Title: THE ABCs OF ERATE
1THE ABCs OF E-RATE
- John Noran
- Schools and Libraries Division
- Universal Service Administrative Company
- Washington Chicago Los
Angeles Newark - Sept. 30, 2005 Oct. 6, 2005 Oct. 11,
2005 Oct. 21, 2005
2Overview
- Schools and Libraries Program
- Provides discounts to eligible schools and
libraries for Telecommunications Services,
Internet Access, Internal Connections, and Basic
Maintenance - Applicants can be schools, libraries, or
consortia, but only eligible recipients of
service can receive discounts - Applicants must apply for discounts each year
(Form 471 application filing window) - Funding cap each year is 2.25 billion
2
3Overview
- Form 471 Application Filing Window
- Issues that affect window for FY2006
- Release of final Eligible Services List by the
Federal Communications Commission (FCC) - Special Katrina window
- Applicants File Form 470 now
- Receipt of recurring services
- July 1 June 30 (12 months)
- Receipt of non-recurring services
- July 1 September 30 (15 months)
3
4Overview
- The ABCs of E-rate
- Covers each step of the application process for
applicants and service providers - Dos and Donts slides contain program rules
- Tips slides contain suggestions that may help
applicants and service providers complete the
application process successfully.
4
5Overview
- Application process
- Eligibility
- Technology planning
- Competitive bidding / Form 470
- Calculating discounts
- Funding requests / Form 471
- Application review / Funding commitments
- Starting services / Form 486
- Invoicing USAC / Form 472 or Form 474
5
6Overview
- Forms and Letters for Applicants
- Technology plan
- Form 470
- Receipt Notification Letter (RNL)
- Form 471
- Receipt Acknowledgment Letter (RAL)
- Funding Commitment Decision Letter (FCDL)
- Form 486
- Form 486 Notification Letter (486NL)
- Form 472 or Form 474
- BEAR Notification Letter Form 472 only
- Quarterly Disbursement Report
6
7Overview
- Forms and Letters for Providers
- Form 498
- Notification by e-mail
- Form 499-A
- Notification by e-mail or telephone
- Receipt Acknowledgment Letter (RAL)
- Funding Commitment Decision Letter (FCDL)
- Form 473
- Form 486 Notification Letter (486NL)
- Form 472 or Form 474
- BEAR Notification Letter / Invoice Status Report
- Electronic notification
7
8EligibilityApplicants
- Eligible Entities - Schools
- Must meet the statutory definition of elementary
or secondary school found in the No Child Left
Behind Act of 2001. - Must be a non-profit institutional day or
residential school, including a public charter
school, that provides elementary or secondary
education, as determined under state law. - Must not be operating as a for-profit business.
- Must not have an endowment exceeding 50 million.
8
9EligibilityApplicants
- Eligible Entities - Schools
- Pre-kindergarten, Adult Education, Juvenile
Justice students/facilities may be eligible. - Must provide elementary or secondary education as
determined under state law. - USAC requests updated eligibility information
from state departments of education every two
years.
9
10EligibilityApplicants
- Eligible Entities - 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. - Budget must be completely separate from that of
any schools. - Must not be operating as for-profit businesses.
10
11EligibilityApplicants
- Consortia
- Eligible schools and/or libraries may form
consortia with - Other eligible schools and/or libraries
- Certain health care providers
- Public sector (governmental) entities
- Only eligible entities can receive discounts
11
12Eligible ServicesBoth
- Priority 1 funded first
- Telecommunications Services
- Basic telephone service wireline or wireless
phone service (local, cellular/PCS, and/or long
distance) - Voice mail
- Transmission services (T-1, DSL)
- Internet Access
- Basic conduit access to the Internet
12
13Eligible ServicesBoth
- Priority 2
- Internal Connections (switches, hubs, routers,
wiring) - Basic Maintenance on Internal Connections
- Priority 1 funded first, then Priority 2 begins
with neediest applicants (90 first, then 89,
88, etc.). - Internal Connections funded in only two out of
five funding years.
