information

• Who can apply?
• Schools and school districts
• Libraries and library systems
• Consortia groups of eligible entities that band
  together to aggregate demand and negotiate lower
  prices

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General information

• How large are the discounts on eligible products
  and services?
• Discounts 20 to 90 of eligible costs
• Discount for a school or library depends on
• Percentage of eligibility of students for
  National School Lunch Program (NSLP) in
• (for a school) the school
• (for a library) the school district in which the
  library is located
• Urban or rural location of the school or library

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General information

• What services are eligible?
• Priority 1 (funded first)
• Telecommunications Services
• Internet Access
• Priority 2 (funded beginning with neediest
  applicants first)
• Internal Connections
• Basic Maintenance of Internal Connections

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General information

• How do I file a program form?
• In general, you have three options
• File online, certify online
• File online, certify on paper
• File and certify on paper
• USAC encourages you to file online
• Online filing speeds processing and reduces errors

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What is sent and received
Applicant to USAC -gt Letters received
from USAC
Technology plan created but not sent

• Form 470
• Form 471
• Form 486
• Form 472

• Receipt Notification Letter (RNL)
• Receipt Acknowledgment Letter (RAL)
• Funding Commitment Decision Letter (FCDL)
• Form 486 Notification Letter (486NL)
• BEAR Notification Letter Form 472 only

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1. Technology planning

• You must write a technology plan that contains
  the following elements
• Goals and strategies for using technology to
  improve education or library services
• Staff training/ Professional Development
• Needs assessment
• Budget
• Evaluation plan
• Note if you are only requesting basic telephone
  service, a technology plan is not required

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Necessary Resources

• Does the applicant have the resources needed to
  provide the service
• Are there end user computers?
• Must have reasonable plans to fully utilize all
  internal connections for which you are requesting
  discounts
• Do you have software to run on the computers?
• Staff trained on how to use the technology?
• Electrical capacity?
• Can you maintain the eligible and ineligible
  equipment?

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Budget

• This is an important part of the Tech plan and
  the purpose is to show USAC that the applicant
  can fund their share
• Operating budget (or draft) has dates that cover
  the funding year (July June)
• Budget documentation should have clear expense
  line items not all bundled together
• If budgets are not passed at that time, can
  provide letter for reasonable expectation that
  funds will be secured by 7/1

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Non-Discounted portion

• Obligation to Pay Non-discount Share
• Applicants are required to pay their share of the
  cost (the non-discount portion or share) this
  share cannot be donated, forgiven or ignored.
• Service providers cannot waive or credit the
  applicants share.
• Service provider must bill the applicant for
  non-discount share of services. If applicant
  cant show proof of payment during invoice
  review invoice may be denied.
• Deferred payment plans that allow the applicant
  to pay after USAC has paid will jeopardize a
  funding request.

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Free Goods and Services

• Applicants and service providers are prohibited
  from using E-rate to subsidize the procurement of
  ineligible or unrequested products and services
• E-rate cannot be used to get free stuff or
  kick-backs. The value of ineligible products that
  are needed to run the service have to be backed
  out in your vendor selection process.
• Cost of eligible goods and services cannot be
  inflated to cover thefree ineligible stuff

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Technology plan approval

• Technology Plan Approver (TPA) the agency
  certified by USAC that approves your technology
  plan
• It has to be written (drafted) before the filing
  of the Form 470, finalized and approved before
  the start of services.
• Can be multi-year but major changes have to be
  re-approved

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Tech Plan Validity
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Technology Planning Dos and Donts

• DO
• draft your technology plan before Form 470.
• verify that it contains all five required
  elements.
• make sure your technology plan covers at least 12
  months
• make sure that your technology plan approver is
  certified by USAC.
• verify that plan is approved before services
  begin and before your Form 486 is filed.
• PRINT A COPY of your Tech Plan for your records.
• PRINT A COPY of your approval for your records.
• DO NOT ask the service provider direct advice on
  technology planning.

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Questions?
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2. Request services (470)

• You post a Form 470 to
• Open a competitive bidding process
• Notify potential bidders (service providers) of
  the types and quantities of services that you
  need
• Define the scope of your needs (e.g., a school
  building, a library system, a state network)

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2. Request services (470)

• Acronyms and terms
• Billed Entity Number (BEN) an identification
  number assigned by USAC to each school or library
  building
• Personal Identification Number (PIN) a code
  assigned by USAC to applicants for use in
  certifying program forms online
• USAC issues a PIN to every new authorized person
  filing a paper Form 470, 471, or 486
• Request for Proposals (RFP) a bidding document
  (not required by E-rate) that provides detailed
  information about your services, locations, bid
  submission requirements, etc.
• Allowable vendor selection/contract date (ACD)
  the date 28 days after the Form 470 is posted to
  the USAC website

