What Documents Should I Keep? Back to the New Basics Schools and Libraries Division Washington, DC Orlando Boston New Orleans Cleveland San Francisco Phoenix September/October 2007

2 Overview  Document Retention Rules  The Top Five “Missing” Documents  USAC Tips & Tools

3 Retention Rules How long should you keep your documents? A.Until I run out of office space. B.Five years. C.Period of five years after the last day of service delivered for a particular FY.

4 Retention Rules Answer is C.  Period of five years after the last day of service delivered for a particular FY  Effective in FY 2004

5 Retention Rules Examples: Application Fund Year Application Commitment Year Keep Documents At Least Until 2003Committed in FY03Follow your state’s document retention rules 2001Committed in FY06Keep at least until  Committed in FY05  Service delivery extension in 2006 Keep at least until 2011 unless other extensions are requested 2004  Committed in FY04  RFCDL issued in 2007 Keep at least until 2012 unless other extensions are request

6 Retention Rules Who should retain documents? A.Applicants B.Service Providers C.Consultants

7 Retention Rules Answer is A & B.  “…our rules to require both applicants and service providers to retain all records related to the application for, receipt and delivery of discounted services …”

8 Retention Rules USAC will ask to review documents: Compliance review (PIA, CIPA, Invoicing, COMAD, etc.) Audits Site visits Appeals

9 Retention Rules Reasons to keep good records:  To ensure applicants & service providers comply with program rules  Protect applicants & service providers in the event of disputes  Prepare appeals  Audits (E-rate and applicant internal audits)  Archive for successors  Prevent waste, fraud and abuse

10 Retention Rules Consequences of “poor” recordkeeping  Non-compliant audit findings  FRN modified or denied  Invoice rejected  Funds COMAD/RIDF  Heightened Scrutiny application review  Red Light status

11 Missing Documents Top 5 Missing Documents 1.Discount verification (NSLP, survey, etc.) 2.Asset listing not maintained or updated 3.Signed and dated contracts 4.Consultant agreement or LOA 5.Bid evaluation/ Award schedule

12 Missing Documents Facts & Figures  At the time of the initial visit: 63% IPIA Audit Beneficiaries and 40% of Site Visit applicants were missing documents in 2007  As of June 2007, 97% of Site Visit applicants are aware of FCC documentation requirements

13 Tips & Tools USAC Tip:  Maintain an “E-Rate Binder” –Binder or filing system housing copies of documents or document location –Can be organized by FY, BEN, or Application –Paper or electronic filing system

14 Tips & Tools USAC Tool:  USAC E-Rate Binder Table of Contents –Records retention guide –Contains a list of key documents commonly requested during programmatic reviews, Site Visits and audits –Headings are organized by forms, letters, programmatic reviews, change requests, and invoicing

15 Tips & Tools  USAC E-Rate Binder Table of Contents –Downloadable Table of Contents Guide –Downloadable Table of Contents (Word document preformatted for Avery© Ready Index 10) –Located in USAC web site Reference Area –Hyperlinks to USAC web site Reference Area, samples & checklists

16 Tips & Tools  USAC Forms  USAC Letters  Technology Plan & Approval Letter  Competitive Bidding, Vendor Evaluation & Contracts  PIA Review USAC Table of Contents Sections

17 Tips & Tools  CIPA (Children’s Internet Protection Act)  Service Delivery & Inventory Management  Invoicing & Payments  Change Requests & Appeals  Miscellaneous USAC Table of Contents Sections

18 Tips & Tools USAC Tools:  Sample Documents –“Good” or “Acceptable” documents –Resource for applicants to develop their own documents –Located on USAC website Reference Area –Technology Plan Sample is available

19 Tips & Tools USAC Tools:  Sample Documents  Service Sub Request  Income Survey for Discount Calculation  Bid Evaluation Matrix  Technology Training Sign In Sheet  Professional Development Training Calendar  Letter of Agency (Consortium) More to Come!

20 Tips & Tools USAC Tools:  Checklists –Documents applicants can use when preparing a request or responding to USAC inquiries –Prevents omitting information needed for preparing a request or responding to USAC inquiries –Located on USAC’s website in Reference Area

21 Tips & Tools USAC Tools:  Checklists  Appeals  Service Substitution  SPIN Change MORE TO COME!

22 Tips & Tools USAC Tips:  Check your dates & signatures –Make sure you have an applicant signed and dated contract –Make sure the contract complies with state and local procurement rules  Keep paper copies of “e-certifications” –Websites often are updated or changed, so print out a copy of your certification with the date  Keep web addresses & e-reference material –Websites often are updated, keep updated information on state master contracts

23 Documents to Keep  USAC Forms –Filing & Certifying online print a copy of the form retain online cert id –Filing & Certifying paper Copy the original Maintain a copy or proof of postmark dates –Consortium members Form 479 (Verification of CIPA compliance)

24 Documents to Keep  USAC Letters –Generally are printed on colored paper –The Administrator’s official decision –Applicant & Service Provider should always review for accuracy of: Contact information FRN count Funding request amount Funding decision

25 Documents to Keep  Technology Planning & Approval Letter –Written technology plan with the creation date –Approved technology plan with effective dates –Copy of the approval letter Paper copy or Dated screen print of the certification –Technology plan updates

26 Documents to Keep  Competitive Bidding, Vendor Evaluation, & Contracts – Maintain reference information about state and local procurement regulations – Bidding Notices (RFP, RFI, advertisement, etc.) –Evaluation criteria & matrix –Winning and losing bid responses –Vendor and internal correspondence

27 Documents to Keep  PIA Review – Letter of Agency (Consortium or Consultant) – Signed and date contracts Extensions, Addendums, Amendments Board approval & board minutes Notice of award letters – Discount Calculation

28 Documents to Keep  PIA Review – Product and service documentation Item 21 Attachment Tip: Online submissions print detail Item 21 and confirmation page Service agreements Eligible & Ineligible Items (hardware & software) Network diagrams Product description

29 Documents to Keep  PIA Review –Budget & Funding Information Budget information should contain discount and non-discount funds Grant letters, board resolutions, draft and approved budgets Superintendent or School Official letter (reasonable expectations to secure financial resources by the time services are delivered)

30 Documents to Keep  PIA Review –Entity Eligibility Charter Matching Records State law or provision –PIA review Responses to PIA questions Supporting documentation

31 Documents to Keep  CIPA (Children’s Internet Protection Act) –Filtering documentation (purchase, installation and use) –Internet safety policy & board approval –Actions taken to comply with CIPA in the first funding year Public Notice Hearing Minutes from the hearing or meeting

32 Documents to Keep  Service Delivery & Inventory Management –What date did you receive service? –Who received service? –Where are the items located? –Were the items replaced, maintained, or transferred? (if so, remember to record the new serial numbers) Tip: Color code equipment labels by fund year and include application number and FRN on label.

33 Documents to Keep  Invoicing & Payments –Invoices and customer bills –Payments Maintain payment records for discount and non-discount amounts for each FRN –Reimbursements from vendors –Memorandums or correspondences –Service Certifications –Quarterly Disbursement Report

34 Documents to Keep  Change Requests & Appeals –Change Requests Requests submitted to USAC to modify the Form 471 post-commitment (SPIN change, Service Substitution) Notify USAC you are transferring equipment to due school or library closing Service delivery and/or payment timeframes have changed

35 Documents to Keep  Change Requests & Appeals –Appeals The appeal request submitted to the FCC and/or USAC Delivery receipt (Proof of postmark, fax or confirmation) Supporting documentation

36 Questions?