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A YEAR IN THE LIFE OF AN E-RATE APPLICANT

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Presentation on theme: "A YEAR IN THE LIFE OF AN E-RATE APPLICANT"— Presentation transcript:

1 A YEAR IN THE LIFE OF AN E-RATE APPLICANT
Preparing for the Funding Year

2 PLAN FCC 470 EVALS CONTRACT ADMIN WINDOW FCC 471 PIA FCC 486 INVOICE

3 Where To Begin? KNOW THE PROCESS Preparing for the Funding year
E-rate Binder Deadlines Helpful Tips EPC Preview KNOW THE PROCESS

4 COMMONLY USED TERMS SLD- Schools and Libraries Division is the part of USAC with responsibility for E-rate. Billed Entity- The entity that receives the bill and pays for the supported service. Applicant- The entity applying for universal service support (i.e., a school, library, consortium, or other eligible entity that files program forms. )

5 COMMONLY USED TERMS FCC Form 470- competitive bidding form for services desired that are eligible for discounts under the E‐rate Program. FCC Form 471- the application process used for requesting services listed on Form 470. FCC Form 486- The Receipt of Service Confirmation Form. Filed letting you know when service will begin and will comply with CIPA requirements. Funding Commitment Decision Letter (FCDL)- Notification letter sent to applicant after PIA review is complete and the application has been “approved”.

6 COMMONLY USED TERMS BEAR Form- Applicant filed form submitted to USAC for reimbursement (Applicant pays full cost of service and files BEAR for discounted share.) SPI Billing- Service Provider Invoicing method. Applicant pays only their non-discounted share and receives discount for the remainder of the cost of service. Entity Profile- Section in the 471 application to determine discount; a complete list of schools in district. BEN- “Billed Entity Number”- the unique number assigned by USAC to each billed entity that pays for services and/or recipient of service.

7 COMMONLY USED TERMS Funding Request Number (FRN)- Unique number that USAC assigns to each funding request in a completed FCC Form 471. (Three types: Internet Access, Telecommunications, Voice) FRN Key Information: FRN Section of 471 application where the applicant provides details of services requested including service provider, contract information, and category of service. FRN Line-item- Provides detail of services requested, including type, purpose, amount/quantity, and, recipient of service monthly cost of service. Annex: If a school has more than one location separated by a public right-of-way, but all of those locations together are considered one school by the state, those additional locations are annexes of that school *no longer a separate upload but integrated into the Block 5 section of the 471 application process.

8 PREPARING FOR THE FUNDING YEAR
Where to begin? What’s the first step in the process? What do you need before you can file an FCC Form 470? What are the form deadlines? What are your organization's procurement rules? Do they have any procurement guidelines? What’s the last step in the process? What are your technology needs? Have your FY2017 apps been funded? Have you used all your Cat 2 budget? Are your contracts expiring?

9 THE MOST IMPORTANT QUESTION?
PREPARING FOR THE FUNDING YEAR THE MOST IMPORTANT QUESTION?

10 DO YOU HAVE A CLEARLY DEFINED PROCESS?
PREPARING FOR THE FUNDING YEAR DO YOU HAVE A CLEARLY DEFINED PROCESS?

11 PREPARING FOR THE FUNDING YEAR
Define your process (if you don’t have one). Teach your process to someone else (if possible). The first step in passing an audit is ___________ ?

12 PREPARING FOR THE FUNDING YEAR
Define your process (if you don’t have one). Teach your process to someone else (if possible). The first step in passing an audit is being organized .

13 THE E-RATE BINDER

14

15 Competitive Bidding COMMON AUDIT FINDINGS
State and local procurement rules not followed. Applicants must follow E-rate and state and local procurement rules when conducting the competitive bidding process. Most cost effective solution not selected. Applicants should select the most cost effective solution with price being the primary factor when conducting competitive bid evaluation. Documenting the bid evaluation will help demonstrate how your vendor selection was conducted. *Cardinal Rule Change

