FUNDING YEAR 2013: COMPLETING FORM 470 Funding Year 2013: July 1, 2013-June 30, School Year

Topics for today’s session 1.What online resources will assist me in E- rate? 2.What is the purpose of form 470? 3.Form 470: Common errors made in filing 4.What’s new with the E-rate program in 2013? 5.Commonly asked questions 6.Form 470: We’ll walk through the online form

Numbers to remember SLD Client Service Bureau – Pam Jacobs (schools and districts) – – Jay Peterson (public libraries) – –

Online resources Actual online filing: Funding commitments/disbursements: Iowa E-rate information

What is the purpose of form 470?

To open the competitive bidding process for the E-rate services you seek. This form is required prior to filing form 471. There is a required 28-day “waiting period” between form 470 filing and 471 filing.

E-rate Timelines 1.Complete an E-rate tech plan (required if applying for priority 2; not required if only filing for priority 1) 2.Form 470 (File any time between now until mid- January) 3.Develop a bid evaluation matrix and accept bids 4.Wait at least 28 days after filing form 470 to complete the bid matrix and select service provider(s) 5.Select provider and sign contract (if applicable) 6.Form 471 (deadline is March 14 at 10:59 p.m. CT). Form 471 is often called “the application” 7.Answer questions/call from PIA (March-?) 8.Funding commitment decision letter 9.Form No discounts on bills? File form 472/BEAR form

Do I file form 470 every year? Question: Do I have to file a form 470 every year? Answer: Yes, if you are applying for month-to-month services, you must file form 470 every year. Yes, if you want to sign a new contract, you must file a form 470. No, if you have an existing multi-year contract that meets certain conditions (more info is provided later in this presentation)

Form 470: How many separate 470 forms to file? Your choice! You may file one form 470 OR You may file a separate form 470 for each type of service Recommendation: If you are applying for internal connections or basic maintenance, file a separate form 470 for these priority 2 services

Common Errors in filing form 470

Form 470: Common errors made in filing Error 1: Applicant doesn’t wait the full 28 days before choosing a service provider or signing a new contract FIX: Wait at least 28 days!

Form 470: Common errors made in filing Error 2: Applicant does not properly keep record of the bid evaluation process. Fix: (See the following slide for guidance).

Bid evaluation process SLD is getting more particular about documenting a fair and open bidding process 1.Have a written process for evaluating bids and criteria for selection prior to selecting your provider and signing a contract. 2.Keep a record of bids received!!! (not just the winning bid). 3.Complete your bid evaluation document, even if you just received one bid. Be sure to wait at least 28 days after filing form 470 to complete the bid evaluation process. 4.Date the completed bid evaluation document to show you waited at least 28 days to make your vendor selection.

Bid Evaluation Matrix (sample) Competitive Bidding FactorPoints AvailableVendor 1Vendor 2Vendor 3 Price of the ELIGIBLE goods and services Prior experience w/ vendor 20 0 Prices for ineligible services, products and fees Flexible Invoicing: 472 or Environmental objectives 5532 Local or in-state vendor 5555 Total

Must I accept the lowest bid? No, not according to e-rate rules…but cost must be the primary consideration Other factors might be prior experience of vendor, qualification of personnel, financial stability of the company, service that meets the needs of your school/library, in-state preference, willingness of the vendor to give discounts on bills

May we sign a contract? Yes, but only after the “allowable contract date” of 28 days following the posting of form 470 Include contingency language in case you don’t get funded, especially for internal connections

What if we already have a contract for school year? Did you already file form 470 in a previous year “establishing” this contract? (If you’re not sure your 470 qualifies to “establish” a multi-year contract, contact me and I’ll check it over with you). Did the “establishing” form 470 accurately describe the services and bandwidth for the contract?(especially important if you plan to increase bandwidth for school year) Does the contract cover ALL of school year? If all above statements are true, you do not need to file form 470 for this service. You will have to file form 471 in order to get funding.

Form 470: Common errors made in filing Error 3: Not enough quantity and/or capacity requested for telecommunications services and/or Internet FIX: Don’t limit your capacity. Use words like “no less than 8 cellular phone lines” or “minimum of 3 mbps”. Avoid using words like “8 phone lines.”

Form 470: Common errors made in filing Error 4: Form 471 requests services not listed on form 470 (forgot some services on form 470) FIX: You may file more than one form 470 (but must wait 28 days before selecting a service provider and signing a contract)

What’s new for E-rate funding year 2013?

New item 1: Have the form 471 deadlines been set? Yes! The form 471 “window” will open at noon (ET) on Wednesday, December 12 and close on Thursday, March 14 at 11:59 (ET). To meet the 28-day waiting period between filing form 470 and filing form 471, it is recommended that you file form 470 no later than mid-January (although the absolute last day to file form 470 is February 14).