13
14EligibilityApplicants
- Educational Purposes
- Activities that occur on library or school
property are presumed to be integral, immediate,
and proximate to the education of students or the
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.
14
15EligibilityApplicants
- Examples of Non-instructional Facilities (NIFs)
that can receive Priority 1 services
- SCHOOLS
- Administrative buildings
- School bus barns and garages
- Cafeteria offices
- Facilities associated with athletic activities
- LIBRARIES
- Administrative buildings
- Bookmobile garages
- Interlibrary loan facilities
- Library technology centers
15
16EligibilityApplicants
- Educational Purposes Priority 1
- Wireless Telecommunications Services used offsite
may be eligible. For example, - School bus drivers delivering children to and
from school - Library staff providing library services on a
librarys mobile library unit van - Teachers or other school staff accompanying
students on a field trip or sporting event.
16
17EligibilityApplicants
- Educational Purposes Priority 2
- Priority 2 services to NIFs are NOT eligible
unless those internal connections are essential
for the effective transport of information to an
instructional building of a school or to a
non-administrative building of a library.
17
18EligibilityService Providers
- Service Providers
- Must file Form 498, Service Provider Information
Form - Request a Service Provider Identification Number
(SPIN) - Provide/update contact information.
- Must file Form 473, Service Provider Annual
Certification (SPAC) Form - Required for invoices that reference that Funding
Year to be paid.
18
19EligibilityService Providers
- Providers of Telecommunications Services must be
authorized as Telecommunications Carriers - Must contribute to the Universal Service Fund, if
applicable. - Must provide telecommunications services on a
common carriage basis to be deemed a
Telecommunications Carrier.
19
20EligibilityService Providers
- Telecommunications Carriers must
- (1) allow the customer to transmit information of
its own design and choosing, without change in
the form or content of the information, and - (2) provide that capability for a fee directly to
the public, or to such classes of users as to be
effectively available to the public (i.e., hold
itself out to serve indifferently all potential
users).
20
21EligibilityService Provider Tips
- Keep contact information updated by filing
revisions to Form 498 - USAC web site SPIN Search reflects information
from Form 498 Block 11 - Designate individual program contacts if new or
changed - Telecommunications Carriers provide Form 499
Filer ID
21
22Technology PlanningApplicants
- Technology Plans
- Not required for basic telephone service
- Must be written before Form 470 filing
- Must be approved by a certified approver before
the Form 486 is filed or discounted services
start, whichever is earlier - Must cover all 12 months (or all months of
service) - Must cover five specific elements
22
23Technology PlanningApplicants
- Technology Plans
- Must cover five specific elements
- Goals / Strategies for using technology
- Professional development
- Needs assessment
- Sufficient budget
- Evaluation process
23
24Technology PlanningApplicant Dos and Donts
- DO write your technology plan before submitting
your Form 470. - DO make sure your technology plan covers and is
approved for the entire period (usually 12
months) that discounted services will be
delivered. - DO make sure that your technology plan approver
is certified by USAC. - DO verify that your certified approval is dated
before services begin and before your Form 486 is
filed. - DO verify that your plan contains all five
required elements.
24
25Technology PlanningApplicant Tips
- Use each required area as a heading in your plan
and address that area under the heading. - PRINT A COPY of your certified approval for your
records. - Make sure your technology plan is approved for
the entire period (usually 12 months) that
discounted services will be delivered. - Prepare a technology plan if any of your services
fall outside of basic telephone service (such as
Centrex, PBX, T-1).
25
26Technology PlanningService Provider Tips
- Refer applicants with questions on technology
planning to neutral, third-party sources of
information such as state web sites. - Avoid giving applicants direct advice on
technology planning, especially targeted advice
on services you provide. - If you offer assistance, make sure it is neutral
technical advice.
