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Step 4: Entity profiles and FCC Form 471
Date needed for discount calculation and 471 creation Step 4: Entity profiles and FCC Form 471
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PROCESS CHECK We have… Posted 470 Waited 28 days
Kept process “open, fair, and competitive” by posting Q&A and other related RFP docs: No secrets Every potential bidder has the same info at the same time All’s fair in love and competitive bidding.. Restarted 28 day clock for any substantive changes.
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PROCESS CHECK We have… Evaluated ALL bids
Selected the winning provider. Documented all necessary processes and decisions Cost effectiveness Winning and losing bids (including those disqualified) Memorization date of approved bid/contract If possible, entered into a legally binding agreement… Signed a contract or a month-to-month agreement
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PROCESS CHECK We need to…
Complete contract module for all **new** contracts Complete connectivity questions (if data has changed) Gather all necessary FRN/Line-item data Update entity profiles Including new schools, library outlets, student counts, NSLP, square-footage, etc. *make sure to call CSB to create BEN’s for new entities
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PLAN FCC 470 EVALS CONTRACT ADMIN WINDOW FCC 471 PIA FCC 486 INVOICE
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Competitive bid exemptions
Options for avoiding the 470 process Competitive bid exemptions
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COMPETITIVE BID EXEMPTION
(e) Exemption to competitive bidding requirements. An applicant that seeks support for commercially available high-speed Internet access services for a pre-discount price of $3,600 or less per school or library annually is exempt from the competitive bidding requirements in paragraphs (a) through (c) of this section. (1) Internet access, as defined in §54.5, is eligible for this exemption only if the purchased service offers at least 100 Mbps downstream and 10 Mbps upstream.
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STATE MASTER CONTRACT Per USAC website:
A state master contract is a contract that is competitively bid and put in place by a state government entity for use by others. The applicant may cite the state's FCC Form 470 (procurement documentation form) on its FCC Form 471 (E-rate application). Only applicable with certain SUNCOM SMC’s (mobile communication)
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STATE MASTER CONTRACT State Master Contracts (SMC) SUNCOM
Voice Services Internet Access WAN DMS pays the Service Provider bills. As the applicant, State Coordinators complete and certify ALL E-rate forms on behalf of the end-user.
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STATE MASTER CONTRACT This includes:
State Coordinators complete and certify ALL E-rate forms on behalf of the end-user. Other forms: Audits, service substitutions, invoice reviews, PIA inquiries, appeals, etc. This includes: FCC Forms: 470, 471, 486, 472, 474, 500.
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NEW SUNCOM State Master Contract
MY FLORIDA NET 2 (MFN2) The Challenge – Federal and state bandwidth goals with per student Gigabit Internet access demands create the need for upgrade plans and budgeting. Capability Internet Gigabit High Speed Access, (Speeds 500MB, 1, 2, 3, 5, 10, 20, 30, 40GB) with fixed access price points to provide you the capability to budget and plan for future growth.
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NEW SUNCOM State Master Contract
MY FLORIDA NET 2 (MFN2) FIRN2 services are delivered on fiber access that provides Broadband from the premise to the POP. Internet Services are carried to the edge of the Network to the hosts on broadband connections without aggregation, providing a pure end to end broadband connection. Options available for Routers, Firewall, Advanced Security , Monitoring, on site security Audits , DDOS Mitigation, Content filtering, VPN. On-site or cloud based. For more information: Make an appointment to coordinate an on-site briefing
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Calculating discounts
NSLP, CEP, and Alternative Methods Calculating discounts
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CALCULATING DISCOUNTS
VIABLE DATA SOURCES NSLP Participation Community Eligibility Provision (CEP) Survey Financial Aid forms State Agency Valid file Official State Agency Reports Confirmation from State Agency staff* Think like an auditor! These are PIA-friendly data sources. Re Survey - alternative discount mechanisms – such as income surveys, sibling matches, and participation in certain federal programs – can be used to establish eligibility on an individual student basis. *Re “Confirmation from State Agency”: Applications This is the valid file or another state report PIA/ Audits We can provide confirmation, but require back-up We still will request backup detail (NSLP Participation, Survey, Financial Aid forms, etc.) Make sure that leadership person signs off on backup docs from applicant entity (Food and Nutrition Services Administrator or Superintendent, etc.)
