JACK O’CONNELL State Superintendent of Public Instruction 1 E-Rate for California

JACK O’CONNELL State Superintendent of Public Instruction 2 Agenda 1.General Program Information 2.Technology Plans 3.Competitive Bidding and the Form Form PIA (Program Integrity Assurance) 6.Form 486 & Invoicing 7.Program Updates & Gotchas 8.Audits, Appeals, Cost Effectiveness and Other Reviews 9.USAC Tools – Training Materials, DRT 10.California Teleconnect Fund 11.Q and A Afternoon 1.Form 471 Tour 2.Tour of USAC Web Site 3.Calnet 2

JACK O’CONNELL State Superintendent of Public Instruction 3 The California Department of Education (CDE) does not administer the federal E-Rate program.  CDE has no statutory authority to administer the federal E-Rate program  CDE only provides general information about the E-Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources

JACK O’CONNELL State Superintendent of Public Instruction 4 1. General Program Information

JACK O’CONNELL State Superintendent of Public Instruction 5 Discount Calculations Calculated based on two factors 1.Percentage of students eligible for National School Lunch Program matrix.aspx matrix.aspx 2.Urban or Rural status of Entity

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

JACK O’CONNELL State Superintendent of Public Instruction 7 Discount Calculations and Entities Instructional Facilities will have a discount that comes straight from Matrix Non-Instructional Facilities will use District Weighted Average (District Office, Maintenance, Bus Barn, Gardener’s Shed, etc) –For use on Block 4 of the Form 471

JACK O’CONNELL State Superintendent of Public Instruction 8 Eligibility Schools – Elementary, Secondary, Charters, Private, Religious, Adult Ed (conditional), Pre-K, Juvenile Justice Libraries – public, separate from school libraries Consortia – any combination of the above

JACK O’CONNELL State Superintendent of Public Instruction 9 Non-Instructional Facilities (NIFs) Are eligible for Priority 1 services, telecommunications and internet access Are NOT eligible for Priority 2 services, internal connections, UNLESS they are essential for the effective transport of information to an instructional building of a school or to a non-administrative building of a library

JACK O’CONNELL State Superintendent of Public Instruction Non-Instructional Facility (NIF) Scenario One: NIF as a hub. This NIF is essential for the transport of info to the Schools and is eligible for P2 funding

JACK O’CONNELL State Superintendent of Public Instruction Ineligible for Priority 2 NIF Scenario Two: NIF as an end-point. The schools would maintain service if the NIF were removed, therefore the NIF is ineligible for P2 support

JACK O’CONNELL State Superintendent of Public Instruction 12 Eligible Services - Categories Four categories of service –Priority 1 (funded first) 1.Telecommunications Services 2.Internet Access –Priority 2 (starts with neediest applicants) 3.Internal Connections 4.Basic Maintenance of Internal Connections

JACK O’CONNELL State Superintendent of Public Instruction 13 Eligible Services List Posted on USAC website ( e-services-list.aspx) e-services-list.aspx Provides guidance to applicants and service providers on the eligibility of products and services under E-rate Organized by category of service Revised and updated each year in advance of the application window

JACK O’CONNELL State Superintendent of Public Instruction FY09 Draft ESL updates Eligible: –Ethernet –VoIP user licenses Ineligible: – Archiving –Intranet Web Hosting –Video-on-Demand Servers –Softphones

JACK O’CONNELL State Superintendent of Public Instruction 15 Telecommunications Service The transmission, between or among points specified by the user, of information of the user’s choosing, without change in the form or content of the information as sent and received. –Examples: ATM, T-1, Centrex, Local and Long Distance Telephone Service, Cellular Service and Paging Service –Rule of thumb: USAC funds the various types of services USAC does NOT fund end-user equipment - e.g., telephone sets

JACK O’CONNELL State Superintendent of Public Instruction 16 Internet Access Basic conduit access to the Internet Examples: T-1, DSL, DS-3, and Wireless service –Rule of thumb: USAC funds the conduit to the Internet USAC does NOT fund content

JACK O’CONNELL State Superintendent of Public Instruction 17 Internal Connections Components at the applicant site that are necessary to transport information to the school or library. –Examples: Access Points, Routers, Switches, Hubs, Wiring, PBXs and Codecs –Rule of thumb: USAC funds items that get the information to the classroom or room in the library USAC does NOT fund end-user equipment such as telephones (including IP telephones) or laptops

JACK O’CONNELL State Superintendent of Public Instruction 18 2 in 5 Rule Applies to Internal Connections funding requests only –Is entity specific –Implemented in Funding Year 2005

JACK O’CONNELL State Superintendent of Public Instruction 19 Basic Maintenance of IC 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. –Rule of thumb: USAC funds basic technical support of eligible hardware. (8 X 5, M-F) USAC does NOT fund end-user support or help desk

