HSTI 2005

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E-rate Overview

• HSTI 2005
• Arkansas E-rate Work Group

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(No Transcript)
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FCC Registration Number

• Who Should Obtain an FCC RN
• The following entities participating in the
  E-rate program must have FCC RNs
• Schools includes individual schools, school
  districts, ESAs, and school administrative
  (non-instructional) facilities
• Libraries includes library outlets/branches,
  library systems and library administrative
  (non-instructional) facilities
• Consortium Leaders and Consortium Members
• Service Providers
• Consultants
• Entities that file Forms 470 and/or Forms 471
  that do not appear above
• NOTE Although an entity may have only one
  Taxpayer Identification Number (see below), that
  entity may have to obtain more than one FCC RN.
  While we encourage entities to obtain all of the
  FCC RNs that they need on their own, the law
  requires that they obtain at least one FCC RN by
  November 1, 2004.
• http//www.sl.universalservice.org/whatsnew/2004/1
  02004.asp

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FCC Registration Number

• NOTE Although an entity may have only one
  Taxpayer Identification Number (see below), that
  entity may have to obtain more than one FCC RN.
  While we encourage entities to obtain all of the
  FCC RNs that they need on their own, the law
  requires that they obtain at least one FCC RN by
  November 1, 2004.
• http//www.sl.universalservice.org/whatsnew/2004/1
  02004.asp
• 471 INSTRUCTIONS all Billed Entities will need
  to have an FCCRN for PIA review.

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You Must Have a Technology Plan!

• Five SL technology plan criteria
• Goals and Objectives
• Needs Assessment
• Professional Development
• Budget
• Evaluation
• Vendors cannot write or approve technology plans
• No tech plan required for basic phone service or
  long distance
• Tech plans approved for no more than 3 years
• Must be approved by SL-certified approver
  before services begin (usually July 1)
• Certify on 486 who approved plan

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Technology Plan

• Tech Plans will be undergoing 3 year review
  process.
• Template Instructions will be posted to E-rate
  list serve, sys admin list serve, open forum list
  serve Commissioner's Memo web site - also AEWG
  web site.
• Approximate due date for tech plans to be
  submitted will be around March 2006.
• These will cover years - 2006-2007, 2007-2008,
  2008-2009
• Make sure that you have started on your plan
  that they have included all E-rate items by the
  time they file their 470's this fall for FY
  2006-2007. You will certify to this when you
  submit your plan.
• The budget piece will be in more detail-
• Dana will try to have a CIV next fall to discuss
  plans the process for submitting them

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eCertification

• If a person signed a previous 471 or 486, they
  may apply for PIN from SL.
• May also soon allow previous Form 472 (BEAR)
  signators to apply for PIN.
• PIN then may be used to eCertify future SL only
  forms.
• PIN is given to a person, not an entity.
• Hopefully, this will change.

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Appeals

• 2 avenues to appeal
• Processing errors appeal to SL
• Policy decisions appeal to FCC
• Appeal letter must be received at SL/FCC within
  60 calendar days of the date listed on the
  funding commitment letter
• Half of all appeals are denied because of late
  filed appeals.
• If you appeal to SL
• you will receive an Appeal Receipt Letter
• If you appeal to FCC
• You will NOT receive a Receipt Letter
• Therefore, ALWAYS send appeal via express
  delivery.

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Appeals, cont.

• It takes months to have appeals considered
• If successful
• SL will send a letter indicating that appeal was
  found to be meritorious
• A funding commitment letter will follow
• If denied
• SL will send letter stating denial
• Applicant has 60 days from date on denial letter
  to have appeal received at FCC.

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Appeals, cont.
Important Be sure it is received within 60 days
of date on funding denial letter

• Suggestion Always appeal
• Appeal letter should contain
• Identifying information
• application numbers
• entity numbers
• funding request numbers, etc.
• Clear case why appeal should be found meritorious
• State problem
• Attach supporting documents
• Have someone read your appeal letter before you
  mail to make sure it makes sense and is
  persuasive.

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Form 500

• File Form 500 to either
• Change a service start date or a contract
  expiration date
• Cancel or reduce a funding commitment
• Needed to take advantage of grace periods
• Warning reductions or cancellations of funding
  commitments are irreversible

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SITE VISITS

• Conducted by Bearing Point
• Review one FRNs E-rate process
• Looking at
• 470 Competitive bidding
• Vendor invoice payment
• Inventory or Asset records
• Files
• Equipment

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Site Visits cont.