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NSLP & CEP E-rate Worksheets on state agency website:
DMS DOS DLIS Community Eligibility Provision (CEP) Annual Notification of Local Educational Agencies (LEA) DOE EIAS reports (e.g. Surveys, ADA/AMA Report) Reimbursement Claim Form/ printout from the Florida Automated Nutrition System (FANS) portal signed (preferably by the Principal, Vice-Principal, Superintendent or Director of Food Services) of a that the school submits to the state each month as part of their participation in the program. DOE no longer posts E-rate worksheets (aka valid file.) CEP is a non-pricing meal service option for schools and school districts in low-income areas EP allows the nation’s highest poverty schools and districts to serve breakfast and lunch at no cost to all enrolled students without collecting household applications CEP are reimbursed using a formula based on the percentage of students categorically eligible for free meals
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ALTERNATIVE METHODS SURVEY
= Actual response results / Total population Must be sent to all families whose children attend the school Must, at a minimum, contain the following information: Name of family and students Size of the family Income level of the family Results cannot be older than two years before the start of the funding year No longer able to extrapolate/ project;
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ALTERNATIVE METHODS SURVEY
Existing Sources e.g. need-based tuition assistance SNAP, TANF, etc. Provision 1, 2 or 3 Schools Schools must be able to produce documentation e.g. copies of its site application, approval letter from its state to participate in that provision, base year statistics, and the state letter approving an extension SNAP- Supplemental Nutrition Assistance Program TANF : Temporary Assistance for Needy Families
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Data needed to complete entity profiles and the FCC Form 471
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ENTITY PROFILES
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ENTITY PROFILES
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ENTITY PROFILES Part-time students count towards Cat 2 budget
A number must be entered into part time fields, Rural/Urban status, and discount method to complete your entity profile Must be completed prior to end of administration window
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ENTITY PROFILES- CEP CEP is PRE multiplier
Some districts operate with a district CEP percentage CEP percent does not change for at least four years. If percent increases, you may use higher percentage. If lower, you may use the original percent. Would need to send out new survey (paid for by applicant) to determine if percent of identified students has changesd.
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ENTITY PROFILES- CEP
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NON-TRADITIONAL STUDENTS
Eligibility Table for Non-Traditional Education Head Start Students 4+ years old = 100% NSLP Eligible Head Start services for children <3 years old ≠ Eligible Home-based Head Start programs ≠ Eligible. Need to include students in population if they are eligible even if their location is precluded from receiving support for services.
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ELEMENTS OF THE 471 Application (471) Funding Request (FRN)
Contact Information Entity Profiles Cat 1 or Cat 2 Funding Request (FRN) Contract/MTM/Tariff Narrative Type Voice Internet Access and/or DT FRN Line-item Purpose WAN? Internet Access? Same speed, same price = one line-item Same speed different price = separate line-item Recipient of Service
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Can be pre-validated prior to PIA through State Coordinator office
AUDIT PREVENTION Use validated data for everything! Total student counts NSLP Part time counts Rural/Urban Status (if different from what USAC has) Can be pre-validated prior to PIA through State Coordinator office
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AUDIT PREVENTION 3rd Party Validation Discount Calculation New School
When using alternative discount methods, PIA may ask for “3rd Party Validation” to support your discount calculated in EPC. Discount Calculation New School Valid Head Start Total Student Eligible for NSLP School Closing
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AUDIT PREVENTION 3rd Party Validation To PRE-validate:
Send to with: Narrative explaining exactly what data needs to be validated Copy of PIA inquiry PIA deadline Supporting documentation
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AUDIT PREVENTION FCC Form 471 & delivery confirmations/2.3. FCC Form 471 Out of Window Letter (OOW) FRN line item back up data Discount calculation back up data FCC Form 471 Receipt Acknowledgment Letter (RAL)
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AUDIT PREVENTION CIPA (CHILDREN’S INTERNET PROTECTION ACT)- INTERNET ACCESS ONLY Undertaking Actions to comply with CIPA (e.g., public notice, public meeting or hearing minutes, Filtering Documentation (purchase, installation, use) Internet Safety Policy CIPA Adopts rules proposed in the Further Notice of Proposed Rulemaking to implement the Children’s Internet Protection Act (CIPA) for Schools and Libraries program.
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DEMO FCC Form 471
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