26
27Competitive Bidding / 470Applicants
- Filing Form 470 opens a competitive bidding
process. - Can also issue a Request for Proposals (RFP).
- Applicants are responsible for ensuring an open
and fair process and selecting the most
cost-effective provider of the desired services.
27
28Competitive Bidding / 470Applicants
- Request for Proposal (RFP)
- Not required under FCC rules, but a good idea
- Must comply with local and state procurement laws
- 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.
28
29Competitive Bidding / 470Applicants
- Competition
- Goal is to have as many bidders as possible
- Promotes better service and lower prices
- Fair and open process
- All bidders treated the same
- No advance knowledge of RFP information
- No secrets in the process
- All bidders know what is required of them.
29
30Competitive Bidding / 470Applicants
- Form 470 Deadline
- Absolute deadline is 28 days before the close of
the Form 471 filing window. - However, if the applicant waits until that date
to file a Form 470, the following must all occur
on the last day of the window - Selecting a service provider
- Signing a contract
- Signing, dating and submitting Form 471.
30
31Competitive Bidding / 470Applicants
- Selecting service providers
- Applicants must choose the most cost-effective
solution to their Form 470 or RFP, with price as
the primary factor - Other factors can be considered, but price must
be the most heavily weighted. - Evaluation process should be carefully documented
and that documentation must be maintained.
31
32Competitive Bidding / 470Service Providers
- Responding to Form 470 / RFP
- Download Forms 470 two options for searching
applicant requests - Search Posted
- Must choose Funding Year
- Can then select other criteria
- Download Reports
- Must choose Funding Year
- One to five days ago or cumulative
- Delimited files
32
33Competitive Bidding / 470Applicant Dos and
Donts
- DO run an open and fair competitive bidding
process. - DO wait at least 28 days before selecting your
service provider. - DO certify your Form 470 promptly.
- DO indicate a multi-year contract or contract
with extensions if appropriate.
33
34Competitive Bidding / 470Applicant Dos and
Donts
- DO list services sought in the correct category
of service. - If USAC moves your request to another category of
service, your Form 470 must have featured that
category of service. - DO use price as the primary factor when selecting
the most cost-effective solution
34
35Competitive Bidding / 470Applicant 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 (and certify) online
- Reduces errors and speeds processing
- USAC will issue you a PIN after successful
certification of your Form 470 if you do not
already have one.
35
36Competitive Bidding / 470Applicant Tips
- Applicant Personal Identification Numbers (PINs)
- Will be issued by secure mailer to all authorized
persons on FY2005 Forms 470, 471 and 486. - Will be automatically issued to any new
authorized persons filing FY2006 Forms 470, 471
and 486. - After accepting Terms and Conditions, can be used
immediately to certify online.
36
37Competitive Bidding / 470Service Provider Dos
and Donts
- DO NOT complete, sign, or file the Form 470.
- DO NOT prepare or be involved in the preparation
of the RFP. - DO remain neutral at all times during the
applicants competitive bidding process.
37
38Competitive Bidding / 470Service Provider Tips
- Service providers may contribute information on
technical issues. - Service providers may provide basic program
information such as timelines and deadlines.