• May ask other staff about program
• Will ask to meet with a teacher
• Wants to see service in use
• May ask about state coordination
• May ask where you go for information and how easy
  it is to find
• Will ask your opinion of the Program
• Now asking applicant sign-off on notes

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AUDITS KPMG

• KPMG contracted to perform 100 audits during
  2004/2004
• KPMG contract extended to 750 audits during
  2005/2006
• Audit selection is random

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AUDIT DOCUMENTATION

• Technology Plan and approval
• Proof of competitive bidding
• Selection criteria
• Copies of bids
• Copy of bid evaluation procedure
• Copy of bid evaluation

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AUDIT DOCUMENTATION cont.

• CIPA Compliance
• Records of Public Board Meeting
• Copy of the acceptable use policy students and
  parents sign
• Will test a site to ensure filter works
• Inventory records
• Equipment labeled
• Proof of Professional Developement

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AUDIT FORM 500

• Will ask if you have turned in a form 500
• If not why
• Will be a comment on Audit but will not be a
  finding

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CONSORTIA AUDIT

• Some requirements pushed down to the member level
• Technology Plans
• CIPA compliance
• Inventory
• Professional Development
• Equipment records

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Washington Issues

• Anti-deficiency Act
• As most of you know, the Senate bill (S.241) has
  39 cosponsors and the recently introduced House
  companion (H.R. 2533) has 20 cosponsors.
• Consider writing letter to Congressional members
  who have not signed H.R.2533
• BARTON Its called the e-rate program. ... Its
  anabsolute boondoggle.

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FCC NPRM

• Adopted June 9, 2005
• Released June 14, 2005
• Comment Date 90 days after publication in the
  Federal Register
• Reply Comment Date 150 days after publication
  in the Federal Register
• 56 Pages

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FCC NPRM

• Managing the Program The Commission is
  exploring ways to simplify and streamline the
  management of the program. In particular, the
  Commission tentatively concludes that a
  multi-year application process for
  telecommunications services for the E-rate and
  Rural Healthcare programs would simplify the
  process in a way that still guards against
  potential abuse. The Commission also seeks
  comment on, among other things, reducing or
  consolidating application forms and adopting
  deadlines and other criteria to provide certainty
  to program applicants.

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FCC NPRM

• Improving Oversight The Commission seeks
  comment on the effectiveness of existing efforts
  to protect the fund against potential misuse.
  The Commission tentatively concludes that more
  aggressive debarment procedures are necessary to
  safeguard the fund and seeks comment on ways to
  improve the debarment rules. In addition, the
  Commission seeks comment on establishing
  independent audits for certain USF beneficiaries
  and contributors and seeks comment on what rules
  would help ensure that any audits are effective
  and fair. The Commission is also seeking comment
  on establishing rules for recovering USF monies
  that were not used in accordance with program
  rules.

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FCC NPRM

• Administrative Structure The Commission is
  examining the effectiveness of the existing
  administrative structure and seeks comment on
  whether any rule changes are needed to ensure the
  USF is administered in an effective,
  competitively neutral way.
• Performance Measures The Commission is seeking
  comment on establishing performance measures to
  assess the effectiveness of the program

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FCC NPRM

• Forms Seeking comments on all forms
• Distribution of funds Formula approach
• Multi-year contracts Applying once and funded
  for life of contract
• Request for Proposal Should an RFP be required
  for every service funded by E-rate?
• More to come Additional information will be
  posted to the E-rate list serve and the AEWG
  website

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What are your concerns

• application process
• site visits
• audits
• document retention

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Resources to Remember

• SL web site www.sl.universalservice.org
• SL CSB 888-203-8100
• AEWG E-rate website www.asl.lib.ar.us/arerate/ind
  ex.htm
• AEWG E-rate listserve
• Send email to listserv_at_adelist.k12.ar.us
• No subject
• Message Subscribe Erate (without quotes)
• Arkansas Contacts
• Becky Rains, DIS 501.682.4003 or
  becky.rains_at_mail.state.ar.us
• Dana Koite, ADE 501.682.1287 or
  dkoite_at_arkedu.k12.ar.us