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3. Competitive bidding

• When you open a competitive bidding process for
  your services
• Potential bidders have the information from your
  Form 470 and RFP and can respond to your requests
• You must ensure that the competitive bidding
  process is open and fair
• You must be prepared to evaluate bids

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3. Competitive bidding

• After you close the competitive bidding process
  for your services (on or after the ACD)
• You can evaluate the bids received
• You can choose your service provider(s)
• You can sign a contract
• You can post a Form 471
• Price as the primary factor In evaluating bids,
  the price of the eligible products and services
  must be the most heavily-weighted factor in your
  evaluation of bids

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Calculate the discounts

• Reimbursements are based on Discounts calculated
  using
• Percentage of students eligible for National
  School Lunch Program (NSLP)
• Urban or rural status of county in which school
  or library is located (see USAC web site)
• http//www.usac.org/sl/applicants/step05/urban-rur
  al/default.aspx
• These two pieces of information are carried into
  the Discount Matrix

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4. Choose services (471)

• You post a Form 471 to
• Report information on the service providers and
  services you have chosen
• Provide a list of the schools and libraries that
  will receive services
• Include discount calculation information
  including student NSLP counts
• Certify your compliance with program rules

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4. Choose services (471)

• Acronyms and terms
• Funding Request Number (FRN) the identification
  number assigned to a Form 471 Block 5 funding
  request
• Service Provider Identification Number (SPIN)
  the identification number assigned by USAC to a
  service provider
• Service providers may have more than one SPIN in
  order to identify separate business units,
  different states in which they operate, etc.
• Non-instructional facility (NIF) a school
  building with no classrooms or a library building
  with no public areas
• NIFs are eligible for Priority 1 services
• NIFs are eligible for Priority 2 services only if
  necessary to provide effective transport of
  information to classrooms or public areas of
  libraries

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4. Choose services (471)

• Item 21 Attachment (Item 21) the description of
  services associated with a funding request (Item
  21 on Form 471)
• Item 21 attachments can be submitted online or on
  paper
• USAC encourages online filing, especially for
  simpler applications
• Form 471 Receipt Acknowledgment Letter (RAL) a
  letter issued by USAC to the applicant and the
  service provider that summarizes the information
  provided in the Form 471
• Many of the entries on the form can be corrected
  after submission by using the RAL

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5. Application review

• USAC reviews your Form(s) 471 to
• Check the eligibility of the schools and
  libraries and their discount levels
• Verify that the services you requested are
  eligible for discounts
• Give you an opportunity to make allowable
  corrections to your form
• In some cases, ask for additional verification of
  your compliance with program rules
• Program Integrity Assurance (PIA) the USAC
  group that reviews and makes funding decisions on
  program applications
• Funding Commitment Decision Letter (FCDL) a
  letter issued by USAC to the applicant and the
  service provider that contains commitment
  decisions on funding requests

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6. Start services (486)

• You post a Form 486 to
• Notify USAC that services have started and
  invoices for those services can be processed and
  paid
• Provide the name of the TPA that approved your
  technology plan
• Report your status of compliance with CIPA
• Acronyms and terms
• Form 486 Notification Letter a letter issued by
  USAC to the applicant and service provider after
  a Form 486 has been processed
• Childrens Internet Protection Act (CIPA) a law
  with specific requirements on Internet safety
  policies and filtering
• TPA Tech plan approver

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7. Invoicing USAC (472/474)

• Applicants have a choice of two invoicing methods
  to receive discounts on eligible services
• Billed Entity Applicant Reimbursement (BEAR) Form
  472
• Service Provider Invoice (SPI) Form 474
• BEAR Form is filed by the applicant and approved
  by the service provider after the applicant has
  paid for the services in full
• SPI Form is filed by the service provider after
  the applicant has been billed for the
  non-discount portion of the cost of eligible
  services
• Acronyms and terms
• BEAR Notification Letter a letter issued by
  USAC to the applicant and service provider after
  a BEAR has been processed
• Quarterly Disbursement Report a report issued
  to the applicant detailing all invoicing activity
  (BEARs and SPIs) during the previous quarter

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Questions?
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Eligibility and Eligible Services List
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Eligibility - 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, including a public charter
  school, that provides elementary or secondary
  education, as determined under state law eg
  Pre-kindergarten( Sp Ed. Only), Adult Education,
  Juvenile Justice students facilities may be
  eligible.
• Must not have an endowment exceeding 50 million.
• USAC requests updated eligibility information
  from state departments of education every two
  years.

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Eligibility - Libraries

• Must meet the statutory definition of library or
  library consortium in the Library Services and
  Technology Act (LSTA) of 1996.
• Must be eligible for assistance from a state
  library administrative agency under LSTA.
• If they are a joint use facility (school public
  library) each can apply separately for their
  portions provided budgets are completely
  separate.
• Must not operate as for-profit business.