What’s new with E-rate for the 2013 funding year? New item 2 : – Priority One services are consolidated into one list. – Priority One services are no longer separated by regulatory category (Telecommunications Services, Telecommunications, and Internet Access). – On form 470, priority 1 services may be filed either under “Telecommunications Services” or “Internet Access” or in both categories.

Commonly asked questions

What are the requirements for the Children’s Internet Protection Act (CIPA?) What about “off site” Internet access? What should we know about gifts and donations from service providers? How can I correct errors on forms 470 or 471? What can I do to get ready for funding year 2013?

What are the requirements for the Children’s Internet Protection Act?

Children’s Internet Protection Act CIPA reminders: The following are already required if requesting discounts on Internet and/or internal connections: 1.Internet safety policy 2.Public notice of – and public meeting or hearing on – the Internet safety policy 3.Technology protection measure (filter)

Children’s Internet Protection Act CIPA (applies only to districts/schools/AEAs) By July 1, 2012, you should have amended your Internet safety policy to provide for monitoring of online activities of minors and the education of minors in appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms, cyberbullying awareness and response.

CIPA change Your school/district/AEA is not required to have a new public notice and hearing for this policy change (assuming you have record of previous action). If you don’t have a record of the public notice and hearing for the original establishment of the Internet safety policy, it is recommended that you refresh the record by posting public notice and holding a public hearing.

CIPA reminders Your school/district/AEA does not have to buy an Internet safety student curriculum! There are plenty of great/free online resources. See Also see Common Sense Media (requires free online registration):

CIPA reminders Local school and library authorities must determine what matter is inappropriate for minors. Social networking sites are not automatically considered harmful to minors. Put into local policy how your school or library locally interprets the requirements and make sure your implementation aligns with the policy. (Do what you say you’re going to do).

CIPA reminders The following is not yet determined by FCC. Public comment likely to be sought on the following type of question: Do CIPA requirements apply to the use of portable devices owned by students and library patrons when those devices are used in a school or library to obtain Internet access funded by E-rate?

CIPA reminders Keep some sort of documentation to show filtering/technology protection measure is in place (e.g. bill from vendor of filtering software; sample of a couple computer logs showing filtering, etc.) (Schools/districts/AEAs only): Keep some sort of documentation that the education of minors occurs (e.g. copy of the curriculum used; sample lesson plan from teachers, etc.)

CIPA resources For a detailed discussion of CIPA requirements for E- rate, see the following: Children’s Internet Protection Act Form 486 Instructions Form 479 Instructions

What about E-rate supported “off site” Internet access?

What about “off site” Internet access? Question: May our district or school provide E- rate supported Internet access for students to use at home? (e.g. wireless access) Answer: No. If you provide E-rate supported Internet access “off site,” then the cost of the service must be pro-rated in your E-rate funding application.

4-pronged test for E-rate Eligibility Requirements for eligibility: – Must be an eligible product or service – Used by an eligible entity – Used at an eligible location – Used for an eligible purpose

What should we know about gifts and donations from service providers?

Gifts and Donations Receipt or solicitation of gifts by applicants from service providers (and vice versa) and potential service providers is a competitive bidding violation. Service providers may not offer or provide any gifts or thing of value to applicants personnel involved in E-rate.

Gifts and Donations Gift rules apply to everyone participating in the E-rate program, whether public or private, and whether operating at the local or regional level Gift prohibitions are applicable year-round, not just during the competitive bidding process

Gifts and Donations Gifts or prizes received at conferences are exempt from the gift rules only when such conferences are open to the public (for free) or meet narrowly-defined conditions as “widely attended events.” E-rate applicants who are not yet concerned about the gift rules might do well to reflect on a recent FCC filing on behalf of the East Central Board of Cooperative Educational Services (“ECBOCES”) which included the following point: ECBOCES believes that it is because ECBOCES employees accepted gratuities that total no more than $674 over a five-year period, USAC rescinded funding for FY2006, FY2007 and FY2008, and denied funding for FY2009 and FY2010 in the aggregate amount of $3,370, East Central Board of Cooperative Educational Services

Gifts and Donations See the following for more details Federal Gift Rules - 5 C.F.R. § Federal Gift Rules USAC training slides on program compliance (slides 41-66)USAC training slides on program compliance

How can I correct errors on forms 470 or 471?

Ministerial and clerical errors What if I make a mistake on a form? Error on form 470? If you discover the error early (like in November, December, January), file a new form 470 and ignore the one filed in error. Remember to wait 28 days after filing the new/replacement to select vendor(s). Corrections to 470 and 471 can be submitted until the funding commitment decision letter is issued (if you discover the error after application window closes) If you made an error and your PIA review has already started, tell your reviewer right away that you made an error

More on ministerial and clerical errors If you find you made an error and need assistance to get it corrected, contact Pam (schools/districts/AEAs) or Jay (libraries)

What can I do to get ready for funding year 2013?