JACK O’CONNELL State Superintendent of Public Instruction 20 Basic Maintenance of Internal Connections (BMIC) Not subject to 2 in 5 rule Caution: –If a contract goes beyond what the FCC defines as basic maintenance, the entire contract will be denied –Eligible as recurring monthly services, i.e. – SmartNet –Include the components that the BMIC Contract will cover on your Item 21 attachment –BMIC can not be 24/7 coverage

JACK O’CONNELL State Superintendent of Public Instruction 21 Manage the Cycle - Teamwork Authorized signer ( Legally Authorized Signer ) Designated contact person (Will receive E-rate calls) Organize paper trail –Written Technology Plan –Assessment of existing Contracts, with signatures and dates (expiring contracts, etc) –Prior years submitted applications –Correspondence from SLD, Service Providers, etc. –All bids received and evaluation documents –Calendar of Deadlines

JACK O’CONNELL State Superintendent of Public Instruction 22 Funding Commitment Process E-rate Technology Planning – What are my goals? Form Starting the Application Process Competitive Bidding Form 471 – Selecting Your Vendors PIA (Program Integrity Assurance) Review Funding Commitment Form 486 Receipt of Services Confirmation Form 472 – BEAR and Form 474 – SPI – Invoicing “Getting the Money”

JACK O’CONNELL State Superintendent of Public Instruction Technology Plan

JACK O’CONNELL State Superintendent of Public Instruction 24 Technology Plan Overview 1.FFC rules require an “approved” technology plan when receiving E- rate for more than basic telephone service. 2.Must be “written” prior to posting Form Must cover all 12 months of the funding year. 4.E-rate only plans should not cover more than 3 years; EETT tech plans that meet E-rate requirements can cover 5 years with progress review during 3 rd year for E-rate purposes. 5.Must include all services that the E-Rate discount covers. 6.Must be approved by a “Certified Technology Plan Approver Locater Tool” Technology Plan approver locator tool:

JACK O’CONNELL State Superintendent of Public Instruction 25 5 Required Elements of a Technology Plan 1. Goals 2. Professional Development 3. Needs Assessment 4. Budget 5. Evaluation

Tech Plans for E-rate: E-Rate Only Plan: 1.Goals & a Realistic Strategy 2.Professional Development 3.Needs Assessment 4.Sufficient Budget 5.Evaluation Process Tech Plan Help applicants/step02/ EETT Plan for E-rate: Executive Summary/Introduction Stakeholders Curriculum Professional Development Infrastructure Adult literacy Research Funding and Budget Monitoring and Evaluation Must also include E-Rate supplemental budget analysis … and also see:

JACK O’CONNELL State Superintendent of Public Instruction 27 Tech Plan “Written” Written same as created: When a tech plan contains all required elements to support services requested on Form 470 – USAC considers the plan written. Must document and keep evidence of written date prior to filing Form 470 by ing plan to Assistant Superintendent, memo with date announcing that tech plan is written, “date stamp”

JACK O’CONNELL State Superintendent of Public Instruction 28 Documentation of Tech Plan Approval 1. E-rate only tech plan: –You can expect to receive an approval letter from your COE or State Library as the USAC- certified technology plan approver. Ask your COE/State Library for projected approval date. 2. EETT tech plan: –You can expect to receive an approval message via from CDE that confirms your EETT tech plan has been approved. –In general, CDE will make a determination regarding the approval of your EETT tech plan within 60 to 90 days of due date for review cycle (Cycles A, B or C). View Tech Plan approval status at:

JACK O’CONNELL State Superintendent of Public Instruction 29 EETT Tech Plan Approval Due dates (cycles) for submission of EETT Technology Plan to CTAP for approval: –Oct 3, 2008 Cycle A (Best practice) –Dec 5, 2008 Cycle B –April 3, 2009 Cycle C

JACK O’CONNELL State Superintendent of Public Instruction 30 Important Tech Plan Reminders Include a supplemental budget analysis if using EETT plan as your approved E-Rate tech plan – form located at: asp asp Ensure all E-rate requested services/products are included in your technology plan

JACK O’CONNELL State Superintendent of Public Instruction 31 Technology Plan Help SLD Libraries - rate.html rate.html CDE CTAP: rdinators.asp rdinators.asp

JACK O’CONNELL State Superintendent of Public Instruction 32 Contact Information State Library: Rushton Brandis, (916) , CDE: John Vardanega, (916) , CDE: Tech Plans: Bill Fong, (916) , Department of General Services (CMAS): Mary Gilbert, (916) , K-12 HSN/Butte COE: Russ Selken, ,

JACK O’CONNELL State Superintendent of Public Instruction 33 Technology Plan Help SLD Libraries CDE Recent News Brief from SLD - briefs/preview.aspx?id=116 briefs/preview.aspx?id=116

JACK O’CONNELL State Superintendent of Public Instruction Competitive Bidding and the Form 470

JACK O’CONNELL State Superintendent of Public Instruction 35 Preparation for Posting of Form 470 Document ALL of your eligible existing services, contracts and their expiration dates Identify existing contracts and services Expected growth – (P1 and P2) National School Lunch Program (NSLP) data for discount percentage Identify bidding restrictions (i.e., CMAS, geographic restrictions, etc.)