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Eligibility - Consortia

• Eligible schools and/or libraries may form
  consortia with
• Other eligible schools and/or libraries
• Certain health care providers
• Public sector (governmental) entities
• Helps bring the prices down
• May even help bring higher band-width or better
  service
• May bring more competition to your area
• BUT
• Only eligible entities can receive discounts
• Be careful about consortial applications
• not easy to administer
• there are consequences and responsibilities.

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Eligible Services - Priority 1

• Priority 1 funded first
• Telecommunications Services
• Basic telephone service wireline or wireless
  phone service (local, cellular/PCS, and/or long
  distance) Voice over IP- PBX and Centrex Radio
  loop
• Internet Access
• Basic conduit access to the Internet including
  but not limited to Broadband over Power Lines
  (BPL), Cable Modem, Digital Subscriber Line
  (DSL), Satellite
• T-x, DS-x, OC-x . E-mail service, and web hosting

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Eligible Services Priority 2

• Priority 2
• Internal Connections (switches, hubs, routers,
  wiring, cabling)
• Basic Maintenance on Internal Connections
• NOTE End user equipment - such as
• computers, monitors, or phone sets - is NOT
• eligible
• 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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Special Eligibility Conditions
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Internal Connections Example 1
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Internal Connections Example 2
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Classroom Internal Connections
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Classroom Internal Connections Ex. 2
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On-Premise Equipment 1

• This leased router may be eligible for P1 funding
  if all conditions are met.
• Single demarcation If the router is removed,
  the LAN would continue to function.

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On-Premise Equipment 2

• This leased router is NOT eligible for P1
  funding.
• Multiple demarcations If the router is removed,
  the LAN would cease to function which violates
  program rules for Priority One eligibility.
  Router may be eligible in IC.

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Internal Connections Maintenance

• 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, and configuration changes.
• Basic technical support of eligible hardware is
  Eligible but end-user support such as a student
  calling a help desk for technical assistance is
  NOT Eligible.
• BMIC is a Recurring service - Delivery must be
  within July 1st June 30th
• BMIC is exempt from the Two-in-Five rule

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Purpose

• Must be for Educational Purpose only
• Activities that occur on library or school
  property are presumed to be integral, immediate,
  and proximate to the education of students or the
  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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Non-instructional Facilities

• Non-instructional facilities are school buildings
  with (few or) no classrooms or library buildings
  with no public areas
• Non-instructional Facilities
• Eligible for Priority 1 services
• Telecommunications
• Internet Access
• Eligible for Priority 2 services only if the
  services are essential for the effective
  transport of data to classrooms or public areas
  of a library

• School examples
• Administration buildings
• Bus barns
• Athletic stadiums

• Library examples
• Administration buildings
• Bookmobile garages
• Technology centers

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Non-instructional Facilities (NIFs)
NIFs can receive Priority 1 services. Examples
are

• SCHOOLS
• Administrative buildings
• School bus barns and garages
• Cafeteria offices
• Facilities associated with athletic activities
• Teachers accompanying students on a field trip

• LIBRARIES
• Administrative buildings
• Bookmobile garages
• Interlibrary loan facilities
• Library technology centers

NIFs Priority 2 NOT eligible unless it is
essential for the effective transport of
information to an instructional building of a
school or to the patrons of a library.
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Eligibility- Service Provider

• What should you know about your Service Providers
• Must be an authorized Telecom Carrier and supply
  on a common carriage basis.
• Must file form 498 (Service Provider Information
  Form)
• Must have a Service Provider Identification
  Number (SPIN)
• Must file Form 473, Service Provider Annual
  Certification (SPAC) Form
• Must contribute to the Universal Service Fund.

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Website and Links
Eligible Services List http//www.usac.org/_res/d
ocuments/sl/pdf/ESL_archive/EligibleServicesList_1
12108.pdf
Questions?
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What are we?
What are the following services? P1, P2, or Not
Eligible
Not Eligible
P2
P1
P1 / P2
P2
P1 / P2
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Calculating Discounts
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Overview

• Basic discount calculations
• Alternative discount mechanisms
• Non-instructional facilities
• Snapshots
• New construction

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Basic Calculations

• E-rate discounts depend on
• The percentage of students eligible for the
  National School Lunch Program (NSLP) or an
  equivalent measure of poverty
• The urban or rural status of the county or census
  tract in which the school or library building is
  located
• USAC may request third-party verification of
  student counts submitted by applicants

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Discount Matrix
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Basic Calculations