Do you have/will you have new buildings? Have you closed any buildings? Will you have buildings closing in school year? Are buildings changing their purpose? (e.g. once were attendance centers and now are for purposes such as admin offices) Have you reorganized with another district? (or will you reorganize for ?) Have you formed a “system” (non-publics)?

Names of school buildings Want to speed up your 2013 application review? Take a look at the Iowa Educational Directory for the school year Note the names of your buildings (and district/system) in the Directory If changes need to be made for school year, notify USAC. Notify me of changes as well

Contact USAC Call the USAC Client Service Bureau to notify them of changes to building names, contact person information, corrections to building addresses, etc. They may request the information in writing on school/district/library letterhead

Completing the form 470

Form 470: What’s eligible for funding? See the 2013 Eligible Services List at ve/EligibleServicesList-2013.pdf ve/EligibleServicesList-2013.pdf

Examples of Priority 1 services Local telephone services Long distance telephone service Cell phone service Text messaging on cell phone Cellular data service/Internet access (Smartphone type service)

More examples of P1 services Centrex Leased circuits (e.g. data circuit to connect your elementary school to the high school) E-911 and 911 lines Voic service Leased dark fiber

More examples of P1 services Internet access Wireless Internet access (via wireless “cards”) Domain Name Service (DNS) registration Webhosting (usually not entirely E-rate eligible) Firewall service if included as a part of bundled Internet service (not purchase of firewall software)

What about Priority 2 services? NOTE: Internal connections is the only category where items may be purchased by school/library NOTE: Tech plan is required for all priority 2 requests!!! 2 in 5 rule applies for internal connections (an eligible location may only receive E-rate funding every 2 years out of 5)

Examples of P2 internal connections LANs Routers Switches Hubs Network servers Wireless LANs/wireless access points PBX (private branch exchange) See ESL for more examples and details

Priority 2 Internal connections Internal connections examples

Basic maintenance of internal connections Should I apply? Yes, if you plan to have a third party provide maintenance of internal connections 2 in 5 rule does NOT apply for maintenance (even though this is priority 2)

Basic maintenance of internal connections Support for basic maintenance of eligible internal connections (BMIC) Such as: – Repair and upkeep of hardware – Wire and cable maintenance – Basic tech support – Configuration Changes

Basic maintenance of internal connections Agreements or contracts must state the eligible components covered, make, model and location Service must be delivered within the July 1 st to June 30 th timeframe

Basic maintenance of internal connections Applicants may make estimates based on: – Hours per year of maintenance – History of needed repairs and upkeep – Age of eligible internal connections Applicants using the factors listed above must submit a bona fide request It is not reasonable to estimate an amount that would cover the full cost of every piece of eligible equipment.

Check out e-rate applications from previous years Dig out last year’s 470 and 471 forms Don’t limit yourself in bandwidth and services (think ahead)

Form 470: Block 1 – Item 5c: “Number of Eligible Entities for which services are sought” (How many buildings, including locations like bus barns, that will receive any E-rate services?) – Item 7: Do not attempt to complete this. This item is only completed by a paid consultant who is filing on your behalf.

Discount Matrix Percent of Eligible Students UrbanRural Less than 1%20%25% 1% - 19%40%50% 20% - 34%50%60% 35% - 49%60%70% 50% -74%80% 75% -100%90%

Iowa counties which are urban: Black Hawk Dallas Dubuque Johnson Linn Polk Pottawattamie Scott Warren Woodbury

Online filing

Should I e-certify? E-certify an option only if – Your principal/supt/authorized person filed a signed and data entered 471 and/or 486 in previous year(s) – Call SLD’s Client Service Bureau if you need a pin number ( ) – Special Pins for BEARs-only (online BEAR filing)

What if we can’t/don’t want to e- certify? Print certification/signature page (as directed on form 470) Have supt/director/authorized person sign Still recommend you use blue ink Mail certification/signature page with return receipt

If you don’t e-certify Use the certification page from the online filing DON’T just copy the cert page of the mail-in version

Final steps: Print and/or electronically save a copy of the completed 470 for your files Photocopy your cert page (if paper cert) Keep the completed copy in e-rate notebook/files (electronic copies are fine) Check to see if your form really was postedwww.sl.universalservice.org/sl/

How do I know my 470 was filed? 2 ways to check – – You will receive a receipt in the mail! Keep the receipt letter (on pink paper for 2013)

Why should I check about filing? To check the “allowable contract date”…this is the earliest date you may file form 471! Don’t pick a service provider before the 28 days is up!

Are you on the helpful E-rate listservs? (primarily for schools/districts and libraries). Send Debbie Wineland a message (primarily for libraries). Sign up at the url or contact Jay Peterson.

Numbers to remember SLD Client Service Bureau – Pam Jacobs – – Jay Peterson – –