JACK O’CONNELL State Superintendent of Public Instruction Forms 470 Indicates the services and categories of service which you are seeking discounts Must be based on tech plan Must be posted for 28 days Indicates if you are planning/have issued RFP –Can only correct this by posting new Form 470 Indicates any special requirements and/or disqualification factors Indicates who will be receiving the services

JACK O’CONNELL State Superintendent of Public Instruction 37 File Online! Once the Form 470 is posted you must 1.Certify online using a PIN, OR 2.Print the certification page, sign and mail Mail this form immediately View form online to get the Allowable Contract Date –Also provided in the Receipt Acknowledgement Letter

JACK O’CONNELL State Superintendent of Public Instruction 38 Special Notes for Form 470 Processing When does the 28 day bidding period begin? 1.The day that ALL material for public viewing (i.e. RFP) is made available AND 2.The day the Form 470 is posted online –If RFP is released AFTER the posting of the Form 470 the 28 day bidding period begins with the day the RFP was released

JACK O’CONNELL State Superintendent of Public Instruction 39 Form 470 Reminders Allow adequate time –Competitive Bidding – minimum of 28 days –Local Procurement –Board Approval –Signing Contracts CMAS - Letter of Intent (LOI) CALNET 2 – 3 signatures needed Understand –Your existing services –Products and services you will need in the coming year Identify E-rate category for each product and service, P1 or P2

JACK O’CONNELL State Superintendent of Public Instruction 40 Receipt Notification Letter (RNL) GOLDEN Opportunity to review application and correct minor errors s/documents/sl/pdf/sampleletters/4 70RNL.acc.pdfhttp:// s/documents/sl/pdf/sampleletters/4 70RNL.acc.pdf

JACK O’CONNELL State Superintendent of Public Instruction 41 Competitive Bidding Fair and open competitive bidding process Avoid conflicts of interests –Independent Consultant vs. Service Provider –Applicant vs. Service Provider Follow the rules – FCC, State and local Read the contract fine print Document the process!!!

JACK O’CONNELL State Superintendent of Public Instruction 42 Competitive Bidding and Program Compliance estPractices.asphttp:// estPractices.asp –Keep copies of all bids, winning and losing –Documentation on the award process and the rationale for the bid award –Complete copies of all related contracts Best Practice: Use standard evaluation process for all bids. Keep evaluation documentation for each bid.

JACK O’CONNELL State Superintendent of Public Instruction 43 Program Compliance If you get NO bids – document this for audit purposes –Same is true if you get only ONE bid You may need to be proactive in soliciting for bids (If not using CMAS)

JACK O’CONNELL State Superintendent of Public Instruction 44 Evaluation Criteria Price must be the most heavily weighted factor Do not include Intent to Award or Evaluation Criteria in CMAS Request for Proposal Can choose most responsive and responsible response, but must DOCUMENT the choice and process Have District official SIGN and DATE the completed rubric as acknowledgement

Vendor AVendor B RawWeightedRawWeighted Selection Criteria Weight* (%) Score**Score*** Score Prices/Charges40% Understanding of Needs15% Prior E-Rate Experience10% Prior District/Service Prov experience 10% Completeness of Response15% References10% Overall Ranking100% SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE

JACK O’CONNELL State Superintendent of Public Instruction 46 Form 470 – Multi Year Contracts You may not need to file Form 470 every year if: –The language on the Form 470/RFP covered all services on the contract AND –The applicant indicated on the Form 470 that a contract was being sought AND –The applicant indicated on the Form 470/RFP that a multi year contract (perhaps w/voluntary extensions)

JACK O’CONNELL State Superintendent of Public Instruction 47 Contracts Must be signed AFTER 28 days have elapsed but BEFORE you file your Form 471 Must be signed and dated by BOTH parties – applicant and service provider –CALNET 2 ATO must have three signatures to be binding contract Be prepared to explain documents that don’t look like a traditional contract.

JACK O’CONNELL State Superintendent of Public Instruction Form 471

JACK O’CONNELL State Superintendent of Public Instruction 49 Form 471 – Your application for Funds Must be filed every funding year: This is your actual funding request Based on posted on Form 470(s) One or more funding requests This is your Who, What, When, Where, & How –Service providers chosen –Services being requested –Dates for services –Service Delivery locations – Signed contracts or tariffed services

JACK O’CONNELL State Superintendent of Public Instruction 50 Form 471 Filing Deadline The Window for the Form 471 filing window has not been announced yet. If you are on CDE E-rate List SERV, you will be notified when FCC determines filing deadline, which then determines Form 471 filing deadline If you receive USAC weekly newsbriefs, notification will be published there. Must be submitted BEFORE close of window

JACK O’CONNELL State Superintendent of Public Instruction 51 Form 471 Filing Deadline –Submit BEFORE close of window DEADLINE DATE = ??