• Individual school calculation
• Calculate the percentage of students eligible for
  NSLP in that school
• Use the urban or rural status of the county or
  census tract in which the school is located
• School district calculation
• Calculate the E-rate discount for each individual
  school in the school district
• Calculate the weighted average discount
• For each school, multiply the E-rate discount by
  the total student population of the school (the
  weighted product)
• Add all weighted products and divide by the total
  number of students in the school district

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Basic Calculations

• Library outlet/branch calculation
• Calculate the total percentage of students
  eligible for NSLP in the school district in which
  the library building is located
• Use the urban or rural status of the county or
  census tract in which the library outlet/branch
  is located
• Library system calculation
• Calculate the E-rate discount for each library
  outlet/branch in the library system
• Calculate the simple average discount
• Add together the discounts for the
  outlet/branches and divide by the total number of
  outlets/branches
• Consortium calculation
• Calculate the E-rate discount for each individual
  member of the consortium
• Calculate the simple average of all the member
  discounts

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Alternative Mechanisms

• Head Start (NSLP)
• Head Start is a federal program that provides
  comprehensive developmental services for
  low-income children ages three to five
• Head Start students meet free lunch guidelines
  under NSLP, so Head Start entities automatically
  qualify for 90 discount
• Children under age three are never considered
  eligible and must be cost-allocated out
• Home based Head Start is not eligible
• Direct certification (NSLP)
• State social services agency works with local
  educational authority to directly certify
  students for NSLP based on household
  participation in other poverty-based programs
• USAC will accept the student counts determined
  using this method if the school can demonstrate
  participation in direct certification

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Alternative Mechanisms

• Other alternative discount mechanisms measure a
  level of poverty in a household equivalent to
  that required by NSLP
• Income Eligibility Guidelines (IEGs) are
  published each year by the U.S. Department of
  Agriculture (USDA)
• Students from households whose income is at or
  below 185 of the federal poverty guideline are
  eligible for the NSLP
• Examples
• Medicaid, Food stamps
• Supplementary Security Income (SSI)
• Section 8 (federal public housing assistance)
• Low Income Home Energy Assistance Program
  (LIHEAP)
• Other programs can be used as mechanisms ONLY IF
  their requirements are at least as stringent as
  IEGs
• Examples of programs that do not automatically
  qualify
• Temporary Aid to Needy Families (TANF)
• Title 1 eligibility, Scholarship programs

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Alternative Mechanisms- Survey

• Applicants can conduct surveys to establish
  eligibility (see sample survey on USAC website)
• Survey requirements
• Must be sent to all families whose children
  attend the school
• Must contain names of family and students
• Must contain size of family
• Must contain income level of family
• Data must not be more than two years old
• Surveys can request information on household
  income level or participation in eligible
  alternative mechanisms or both
• With one exception, applicants must be able to
  provide data on an individual student basis
• Exception if a school sends a survey to the
  households of all of its students and at least
  50 of the surveys are returned, the school may
  project a percentage of eligibility based on the
  percentage of eligibility in the returned surveys
• Retain copies of all surveys for your records

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Other Sources

• Applicants can match siblings or collect data
  from other existing sources
• Example if a elementary school student from a
  household participates in NSLP, an older sibling
  in that household can be counted as eligible
• Multiple entities
• Discount is based on the total enrollment for the
  entity and NSLP data and each location receives
  the same discount
• Obtain an entity number for each facility if the
  facility has a different address or a public
  right-of-way crosses the campus
• Maintain adequate documentation

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Non-instructional Facilities

• Discounts for NIFs without classrooms
• In general, the discount for a NIF on the same
  campus as a school or library is the same as the
  discount of the school or library
• A NIF shared by more than one school in a school
  district or library in a library system is
  eligible for the shared discount for that school
  district or library system

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Non-instructional Facilities- snapshot

• Separate NIFs (not a part of the campus) that are
  used by a class should use the snapshot method
• Choose a specific day
• Determine the percentage of students eligible for
  NSLP for the student population that attends
  class on that day
• Use that percentage and the urban/rural status to
  find the discount in the Discount Matrix
• Save your documentation

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New Schools and Libraries

• Is it really a new school or library?
• Does the State consider this a replacement
  facility for the same school or library?
• If yes, use current discount information
• Does the State consider this a new school or
  library?
• If yes, the may use New School Construction
  guidance

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New Constructions

• If a school is under construction
• If the student population is known, use the
  percentage of NSLP eligibility of those students
  to calculate the discount
• If not, do a pre-enrolment survey
• If a library is under construction
• Use the discount for the school district in which
  the library building is going to be located
• Charter and Private Schools
• If population is unknown use 20 discount . You
  cannot use school district average
• If population is known - Must be able to provide
  supporting documentation. Use that data to
  calculate discount rate

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Questions?
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Form 470 Competitive Bidding
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Competitive Bidding / 470

