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


E-rate - Get those dollars back to Arizona! Process overview Brett Hinton AZ Dept. of Education Mala Muralidharan AZ State Library Archives and Public Records – PowerPoint PPT presentation

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

Brett HintonAZ Dept. of EducationMala
MuralidharanAZ State Library Archives and
Public Records Modified from Train-the-Trainer
  • E-rate - Get those dollars back to Arizona!
  • Process overview

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

  • 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)

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

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

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

Telecomm Internet Internal connections IC
2.25 Billion
Funding Waves
Submitted each Quarter
  • 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.

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

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

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

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

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

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

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
  • 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

  • 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

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.

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

Technology plan approval
  • Technology Plan Approver (TPA) the agency
    certified by USAC that approves your technology
  • 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

Tech Plan Validity
Technology Planning Dos and Donts
  • DO
  • draft your technology plan before Form 470.
  • verify that it contains all five required
  • make sure your technology plan covers at least 12
  • 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.

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
  • Define the scope of your needs (e.g., a school
    building, a library system, a state network)

2. Request services (470)
  • Acronyms and terms
  • Billed Entity Number (BEN) an identification
    number assigned by USAC to each school or library
  • 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

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

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

Calculate the discounts
  • Reimbursements are based on Discounts calculated
  • 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
  • These two pieces of information are carried into
    the Discount Matrix

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

4. Choose services (471)
  • Acronyms and terms
  • Funding Request Number (FRN) the identification
    number assigned to a Form 471 Block 5 funding
  • 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

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
  • 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

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

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
  • 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

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
  • 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
  • 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

Eligibility and Eligible Services List
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
  • Must not have an endowment exceeding 50 million.
  • USAC requests updated eligibility information
    from state departments of education every two

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
  • Must not operate as for-profit business.

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
  • 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.

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
  • 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

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.

Special Eligibility Conditions
Internal Connections Example 1
Internal Connections Example 2
Classroom Internal Connections
Classroom Internal Connections Ex. 2
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.

On-Premise Equipment 2
  • This leased router is NOT eligible for P1
  • 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.

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

  • 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.

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

Non-instructional Facilities (NIFs)
NIFs can receive Priority 1 services. Examples
  • Administrative buildings
  • School bus barns and garages
  • Cafeteria offices
  • Facilities associated with athletic activities
  • Teachers accompanying students on a field trip
  • 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.
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
  • 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.

Website and Links
Eligible Services List http//www.usac.org/_res/d
What are we?
What are the following services? P1, P2, or Not
Not Eligible
P1 / P2
P1 / P2
Calculating Discounts
  • Basic discount calculations
  • Alternative discount mechanisms
  • Non-instructional facilities
  • Snapshots
  • New construction

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
  • USAC may request third-party verification of
    student counts submitted by applicants

Discount Matrix
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

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
  • Consortium calculation
  • Calculate the E-rate discount for each individual
    member of the consortium
  • Calculate the simple average of all the member

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

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
  • Other programs can be used as mechanisms ONLY IF
    their requirements are at least as stringent as
  • Examples of programs that do not automatically
  • Temporary Aid to Needy Families (TANF)
  • Title 1 eligibility, Scholarship programs

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

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

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

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

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
  • If yes, the may use New School Construction

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

Form 470 Competitive Bidding
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

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

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

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
  • Influence or run the competitive bidding process
    for the applicant
  • Be privy to information about the bid not shared
    with other potential bidders

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
  • 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.

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

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

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

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

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

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
  • 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

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.

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

Vendor Selection, Contracts, Form 471
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
  • 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

Vendor Selection
  • Applicants must retain all vendor selection
  • 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

  • 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.

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

USAC bid evaluation template
  • 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

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

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
  • Be prepared for a logjam and software timeouts
    closer to deadline.
  • Good practice to file Certifications for
    associated Forms online or postmarked by
  • Certifications and Item 21 attachments are
    accepted even after the close of the window.

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)

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

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
  • Applicants can request funding changes

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

PIA Review
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.

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
  • Quality Assurance (QA) Review
  • Some Form 471 applications are selected for QA
  • QA has Initial and Final review levels as well

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
  • Subsequent FCC Orders issued identified more
    corrections allowable during PIA review.

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

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.

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

RNL/RAL Corrections
  • Corrections submitted after the deadline in the
  • 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.

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
  • Tech Plan is missing one or more required

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.

Start of services Form 486and Invoicing Form
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

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

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

How do reimbursements or BEARs work?
How do discounted bills or SPIs work?
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

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
  • 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
  • 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

Program Compliance
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

  • 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

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

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

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
  • It is easier to keep track as you go along than
    to scramble when auditors are knocking on your
  • 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.

Retain, retain, retain
  • Retain documents to show your compliance
  • Letters of Agency and any agreements with all
  • 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

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

  • USAC decisions can be appealed to USAC or to the
  • Generally, appeal first to USAC.
  • Can appeal to the FCC if USAC does not grant the
  • 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.

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

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

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
Scan topics alphabetically
E-rate resources for AZ
  • Arizona Department of Education (ADE)
  • http//www.ade.az.gov/erate
  • Arizona State Library Archives and Public
  • http//www.lib.az.us/erate/
  • Arizona State Procurement Office (AZSPO)
  • E-rate Central
  • http//www.eratecentral.com/
  • E-rate resource center http//www.eschoolnews.c

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
  • Use the Submit a Question link on the web site
  • 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

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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