JACK O’CONNELL State Superintendent of Public Instruction 52 Form 471 Best Practices –Get a Partner –Do your own Timeline of milestones –File Online –Certify BEFORE close of window Online if using PIN By trackable mail if you do not use your PIN –File EARLY!! –Do everything before Deadline –Allow enough time to fully complete process & paperwork –Organize your paperwork

JACK O’CONNELL State Superintendent of Public Instruction Keep Your Dates in Order Remember the correct order for dates: –Allowable Contract Date (28 days after 470) THEN –Contract Award Date THEN –Form 471 filing THEN –Form 471 Certification date ALL BEFORE –Window close

JACK O’CONNELL State Superintendent of Public Instruction 54 Form 471 Apply Online = menu.asp menu.asp Form 471 Test page = ngSiteWarning.asp?

JACK O’CONNELL State Superintendent of Public Instruction FORM 471 DON’TS DON’T file Priority One and Priority Two funding requests on the same Form 471 DON’T forget to wait at least 28 days after any mandatory processes associated with your competitive bidding before selecting a service provider or signing any contracts DON’T submit your Form 471 BEFORE signing all related contracts DON’T forget to CERTIFY your submitted application (whether electronic or paper certification) 55

JACK O’CONNELL State Superintendent of Public Instruction 56 Form 471 Reminders Separate your Priority 1 and Priority 2 funding requests onto separate Form 471s. Verify that you are using correct establishing Form 470 number on each Block 5 Funding Request. Choose the correct category of service (e.g., Telecom, Internet, etc.) Check your math, check it again Review your application Validate the information

JACK O’CONNELL State Superintendent of Public Instruction Pre-Commitment Review Things to do before PIA contacts you Submit your Item 21 Attachments online or paper. –Place application number(s),FRN(s), Attachment ID, and page numbers on Item 21 Attachments –Indicate Bandwidth when you are requesting telecom or Internet access –Indicate the entities receiving services and locations –Clearly label ineligible items and costs –Indicate product make and model for each product requested –Provide a detail product or service description

JACK O’CONNELL State Superintendent of Public Instruction 58 Item 21 Attachment Samples available on USAC website – nce/Form471item21Attachments.asphttp:// nce/Form471item21Attachments.asp Remove ineligible costs – be careful –30% rule –30% or more of funding request dollar value cannot be for ineligible products and services. the entire request may be denied unless… – Can be rectified during your PIA process: Remove it-Split it up- separate FRN Work with service provider(s) to create your Item 21 attachment(s)

JACK O’CONNELL State Superintendent of Public Instruction Reciept Acknowledgment Letter Process Opportunity to verify information one more time Three weeks from date of letter to submit corrections /sl/pdf/sampleletters/471RAL.pdf

JACK O’CONNELL State Superintendent of Public Instruction 60 One Last Chance…. ** Bishop Perry Order – 15 day grace period for certifications made after the deadline -of-Correctable-Ministerial-and-Clerical- Errors.pdf -of-Correctable-Ministerial-and-Clerical- Errors.pdf

JACK O’CONNELL State Superintendent of Public Instruction Program Integrity Assurance

JACK O’CONNELL State Superintendent of Public Instruction 62 Program Integrity Assurance (PIA) Applications are reviewed for compliance with program rules concerning areas such as: –Properly executed contracts –Discount calculation –Establishing Form 470 –Eligibility of services being requested –Eligibility of entities requesting discounted services –Proper completion of all of blocks/item 21

JACK O’CONNELL State Superintendent of Public Instruction PIA Reviewer Be nice to your reviewer – even if they are not nice to you!!!

JACK O’CONNELL State Superintendent of Public Instruction 64 Be Responsive Respond promptly, be sure to answer questions in their entirety Document communication with PIA, send to PIA as a confirmation of your phone conversations Ask for more time if you need it –Be advised that if you ask for more time the Reviewer will move on to another application Don’t assume that Reviewer has all of the information you sent in as part of your Item 21 attachment.

JACK O’CONNELL State Superintendent of Public Instruction If corrections are needed Services Cost Allocations –Work with the service provider to identify the ineligible services, so they are clearly identified –On the Item 21 Attachment identify the ineligibles services and associated costs –Prepare a “revised” Form 471 Block 5 to reflect the cost allocations Best Practice – Break out FRN with PIA’s assistance Entity Removal –On the “original” Form 471 Block 4 worksheet identify the entities to be removed –Prepare a “revised” Form 471 Block 4 worksheet if new discount calculations and student counts –On the Block 5 funding request, indicate your revision to the dollars requested based on the share of the funding request for the entities being removed

JACK O’CONNELL State Superintendent of Public Instruction 66 What Happens After PIA Review A Decision – FCDL (Funding Commitment Decision Letter) –Funded –Not Funded –As Yet Unfunded (Priority 2 requests) –Cancelled –IMPORTANT – Check all entries in the FCDL carefully to make sure there are not data entry errors.