• Filing Form 470 opens a competitive bidding
  process, which is fair and open.
• The Goal is
• to have a healthy competition
• to promote better service and lower prices
• Avoid conflicts of interest
• Independent consultant ?Service Provider
• Applicant ? Service Provider

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Competitive Bidding / 470

• 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
  including the selection criteria.
• Follow all rules FCC and state/local

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Pre-bidding Discussions

• Applicants may
• Discuss their product offering with SPs
• Learn about new technologies from SPs
• Applicants may NOT accept/use the following from
  service providers
• Vendor-specific language for RFP or the 470
• Template RFPs or Forms 470
• Assistance with tech plan
• Assistance with RFP

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Vendor Involvement

• Service providers cannot
• Determine the types of service the applicant will
  seek on a Form 470
• Assist applicants with the filling out of the FCC
  Form 470 which requires an applicants
  certification
• Influence or run the competitive bidding process
  for the applicant
• Be privy to information about the bid not shared
  with other potential bidders

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Competitive Bidding / 470

• Request for Proposal (RFP)
• Not required under FCC rules, but a good practice
  
• Must comply with local and state procurement laws
  (check for limits on sealed bid requirements
  etc.)
• Describes your project scope, location, other
  requirements in detail
• Even if you have an RFP, you must describe the
  services you desire on your Form 470.

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Competitive Bidding / 470

• Form 470
• Must indicate a multi-year contract or contract
  with extensions if appropriate.
• Must list services sought in the correct category
  of service. If you are not sure put it in both
  categories (Telecom and Internet). You can decide
  when doing Form 471
• Must indicate if it is for a single entity or
  multiple entities and if there are likely to be
  changes in the middle of the contract period

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The 28 day rule

• WAIT 28 DAYS after your Form 470 is posted and
  your RFP is issued before you evaluate the bids
• No hard deadline for filing Form 470 but is based
  on Form 471 window closing
• RFP handed out at walk through
• 28 day clock starts after last of the RFP issued
• Clock for 28 days restarts when
• If you issue a new RFP, then your 28 days starts
  again (do not have to post a new 470)
• Changed services sought
• Make other cardinal changes to RFP
• Post new Form 470

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Qualifying factors

• Qualification Factors
• Can require that potential bidders meet minimum
  number of qualification factors
• Disqualification Factors
• Can require that potential bidders that meet any
  disqualification factors are not considered
• Ensure that all potential bidders have adequate
  notice of these items
• If no bids received after 28 days, you may
  contact vendors to seek bids

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Sham bid process

• I want to stay with my incumbent
• Avoid appearances of a done deal
• Must respond to all legitimate inquiries. Need
  not respond to spams
• Cost to transfer to another provider alone is not
  by itself a good enough reason to stay with
  incumbent, but can be one of the bid evaluation
  criteria

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Competitive Bidding

• If you wait until the last date to file a Form
  470, the following must all occur on the last day
  of the window for Form 471
• Bid Evaluation
• Selecting a service provider
• Signing and dating a contract
• Submitting Form 471 online or mailing the manual
  paper copy
• Certifying, signing and dating
• Retain your documentation
• Retain, retain, lessen your pain

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Competitive Bidding / 470 Tips

• Retain worksheets, bid evaluation criteria,
  winning AND LOSING bids
• Prepare a memo to file if you received only one
  bid or no bids
• File online to reduces errors and speed
  processing
• Read the contracts fine print
• Personal Identification Numbers (PINs)
• Will be automatically issued to any new
  authorized persons filing Forms 470, 471 and 486
  after at least one wet signature.
• Do not use the pin that was issued to a former
  staff (Pins are electronic signature of the
  individual)

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Competitive Bidding / 470

• Form 470 Receipt Notification Letter (RNL)
• Cover page of important reminders
• Notifies applicant that Form 470 has been posted
  to the USAC web site
• Contains Allowable Vendor Selection / Contract
  Date (ACD)
• Use the calendar tool on the website rather than
  calculating it yourself.
• Remember if you posted your RFP after posting
  form 470 you will have to wait 28 after posting
  the RFP even if you have a ACD on your RLN.

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Questions?
Video Tutorials at http//usac.blip.tv/

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Vendor Selection, Contracts, Form 471
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Selecting a vendor

• Applicants must choose the most cost-effective
  solution to their Form 470 or RFP.
• Price has to be the primary factor the one with
  the most weightage (next slide)
• See Rubric on how to do the bid
  evaluation(Handout)
• Bid evaluation process should be carefully
  documented and filed - winning and losing bids
• If only one bid or no bids are received make a
  memo for your files

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Vendor Selection

• Applicants must retain all vendor selection
  documentation
• This includes winning and losing bids
• Price of the eligible goods and services must be
  the primary factor in all rounds
• Applicants determine remaining vendor selection
  criteria and relative weighting
• USAC sample evaluation matrix available

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Cost-Effectiveness

• Solution must be cost-effective
• Routers priced at two or three times greater than
  the prices available from commercial vendors
  would not be cost-effective, in the absence of an
  explanation of extenuating circumstances.
• Receiving only one bid does not automatically
  make it cost-effective
• Service Providers may work with the applicant to
  help them understand the technical needs for this
  expensive solution.