38
39Competitive Bidding / 470Applicants
- Form 470 Receipt Notification Letter (RNL)
- Cover page of important reminders
- Notifies applicant that Form 470 has been posted
to the USAC web site - RNL generated before certification
- Contains Allowable Vendor Selection / Contract
Date
39
40Calculating DiscountsApplicants
- Discounts are 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 (from web site) - These two pieces of information are carried into
the Discount Matrix
40
41Calculating DiscountsApplicants
Discount Matrix
41
42Calculating DiscountsApplicants
- Calculation for individual school
- Percentage of students eligible for NSLP for
individual school - Urban/Rural status
- Find discount from Discount Matrix
42
43Calculating DiscountsApplicants
- Calculation for school district
- Determine discount for each individual school in
the school district - Calculate the weighted average of the discounts
for all schools in the district - Discounts of individual schools with more
students will be weighted more heavily
43
44Calculating DiscountsApplicants
- Calculation for library outlet/branch
- Percentage of students eligible for NSLP in the
school district in which the library
outlet/branch is located - Urban/Rural status
- Find discount from Discount Matrix
44
45Calculating DiscountsApplicants
- Calculation for library system
- Determine discount for each individual
outlet/branch in the library system - Calculate the simple average of the discounts for
all outlets/branches in the library system
45
46Calculating DiscountsApplicants
- Calculation for consortium
- Determine the discount for each consortium member
- Calculate the simple average of the discounts of
all consortium members
46
47Calculating DiscountsApplicants
- Non-instructional facilities (NIFs) are eligible
for their school district or library system
discount - Online - calculate school district or library
system discount, then enter that discount for
each NIF (non-matrix discount) - School NIFs with classroom(s) calculate as with
individual schools using the student count in the
classroom(s)
47
48Calculating DiscountsApplicants
- Schools with transient populations
- Take a snapshot of the student population on a
specific day - Report the NSLP eligibility of that student
population - RETAIN DETAILED DOCUMENTATION OF YOUR CALCULATION
48
49Calculating DiscountsApplicants
- Alternative Discount Mechanisms for determining
student NSLP eligibility - Must be based on income family units whose
income is at or below 185 of the federal poverty
guidelines (Income Eligibility Guidelines) - Must be collected from a survey or from existing
sources - Must tie to individual students (with one
exception, projections are not allowed)
49
50Calculating DiscountsApplicants
- Examples of Alternative Discount Mechanisms
- Participation in food stamps, Supplementary
Security Income, Federal public housing
assistance, Low Income Home Energy Assistance
Program - Existing sources that are based on federal
poverty guidelines - Matching siblings
50
51Funding Requests / 471Applicants
- Form 471
- Provides specific information on services,
service providers selected, and contracts - Provides discount calculation information
- Must be filed for each funding year
- Contains certifications of compliance
- Includes one or more funding requests
51
52Funding Requests / 471Applicants
- Form 471 Deadline
- Must be filed online or postmarked on or before
the close of the Form 471 application filing
window. - Forms 471 filed after the close of the window
will be considered after all Forms 471 filed
in-window. - Certifications for associated Forms 470 also must
be filed online or postmarked before the close of
the window.
52
53Funding Requests / 471Applicants
- Contracts
- Applicants and service providers must sign
contracts for services that are not provided
under tariff or under month-to-month arrangements - Contracts can cover more than one year or contain
extensions, but applicant must indicate these
options in the Form 470
53
54Funding Requests / 471Applicants
- State Master Contracts
- If the state filed a Form 470, then the applicant
can cite the states Form 470 on its Form 471
Funding Request. - If the applicant filed a Form 470, the applicant
can consider a state master contract as one of
the bids, and can choose it as the winning bid if
it is the most cost-effective solution. - The state master contract can meet the FCC
requirements for a signed contract.
54
55Funding Requests / 471 Applicant Dos and Donts
- WAIT AT LEAST 28 DAYS BEFORE
- Selecting a service provider
- Signing a contract
- Signing and dating the Form 471
- Submitting the Form 471
- These actions must occur in this order.
- Refer to 470 RNL for allowable date.
- Both applicants and service providers must sign
and date all contracts.
55
56Funding Requests / 471 Applicant Tips
- Remove ineligible costs from funding requests
- Document ineligible costs carefully
- 30 rule if 30 or more of the dollar value of
the request is for ineligible products and
services, the entire request will be denied - Work with your service provider(s) to create your
Item 21 attachment(s)
56
57Funding Requests / 471 Applicant Tips
- 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
57
58Funding Requests / 471 Applicant Tips
- Dont combine Priority 1 and Priority 2 requests
on the same Form 471. - Review of Priority 2 requests may hold up
Priority 1 commitments. - File (and certify) online
- Reduces errors and speeds processing
- USAC will issue you a PIN after successful
certification of your Form 471 if you do not
already have one.