JACK O’CONNELL State Superintendent of Public Instruction Post-Commitment Review the FCDL for Accuracy –Read the FCDL comment to determine if modifications have occurred to the FRN to ensure you invoice for the correct services. –Verify SPIN, discount, fund request, start and end dates, and contract number (if applicable) –If you disagree with the decision, you may file an appeal.

JACK O’CONNELL State Superintendent of Public Instruction 68 What next? FCDL should be your “trigger” to file subsequent forms Starts deadline clock for appeal on denial(s) –Note: Appeals must be done within 60 days of the date of FCDL

JACK O’CONNELL State Superintendent of Public Instruction Form 486 & Invoicing

JACK O’CONNELL State Superintendent of Public Instruction 70 Purpose of 486 Notifies USAC that entity is ready to receive services, services have started or are scheduled to start and invoices can be paid Certifies that Tech Plan is approved and meets program requirements Certifies status of compliance with Children’s Internet Protection Act (CIPA) Do NOT miss Form 486 deadline for your district; LATE FILINGS WILL LOSE $$ – 86-filing-information.aspxhttp:// 86-filing-information.aspx

JACK O’CONNELL State Superintendent of Public Instruction 71 What is the Form 486 deadline? –Filed AFTER receipt of FCDL –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 –Grace period from USAC – SLD will send letter giving reminder to file Form 486 – (Alaska Gateway order) Take this letter seriously; you have 20 days from date of the SLD letter to take action!

JACK O’CONNELL State Superintendent of Public Instruction 72 Form 486 Compliance Review USAC may review Form 486 for compliance with program requirements for technology planning before the form is successfully processed. If Form 486 undergoes review, USAC does not issue a Form 486 Notification Letter until all compliance issues have been resolved. (i.e. Approved Tech Plan)

JACK O’CONNELL State Superintendent of Public Instruction 73 Form 486 Notification Letter (486NL) Letter received after filing of Form 486 –Verify that ALL FRNs are on letter –Verify service start dates for each FRN USAC is now ready to begin receiving invoices for payment on these FRNs –Form 472 – filed by Applicant OR –Form 474 – filed by Service Provider

JACK O’CONNELL State Superintendent of Public Instruction 74 Receipt of Funds One of two ways: –Applicant pays entire bill up-front and gets reimbursed Form 472 (BEAR) – BEAR submitted by Applicant –Service Provider applies discounts to bills and submits invoices to USAC for reimbursement Form 474 (SPI) – filed by Service Provider

JACK O’CONNELL State Superintendent of Public Instruction 75 Special Note on Form 472 Note – Form 472 (BEAR) cannot be filed if applicant is also receiving California Teleconnect Fund (CTF) discounts on same services. Applies only to Telecommunications (data-voice) –Internet services may also be eligible for CTF discounts

JACK O’CONNELL State Superintendent of Public Instruction 76 Important Reminders Print and retain copies of everything Keep E-Rate files organized Create a timeline of E-Rate deadlines Share this information with others at your site

JACK O’CONNELL State Superintendent of Public Instruction Program Updates & Gotchas

JACK O’CONNELL State Superintendent of Public Instruction 78 Forms Form 470 –Be careful when specifying services –Understand the categories of service –Can combine all services that cover Priorities 1 and 2 on the same Form 470 Form 471 –File separate forms for Priorities 1 and 2 –File separate forms for different discount bundles

JACK O’CONNELL State Superintendent of Public Instruction 79 California Pre-K and Adult Ed These student populations are eligible for E-Rate discount in California except Adult Ed. enrichment VS secondary curriculum Children under age of 3 Treat same as traditional classrooms or facilities Obtain entity numbers and establish poverty level Head Start is 90% May use alternative discount methods Be sure to add their plans to your District technology plan to ensure compliance

JACK O’CONNELL State Superintendent of Public Instruction 80 Non-Instructional Facilities Priority Two GOTCHA  Educational Purposes – Priority 2 –Priority 2 services to Non Instructional Facilities (NIFs) are eligible ONLY IF 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.

JACK O’CONNELL State Superintendent of Public Instruction 81 2 in 5 Rule for IC Determined on an individual entity basis or shared worksheet (bundle) All entities on a Block 4 worksheet that utilize approved funding for IC, are counted as taking a year 2009 is the fifth year for the rule (if applicant applied in 2005) Must file Form 500 to cancel FRN if approved and not utilized Establish a matrix for tracking the UTILIZATION of funds for approved goods or services USAC tool does not track pending or utilized, just funded

JACK O’CONNELL State Superintendent of Public Instruction 82 October Important Deadlines Complete your BEAR for prior to Oct 28 th, 2008 Pay attention to 486 deadlines, Due 120 days after FCDL (Note: this is due Oct 28 th if you received your FCDL for on or prior to July 1 st ) Have your tech plan written PRIOR to posting your Form 470 for if it expires June 30 th 2009 or sooner File your Form 470 for NOW!