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Selecting Factors

• Selecting the winning bidder
• Price of the ELIGIBLE goods and services must be
  the primary factor.
• Other factors, including other price factors, can
  be considered as well but they cannot be weighted
  equally or higher than cost of the eligible goods
  and services
• See Step 4 Construct An Evaluation for weighting
  samples

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USAC bid evaluation template
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Contracts

• Once you have selected your vendor applicants and
  service providers must sign contracts for
  services that are not provided under tariff or
  month-to-month arrangements
• Contracts have to be signed by the applicant
  before filing form 471
• It is a good practice for the applicants to get
  the vendors to sign the contracts too, to make it
  legally binding.
• Contracts can cover more than one year or contain
  extensions, but applicant must indicate these
  options in the Form 470.
• TIP You may want to add some contract language
  that allows the contract to be extended into
  another program year in the event you are awarded
  late in the funding cycle and an opt out clause
  in case of funding denial

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Funding Requests / 471

• Form 471
• Provides specific information on services,
  service providers selected, and contracts
• Provides discount calculation information
• Details itemized services item 21 attachments
• Must be filed for each funding year even if you
  do not do a Form 470
• Contains certifications of compliance
• Has a hard deadline date.
• You can do multiple form 471s (Block 5s ) by
  breaking it out.
• File Priority 1 and Priority 2 requests
  separately. Review of Priority 2 requests may
  hold up Priority 1 commitments

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Funding Requests / 471

• Form 471 Deadline
• Must be filed online or postmarked on or before
  the close of the Form 471 application filing
  window. (midnight Eastern on the date of the
  deadline).
• Be prepared for a logjam and software timeouts
  closer to deadline.
• Good practice to file Certifications for
  associated Forms online or postmarked by
  deadline.
• Certifications and Item 21 attachments are
  accepted even after the close of the window.

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Funding Requests / 471

• Remove ineligible costs from funding requests
• Document ineligible costs carefully and cost
  allocate it out
• 30 rule if 30 or more of the dollar value of
  the request is for ineligible products, services,
  or entities you will get called during PIA review
  and asked to remove it.
• Work with your service provider
• to help you unbundle the services and products
• to break out eligible and ineligible costs
• to create your Item 21 attachment(s)

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Funding Requests / 471

• Enter recurring and non-recurring costs carefully
  in the cost summary of each Funding Request
• Recurring costs ALWAYS must be received by June
  30 of the Funding Year.
• Non-recurring costs must be received by September
  30 following the Funding Year, and this deadline
  can be extended under certain circumstances

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Funding Requests / 471

• 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 changes

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Questions?
Video Tutorials at http//usac.blip.tv/

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PIA Review
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Application Review - PIA

• All Forms 471 are reviewed by Program Integrity
  Assurance for compliance with program rules
  concerning areas such as
• Competitive bidding process, contracts, discount
  calculation, sufficient budget, establishing form
  470, Technology plan, CIPA
• Some errors can be corrected during PIA review
  but not all.
• All certifications and attachments (esp item 21)
  will be scrutinized.

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PIA Reviews

• Initial Final Review
• Applications always start in Initial Review.
  Reviewer contacts the applicant with questions,
  gives them 15 days to answer.
• Final Reviewer reviews the Initial Reviewers
  comments.
• Quality Assurance (QA) Review
• Some Form 471 applications are selected for QA
  review
• QA has Initial and Final review levels as well

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Clerical Corrections

• Bishop Perry Order allows applicants to make
  corrections to Forms 470 471 - known as
  ministerial clerical corrections.
• Applicants have additional time to certify Forms
  470 471, make corrections that do not require
  the Form 470 to be reposted or the Form 471 to be
  re-filed, and do not violate FCC regulations
  and/or program rules.
• USAC, with FCC guidance, developed a list of
  correctable items. List of Correctable M C
  Errors
• Subsequent FCC Orders issued identified more
  corrections allowable during PIA review.

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Clerical Corrections

• Examples
• Entered the incorrect amount (i.e., data entered
  100 instead of 1,000)
• Omitted an entity from the Block 4
• Provided the incorrect Form 470 number on the
  Form 471
• Selected the wrong category of service
• Submitted an unsigned contract to PIA
• Omitted an FRN
• Did not include all of the required elements in
  the written tech plan

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PIA Review Tips

• 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.
• Ask for everything in writing, respond in writing
• Check the 471 Application Status Tool on the web.