58
59Funding Requests / 471 Service Provider Dos and
Donts
- DO work with applicants to separate pricing for
eligible services from pricing for ineligible
services. - DO sign and date any contracts with your
applicants. - DO comply with state contract law and state and
local procurement laws. - DO work with applicants to choose the method of
payment discounts (Form 474) or reimbursements
(Form 472).
59
60Funding Requests / 471 Service Provider Tips
- Offer to work with applicants to help create
their Item 21 attachments and ask for a copy of
the final submission. - Provide correct SPINs, contact information,
billing account numbers, and other information. - Update contact information by filing a revised
Form 498. - File Form 473 now to avoid invoicing problems
later.
60
61Funding Requests / 471Both
- 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 reductions but not
funding increases
61
62Application Review Applicants
- Forms 471 are reviewed by Program Integrity
Assurance (PIA) for compliance with program rules
concerning areas such as - Competitive bidding process
- Contracts
- Discount calculation
- Sufficient budget
- Establishing Form 470
- Technology plan
- Childrens Internet Protection Act
62
63Application Review Applicant 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. - Check the 471 Application Status Tool.
63
64Application ReviewService Provider Tips
- You can assist applicants in responding to
requests for information, especially on technical
issues, but not with questions on the competitive
bidding process. - Communicate through the applicant or copy the
applicant on any responses to PIA. - Check the 471 Application Status Tool.
64
65Funding Commitments Both
- Funding Commitment Decision Letter (FCDL)
- Cover page of important reminders
- Reports status of individual funding requests
- Funded
- Not funded
- As yet unfunded (Priority 2 requests)
- Service provider does not receive this status
- Cancelled
- May receive more than one FCDL
65
66Funding CommitmentsApplicant Tips
- 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.
66
67Starting Services / 486Applicants
- Form 486
- Notifies USAC that services have started and
invoices can be paid - Certifies that Tech Plan (if required) meets
program requirements. - Certifies the status under Childrens Internet
Protection Act (CIPA). - Lead members of consortia may be required to
collect CIPA certifications from consortium
members on a separate form (Form 479).
67
68Starting Services / 486Applicants
- Childrens Internet Protection Act
- Applicants must certify compliance with
requirements - Internet safety policy
- Public notice or meeting
- Technology protection measure (filter)
- CIPA does not apply to Telecommuni-cations
Services, but applicant must still certify that
it receives only those services
68
69Starting Services / 486Applicants
- Form 486 Deadline
- Form 486 must be filed online or postmarked no
later than - 120 days after the Service Start Date OR
- 120 days after the date of the FCDL
- whichever is later.
- If the Form 486 is late, the date 120 days before
the Form 486 online filing or postmark date will
become the start date for discounted services and
funding may be reduced.
69
70Starting Services / 486Both
- Form 486 Service Start Date
- USAC may adjust the Service Start Date in order
to comply with program rules - Form 486 filed after the deadline
- Technology plan approval issues
- CIPA compliance issues
- Conflict with Form 470 allowable contract date
- The adjusted date is the earliest date that
discounted services may be provided. - Invoices for services provided before that date
will not be paid.
70
71Starting Services / 486Both
- Form 486 Service Start Date
- Cannot be before July 1 of the funding year.
- Can be as early as the date that the service
provider ships the product to the applicant or
earlier, depending on the arrangements between
the applicant and the service provider and/or
the terms of the contract.
71
72Starting Services / 486 Both
- Form 486 Notification Letter (486NL)
- Cover page of important reminders
- Provides confirmation that a Form 486 has been
successfully data entered. - Reports Service Start Date or Adjusted Service
Start Date - USAC will accept invoices from applicants (Form
472) or service providers (Form 474) once the
Form 486 is certified.
72
73Starting Services / 486Applicant Tips
- VERIFY THE SERVICE START DATE YOU REPORT.