JACK O’CONNELL State Superintendent of Public Instruction Audits, Appeals, Cost Effectiveness and Other Reviews

JACK O’CONNELL State Superintendent of Public Instruction Compliance Attestation Examination AKA “The Big Audit” Directed by the FCC’s Office of Inspector General (OIG) Randomly selected by FCC Annually between November and July 1 st 84

JACK O’CONNELL State Superintendent of Public Instruction Compliance Attestation Examination Examine payments made during a single fiscal year – May include examination of MUTIPLE funding years! Conducted by third party auditing firms who may be on-site 2 to 8 weeks Purpose: Did applicant comply with FCC rules? (not just looking for waste, fraud, and abuse) Applicant must be able to prove compliance with rules 85

JACK O’CONNELL State Superintendent of Public Instruction Examples of Rule Violations that Warrant Recovery of Funds Insufficient documentation of the competitive bidding process Lack of necessary resources – equipment not fully utilized Service substitutions not meeting criteria established in the rules Failure to pay (or show proof of payment) of non- discounted share Failure to complete services within funding year Discount calculation violation Technology Plan not approved and/or not containing required elements and requested services More specific examples located on USAC Audit training slides located at: presentations/training-presentations-archive/training- 2008/fall/materials.aspx 86

JACK O’CONNELL State Superintendent of Public Instruction 87 How To Prepare For The Audit Follow All E-rate Rules Retain – Retain – Retain – Lessen your pain!! Document, Document, Document! Plan ahead for an audit by documenting every step of the process Create an E-Rate Binder for EACH funding year USAC Compliance Documentation Checklist for audits DocChecklist.pdfhttp:// DocChecklist.pdf

JACK O’CONNELL State Superintendent of Public Instruction 88

JACK O’CONNELL State Superintendent of Public Instruction 89 Who Should Be Available During Audits? Person(s) who –filed the E-rate forms –managed the bidding and award process –reviewed and approved invoices –prepared E-rate invoices –is responsible for budget (CBO) –Is responsible for NSLP documentation –is knowledgeable about the network and the location of equipment Appoint a single contact person who can manage interactions between auditors and staff members

JACK O’CONNELL State Superintendent of Public Instruction Document Retention Requirements Keep for 5 years after last date of service –Be aware of contract dates and extensions as the 5-year minimum may be extended –All USAC correspondence, including Quarterly Disbursement Reports Make sure all departments understand documentation retention requirements for E-Rate Align Board policy with E-rate requirements

JACK O’CONNELL State Superintendent of Public Instruction 91 Technology Plan Documentation Copy of Technology Plan that covers entire year being audited (should be part of your ANNUAL e-rate documentation) Copy of Draft and creation date documentation Proof of approval of Technology Plan Supplemental Budget analysis (if using EETT Plan) Summary of the technology environment and a high-level network diagram

JACK O’CONNELL State Superintendent of Public Instruction 92 Bidding Documentation Copy of State and Local procurement policies Form 470 and all request for bid documentation RFP/RFB/RFQ, announcements, advertisements, addendums, etc… ALL correspondence between applicant and service providers ( , phone log, job walk sign- in sheet, etc…) Copy of all bids received (winning and losing) Document if NO bids are received Bid evaluations Notice of Award to winning vendor Contract Board Award Copy of any change orders

JACK O’CONNELL State Superintendent of Public Instruction 93 Invoicing Documentation Proof of payment to service providers Copies of warrants or cancelled checks, check register Auditors will ask for reconciliation of payment by invoice Copies of all invoices, phone bills Invoices should be detailed Copies of BEAR Forms Reconciliation (by FRN) of service provider invoices to BEARs submitted to SLD (removal of all ineligible costs) Copy of reimbursement check from service provider to prove receipt of E-rate funds if applicable

JACK O’CONNELL State Superintendent of Public Instruction 94 Priority Two Services Documentation Equipment purchased using E-Rate Detailed vendor invoices Packing slips showing date of delivery Walk through or sign off that shows when services were delivered Asset register see detailed USAC example ng/samples-checklist-inventory-list.pdfhttp:// ng/samples-checklist-inventory-list.pdf Well-marked equipment Service Substitution Equipment Transfer documentation Basic Maintenance Maintenance log

JACK O’CONNELL State Superintendent of Public Instruction 95 CIPA Documentation Internet safety policy Local governing board adoption of the Internet safety policy The date and a copy of the minutes of the public hearing regarding the Internet safety policy [Local Board adopted policy] Internet filtering reports Copies of invoices for Internet filtering services Copies of Forms 479 and/or Forms 486, if applicable

JACK O’CONNELL State Superintendent of Public Instruction Discount Documentation NSLP Method –Proof of discount calculations including source data and reports –Auditors may ask for a sampling of actual NSLP applications –USDA and FCC agreement Memos/2008/SP_ pdf Alternative Methods –Keep copies of every survey and a summary report –Source data and annual poverty guidelines