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Deadlines, Deadlines

• 15 Day Rule
• PIA corrections MUST be submitted 20 calendar
  days (5 days for mail receipt 15 days) from the
  date of USACs letter
• Receipt Notification Letter (RNL) 470
• Receipt Acknowledgment Letter (RAL) 471
• Mail, email or fax corrections to USAC
• RAL doesnt contain Block 4 information, so
  include the corrected Block 4 worksheet with your
  RAL corrections
• 7 day reminder

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RNL/RAL Corrections

• Corrections submitted after the deadline in the
  letter
• Requests to increase funding will not be granted.
  
• PIA will work with applicants to make clerical
  error corrections until the FCDL is issued
• PIA will request documentation to support the
  correction, such as contract, invoice, bill, etc.

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PIA Identified Changes

• Errors may be detected during PIA review
• PIA may contact you and allow corrections if they
  find certain discrepancies
• Item 21 doesnt match Block 5
• Discount for single entity doesnt match discount
  reported on different application
• Item 21 includes entities missing from your Block
  4
• Tech Plan is missing one or more required
  element(s)

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Funding Commitments

• After PIA review is successfully completed you
  get a Funding Commitment Decision Letter (FCDL)
• Cover page has important date-reminders
• Reports status of individual funding requests
• Funded
• Not funded
• As yet unfunded (Priority 2 requests)
• May receive more than one FCDL
• Check all entries on the FCDL carefully to make
  sure there are no data entry errors.
• Use the information on the FCDL to prepare your
  Form 486.

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Questions?
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107
Start of services Form 486and Invoicing Form
472/474
108
Starting Services / 486

• Notifies USAC that services have started and
  invoices can be paid
• Certifies that Tech Plan (if required) meets
  program requirements.
• CIPA compliance file proof of
• Internet safety policy
• Public notice or meeting
• Technology protection measure (filter)
• CIPA does not apply to Telecom Services Local
  and Long distance.
• But if you apply for cell phones and
  blackberries or any data transmission services
  you must be CIPA compliant

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Starting Services / 486

• Form 486 Deadline
• Form 486 must be filed no later than
• 120 days after the Service Start Date OR
• 120 days after the date of the FCDL
• whichever is later.
• If you file late your funding commitment will be
  adjusted to reflect the new start date
  corresponding to 120 days before the filing date.
• Form 486 Notification Letter (486NL)
• USAC will accept invoices once the Form 486 is
  certified.

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Invoicing BEAR or SPI? Why?

• Why would you choose one or the other?
• Form 472, Billed Entity Applicant Reimbursement
  (BEAR) Form
• Applicant pays for services in full and then
  requests reimbursement from USAC
• The form is submitted through the SP and they
  have to certify the invoices
• Form 474, Service Provider Invoice (SPI) Form
• Service provider discounts customer (applicant)
  bills and then requests discount amount from USAC
• The applicant pays only the non-discounted share

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How do reimbursements or BEARs work?
112
How do discounted bills or SPIs work?
113
Review of Invoices

• Service providers and applicant must review
  BEAR/SPI to ensure
• Only eligible services are being billed
• Only services that were approved on the
  application are being billed
• Services were delivered consistent with the FCDL
  and any agreements
• Any service interruptions are accounted for
• Follow through and ensure that Service providers
  sign off all months and all invoices

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Invoicing / 472 or 474 TIPS

• Form 472 (BEAR Form)
• DO NOT wait till the last day to file. Remember
  that the Service provider has to sign off on
  these.
• DO keep checking that your service provider has
  signed off on your 472 online
• DO check your calculations.
• Do make sure you have paid your non-discount
  share.
• Invoicing deadlines
• Form 472 or 474 must be filed online or
  postmarked no later than
• 120 days after the last date to receive service
• Can be monitored online to ensure that vendors
  have certified.
• File for invoice extension if needed
• You will receive a BEAR Notification Letter
  after your BEAR filing read it to see if you have
  submitted successfully

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Questions?
116
Program Compliance
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Know Your Role

• Applicants
• Write tech plan, file Form 470 and write RFP,
  evaluate bids, select provider, document the
  process, file Form 471, get tech plan approved,
  file Form 486, select invoice method, file BEARs
• Service Providers
• Respond to 470/RFPs, assist with preparing Item
  21 attachments, provide technical answers on
  questions regarding specific goods and services
  requested, but NOT on competitive bidding file
  SPIs and/or approve BEARs file SPAC
• Consultants
• Follow the role of their client either
  applicant or service provider

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Certifications

• Applicants certify that
• Have secured access to necessary resources
• Have complied with all FCC, state and local
  competitive bidding and procurement regs
• Non-discount portion of the costs for eligible
  services will not be paid by the service provider
  