- Also verify any adjustment on the 486NL.
- Work with your service provider to file your Form
486 so that neither you nor the service provider
is disadvantaged. - Initiate an Invoice Check if you want to monitor
the invoices (Forms 474) your service provider
sends to USAC.
73
74Starting Services / 486Service Provider Tips
- VERIFY THE (ADJUSTED) SERVICE START DATE ON THE
486NL. - Invoices dated before that date will not be paid.
- Invoices for services provided before that date
will not be paid. - Work with your applicant to file your Form 486 so
that neither you nor the applicant is
disadvantaged.
74
75Starting ServicesService Providers
- Form 473 Service Provider Annual Certification
(SPAC) Form - Service providers are required to file on an
annual basis. - USAC will only pay invoices for a funding year if
a SPAC is on file for that year. - SPACs are required for both BEARs and SPIs.
- SPIN Search Tool lists funding years for which a
SPAC is on file.
75
76Starting ServicesBoth
- 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. - Offers to reduce price must be incorporated into
the total pre-discount amount. - Service provider must bill the applicant for
non-discount share of services.
76
77Starting ServicesBoth
- Service delivery deadlines
- Recurring Services (June 30)
- Non-recurring Services (September 30)
- Deadline automatically extended to September 30
of the following year for FCDLs, service
substitution approvals, and SPIN change approvals
dated on or after March 1 of the funding year. - Applicants can also request extensions for
specific reasons involving difficulties with
delivery of services by service provider.
77
78Invoicing / 472 or 474Both
- BEAR (Billed Entity Applicant Reimbursement) Form
472 is filed by the applicant and certified by
the service provider after the applicant receives
services and pays for the services in full. - SPI (Service Provider Invoice) Form 474 is filed
by the service provider after providing services
and billing the applicant for its non-discount
share.
78
79Invoicing / 472 or 474Applicant Dos and Donts
- Form 472 (BEAR Form)
- DO verify that your service provider has signed
the last page of the form before you submit it. - DO check your calculations.
- Make sure you have service provider bills that
agree with your reimbursement request. - Form 474 (SPI Form)
- DO make sure you have paid your non-discount
share.
79
80Invoicing / 472 or 474Service Provider Dos and
Donts
- Form 474 (SPI Form)
- DO check your calculations.
- DO NOT use Form 474 to request a service
substitution. - Form 472 (BEAR Form)
- DO reimburse your applicant within 20 days of
receiving payment from USAC.
80
81Invoicing / 472 or 474Both
- Invoicing deadlines
- Form 472 or 474 must be filed online or
postmarked no later than - 120 days after the last date to receive service
OR - 120 days after the date of the 486 NL
- whichever is later.
- If the invoice is late, payment will be denied.
- Extensions of invoicing deadlines may be
requested under certain conditions.
81
82Invoicing / 472 or 474 Both
- BEAR Notification Letter
- Cover page of important reminders
- Provides confirmation that a Form 472 has been
successfully data entered. - Indicates what amounts are being paid and reasons
for reductions or denials. - Invoice Status Report / E-notification
- Indicates what amounts are being paid and reasons
for reductions or denials. - Sent only to service providers.
82
83Invoicing / 472 or 474 Both
- Quarterly Disbursement Report
- Sent only to applicants
- Authorized person
- Billed Entity (BEN) address.
- Contains all invoice (Form 472 and Form 474)
payment authorization amounts for the Billed
Entity for all funding years approved during that
quarter.
83
84AppealsBoth
- 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.
84
85General TipsBoth
- If you submit something to USAC
- Check your work
- Sign and date it (online or on paper)
- Submit it by the deadline
- Keep a copy and proof of submission
- If USAC sends something to you
- Read it
- Take all appropriate actions
- Save it
85
86AssistanceBoth
- Schools and Libraries / USAC web site
- Client Service Bureau
- 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
- Form instructions
86
87Questions?
87