JACK O’CONNELL State Superintendent of Public Instruction 97 Other Documentation SPIN change requests including copy of notice to original service provider School closure, consolidation or construction documentation ALL communication regarding E-Rate Service Providers SLD/USAC Case Numbers PIA questions and responses Documentation of other services necessary to make effective use of E-rate discounts, such as Training End user equipment

JACK O’CONNELL State Superintendent of Public Instruction 98 Other Documentation Reports from any other audits conducted that relate to either E-rate program or the NSLP Eligible Services List for every funding year Board minutes and policies relating to document retention or other E-rate related issues Financial statements and annual budgets

JACK O’CONNELL State Superintendent of Public Instruction Other Levels of Scrutiny Site Visits Selective Review Information Request (SRIR) Cost Effectiveness Review 99

JACK O’CONNELL State Superintendent of Public Instruction Site Visits Single FRN reviewed On-site 4 hour visit Review of –Asset register –Equipment in the field –Staff development –Invoices/payments –Technology plan approval –Competitive bidding Best practices feedback 100

JACK O’CONNELL State Superintendent of Public Instruction Item 25 Selective Reviews PIA on steroids Intensive review of the “Item 25” Block 6 certification from Form 471 Complete documentation of necessary resources hardware, software, professional development, retrofitting, maintenance Competitive bidding documentation Technology Plan Budget – matching funds and support for non E-rate items 101

JACK O’CONNELL State Superintendent of Public Instruction Cost Effectiveness Review Occurs during PIA Must be able to justify that the selected solution is ‘cost effective’, not just the MOST cost effective Bright line test: Routers that cost two to three times the commercially available price Single bid received does not equal cost effective Think about reasons why the price may be inflated Location Structural challenges Anticipated growth of student population, etc 102

JACK O’CONNELL State Superintendent of Public Instruction 103 Appeals Submitted to USAC if you feel program rules were not upheld by the denial of funds Submitted to FCC if you are questioning the existing program rules or if USAC denies the initial appeal

JACK O’CONNELL State Superintendent of Public Instruction 104 USAC Appeals – Approved for Limited Circumstances When the appeal makes it clear that USAC erred in its initial review When the applicant provides USAC with information it did not provide when the original request was made When USAC obtains policy clarification or new policies that impact the original decision peals-guidelines.aspxhttp:// peals-guidelines.aspx

JACK O’CONNELL State Superintendent of Public Instruction Tools – Data Retrieval Tool and Other

JACK O’CONNELL State Superintendent of Public Instruction 106 Data Retrieval Tool Comprehensive data regarding status of applications, past and present –Search by Funding Year, Entity number, State, Type of Service, etc –Provides deadline information for forms –Columns to look at on the DRT for deadline information B: 471 Status E: 470 Status P: Commitment Status (If funded then look at R to see if 486 has been filed) R: 486 SSD (If blank, no 486 on file) T: FCDL date (this date calculates the deadline for the Form 486) AX: BEAR or SPI –

JACK O’CONNELL State Superintendent of Public Instruction 107 View Prior Years’ Applications –Apply Online Form 470 – Search Posted Form 471 – –Application Status (if you don’t know the application number) –Display (must have application number)

JACK O’CONNELL State Superintendent of Public Instruction California Teleconnect Fund

JACK O’CONNELL State Superintendent of Public Instruction Q and A Questions?

JACK O’CONNELL State Superintendent of Public Instruction 110 Contact Information State Library: Rushton Brandis, (916) , CDE: John Vardanega, (916) , CDE: Tech Plans: Bill Fong, (916) K-12 HSN/Butte COE: Russ Selken,

JACK O’CONNELL State Superintendent of Public Instruction CALNET 2

JACK O’CONNELL State Superintendent of Public Instruction 112 CALNET 2 - What is it and how does it fit with E-rate? Contract (s) held and administered by State –CALNET 2 Contract effective date: 1/30/2007 –CALNET 2 contract expiration date: 1/29/2012 Master contract purchasing vehicle for all telecom services Available to all “Public Sector” Customers Competitively bid contract - Result of an 18 month bid process (already bid) Full range of products and services Service Level Agreements

JACK O’CONNELL State Superintendent of Public Instruction 113 CALNET 2 MSAs All four MSAs were signed on January 30, 2007 Each MSA is for a 5-Year Term (to January 29, 2012) with the Potential for 2 One-Year Extensions at the State’s Option (2014) Each MSA is a separate contract called CALNET 2, along with their MSA number. They are also collectively called CALNET 2. Until CALNET I expires you will see “I” and “II” or “1” and “2” after the word CALNET to try to avoid “Contract Confusion” In some cases you will see just “CALNET” - that will mean both CALNET I and CALNET II as applicable; as CALNET I phases out, it will mean CALNET 2