• false statements on this form can be punished by
  fine or forfeiture
• Failure to comply with program rules could result
  in civil or criminal prosecution
• Persons who have been convicted of violations in
  the program are subject to suspension and
  debarment from the program

119
Selective Review and Heightened Scrutiny

• These reviews will take additional time and will
  hold up commitments until they are completed
• Selective Review Information Request (SRIR)
  contains some of the questions that may be ask
• May include review of
• Budget
• Necessary Resources
• Competitive Bidding and Contracts
• Pattern Analysis
• Targeted questions based on potential violations

120
Document Retention

• Document retention timeframes
• 5 years from last date to receive service
• FY 2010 this is at least June 30, 2016
• Any document from a prior year that supports
  current year must be kept until 5 years from last
  date to receive service as well
• Eg. Contract from 2004, used to support FY 2010
  FRNs, must be kept until at least June 30, 2016
• Applicants must retain all pre-commitment
  documents that show compliance with all FCC rules

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Document Retention and Audits

• Audits are done by an external agency
• to ensure compliance to rules,
• To ensure that there is no waste, fraud and abuse
  
• To ensure that there are no improper payments
  made.
• It is easier to keep track as you go along than
  to scramble when auditors are knocking on your
  door.
• Appearances are important
• If you are listed as the contact - you need to
  keep all documents dont expect the accounts to
  keep documents or archives to trace them for you.
• Applicants have been asked to pay back what they
  have received, sometime years later.

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Retain, retain, retain

• Retain documents to show your compliance
• Letters of Agency and any agreements with all
  consultants
• Technology Plan (both draft and final approved
  version) and TPA Plan Approval letter
• RFP, including evidence of publication date and
  any solicitation you did
• Any and all bids (winning and losing)
• Email to yourself if you get no or one bid

123
Retain, retain, retain

• Applicants retain documents to show compliance
• Documents describing bid evaluation criteria and
  weighting
• Any correspondence with potential bidders
• Documents related to the selection of the service
  provider(s)
• Signed and dated copies of contracts
• Also, see further list on USAC website under
  document retention

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Appeals

• USAC decisions can be appealed to USAC or to the
  FCC.
• Generally, appeal first to USAC.
• Can appeal to the FCC if USAC does not grant the
  appeal.
• Can be filed electronically or on paper.
• Must be filed electronically or postmarked within
  60 days of the USAC decision.
• Requests for waivers of rules must be filed with
  the FCC.

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SL News Briefs

• Emailed each week
• Subscribe from website
• Cover topics of current interest
• Archive of past issues
• Search by topic or date

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Tip Sheets

• One-page high-level guidance documents on major
  program topics
• Contain links to guidance documents
• Available on website and during site visits
• http//www.usac.org/sl/about/tip-sheets.aspx

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Video Tutorials and presentations
Viewing Options USAC Tutorials at Blip.tv For
slower connections can be viewed by most
browsers. USAC Blog Higher quality requires
latest Flash player. USAC Tutorials at MotionBox
Higher quality. Click "View All" to see all
available tutorials. You should have latest
version of your browser, and select "SD -
Standard Definition" if not already
selected. Video Tutorials http//www.usac.org/sl
/about/video-tutorials/ Presentation slides
http//www.usac.org/sl/about/training-presentation
s/
129
Scan topics alphabetically
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E-rate resources for AZ

• Arizona Department of Education (ADE)
• http//www.ade.az.gov/erate
• Arizona State Library Archives and Public
  Records
• http//www.lib.az.us/erate/
• Arizona State Procurement Office (AZSPO)
  https//procure.az.gov/bso/login.jsp
• E-rate Central
• http//www.eratecentral.com/
• E-rate resource center http//www.eschoolnews.c
  om/resources/reports/ffl/index.cfm

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USAC Resources

• USAC Homepage
• http//www.usac.org/sl/
• USAC Reference Page
• http//www.usac.org/sl/tools/reference-area.aspx
• USAC tools
• http//www.usac.org/sl/tools/search-tools/
• USAC Outreach and Training
• http//www.usac.org/sl/about/outreach-training.as
  px
• Use the Submit a Question link on the web site
  http//www.slforms.universalservice.org/EMailResp
  onse/EMail_Intro.aspx
• Fax toll-free at 1-888-276-8736
• Telephone toll-free at 1-888-203-8100
• Always ask in writing and insist on a written
  response.

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AZ Contact Information

• Brett Hinton 602-542-4214
• Brett.Hinton_at_azed.gov/
• Brenda Wright 602-542-4214
• Brenda.wright_at_azed.gov/
• Mala Muralidharan 602-926-3601
• mala_at_lib.az.us/

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Questions?