JACK O’CONNELL State Superintendent of Public Instruction 114 CALNET 2 MSAs MSA 1 – Voice, Data & Video Services – AT&T MSA 2 - Long Distance and Network Based Services – AT&T MSA 3 – Internet Protocol Voice, Data, and Video Services – Verizon Business (VzB) MSA 4 – Broadband Fixed Wireless Access Data Services – VzB  10% Lower Pricing Overall From CALNET I

JACK O’CONNELL State Superintendent of Public Instruction 115 CALNET 2 MSAs  Transition of Existing CALNET Services to MSAs I & 2 – No Cost  Transition Out Will Eventually Impact Your Agency; CALNET I Expires by 12/03/08 based on Individual ATO Agreements  CALNET 2 – Each ATO is for a Two Year Term – When Term is Up, Can Use the MSAs Without another ATO For Those Services on the ATO; Adding Services Requires New ATO, New term  New Pricing Starts Within 120 Days of Each Approved CALNET 2 ATO 

JACK O’CONNELL State Superintendent of Public Instruction 116 CALNET 1 to CALNET 2 State Posted Form on Sept 15, 2005 –Includes Telecommunications Services –Did NOT Include ISP –Limited Internal Connections (extended demarc) –CALNET 2 Contract was signed on January 30 th, 2007 (State Master Contract) –CALNET 2: II/calnetII.asp II/calnetII.asp –RFP: rfp.asp rfp.asp May wish to post your own form 470 for all services you will apply for (See additional hand-outs) Do your own analysis to determine best choice for your agency Three Signatures are required on a CALNET 2 contract

JACK O’CONNELL State Superintendent of Public Instruction 117 CALNET 2 MSAs 1 and 2 includes MSA 1 High Speed Optical Services (Enhancements and Additional Services) –ATM –Opt-e-MAN –CSME Enhanced Data Services –MPLS (AVPN) –Remote VPN (Anira) –Interlata Data Services Internet Services Unified Messaging Enhanced Centrex Features –VoIP Business Centrex lines Voice mail Local trunks Frame relay MSA 2 Enhanced Toll Free Long Distance Voice Audio Conferencing Net Conferencing Complete Suite of Call Center Capabilities –ACD –IVR

JACK O’CONNELL State Superintendent of Public Instruction 118 IP Voice, Data, and Video Services (MSAs 3 & 4) Internet Protocol (IP) based solutions to provide voice, video, and data services Voice Over IP (VOIP) Services Converged Services – VOIP Converged Services - IP Transport Converged Services - Required Premise Equipment IP Contact Center Services Other IP Services Wiring and Support Services

JACK O’CONNELL State Superintendent of Public Instruction 119 SLD Guidance for E-rate Yr 11 See Page 5 of SLD Decision Grid for SLD guidance (handout and next slide) Clients either: –post own Form 470 OR –use State’s Form 470 # , posted on 9/15/2005.

SLD Decision Grid

JACK O’CONNELL State Superintendent of Public Instruction 121 How to decide if schools/libraries should post their own Form 470? 1.Are the services you are seeking included in State’s RFP? 2.Are services you are seeking included in State’s Form 470? A.Telecommunications services (Priority 1 services) B.Limitations to State’s Form 470: Form 470 did not include Internet Access Form 470 included Internal Connections defined as: Service or Function: Extended D-Marc Form 470 did NOT include Basic Maintenance on Internal Connections (Priority 2 services) You can do a specific form 470 if the service you need is not covered by the state form 470 (see the limitations described above as examples)

JACK O’CONNELL State Superintendent of Public Instruction 122 Moving from CALNET to CALNET 2 “Steps in Ordering” Work with your Account team to sign ATO & create product list attachment To be legal binding contract, CALNET 2 contract requires 3 signatures: customer + AT&T + State –ATO –Attachment to ATO (product list attachment for svcs to be covered by ATO) has to be initialed by customer

JACK O’CONNELL State Superintendent of Public Instruction 123 CALNET 2 – Multiple SPINS CALNET 2 awarded to two service providers Each Service Provider may have multiple SPINs Verify SPIN with service provider BEFORE filing the Form 471

JACK O’CONNELL State Superintendent of Public Instruction 124 CONTACTS CALNET Transition Questions and Requests for Information –Phone: (916) – CALNET Transition Homepage –URL: Statewide Telecommunications and Network Division Homepage –URL: Department of Technology Services Homepage –URL: DTS-STND and Contractor’s CALNET Homepages, etc.

JACK O’CONNELL State Superintendent of Public Instruction 126 CALNET 2 Contract Resources AT&T Customer Sales & Support Center: CALNET Billing: CALNET, Account Team: –Contact your account team –Bev Agron, E-rate Specialist (925) calnet.ca.gov (select AT&T logo)

JACK O’CONNELL State Superintendent of Public Instruction 127 CALNET 2 Contract Resources Verizon Business Verizon Business – – – (click on Verizon link)