16 Competitive Bidding COMMON AUDIT FINDINGS
RFP or similar document not shared with all potential bidders. Applicants must conduct a fair and open competitive bid process. Information should be available to all potential bidders. Contract was signed prior to the 28 day waiting period. Applicants should not award or select the vendor prior to the 28 day waiting period. Not restarting the 28 day waiting period*. Applicants should restart the 28 day waiting period when a cardinal change to the RFP or similar document is made. Applicants should not start to evaluate bids until the final 28 day waiting period ends. *Cardinal Rule Change

17 Invoicing COMMON AUDIT FINDINGS
Overbilling. Applicants should review service provider bills for errors prior to paying the bill to ensure overbilling does not occur. Submitting invoicing to the cap. Applicants should submit invoices for services they received. Services not approved. Applicants should only submit invoices for services approved in the Funding Commitment Decision Letter (FCDL). Compare your FCDL to the services you requested on your FCC Form 471 or Item 21 attachment. *Cardinal Rule Change

18 Invoicing COMMON AUDIT FINDINGS
Invoiced for recurring services delivered beyond service deadline. Recurring services must be delivered during the fund year requested. Applicants should not invoice for services beyond the delivery deadline. Invoice beyond the invoice deadline. Submit invoices timely. Request an invoice deadline extension if needed. Services delivered or installed are not at the correct physical location. Applicants should ensure equipment is installed at the correct location. Update your address with USAC if the location has changed. *Cardinal Rule Change

19 COMMON AUDIT FINDINGS Products not delivered and/or installed.
Applicants should not invoice for items prior to the delivery or installation. Do invoice once items are delivered and/or installed. Retain delivery and installation records. BMIC not supported by actual services performed. Applicants should not use generic blanket terms that do not differentiate between eligible and ineligible services. Do maintain documentation that demonstrates the amounts and services actually delivered. *Cardinal Rule Change

20 DOCUMENT RETENTION Documentation must be retained for at least 10 years after the latter of the last day of the applicable funding year or the service delivery deadline for the funding request. Documents can be in electronic format or paper as stated in the E-rate Modernization Order (FCC 14-99). Applicants and service providers must retain ALL documentation that shows compliance with all FCC rules. Any document from a prior year that supports current year activities must be kept for a period of 10 years after the last day of service delivered. E.g., contract from 2005, used to support FY2016 recurring service FRNs, must be kept until at least June 30, 2027.

21 DOCUMENTS TO RETAIN RFPs or similar documents
This list is for illustrative purposes. Service providers and applicants must retain pursuant to recordkeeping requirement, as applicable. RFPs or similar documents Delivery and installation records All bid responses and correspondence Maintenance logs Contracts, service agreements, addendums, etc. Payments (canceled checks, credit card receipts, ACH transactions) Purchase requisitions, POs, packing slips, customer bills

22 DOCUMENTS TO RETAIN This list is for illustrative purposes. Service providers and applicants must retain pursuant to recordkeeping requirement, as applicable. USAC-approved SPIN changes and/or service substitutions (request, supporting documentation, and approval) Documents used to prepare forms FCC forms and letters received from USAC (e.g., FCC Forms 498, 474) USAC-approved invoice deadline extension, service delivery and service substitution (request, supporting documentation, and approval) Service provider price listings

23 PLANNING AHEAD

24 KNOW YOUR DEADLINES DEADLINE CALENDAR Holiday Form filing deadlines
Clarifies that Section 1.4(j) of the Commission’s rules provides that if the filing date falls on a holiday (Saturday, Sunday, officially recognized federal legal holidays, and any other day FCC offices are closed and not reopened prior to 5:30 pm), the document shall be filed on the next business day, regardless if program rules state specific date

25 PLANNING PLAN YOUR YEAR 470 Posting Date Application Window Opens
470 Closing Date Application Window Closes Application Filing Date PLAN YOUR YEAR

26 (Competitive bidding)
THE E-RATE YEAR Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun FCC Form 470 (Competitive bidding) PIA Review FCC Form 471 (Application) July 2018 – June 2019 Invoicing Risks: May not get funded, provider may not offer discounted billing, FCC states if you start the process before receiving FCDL “you’re on your own”. 486: if funded, file 486 and submit BEAR as soon as you receive the NL.

27 HELPFUL TIPS

28 HELPFUL TIPS USAC Website USAC Tools DOE Student Data
Recourses and Links USAC Website Webinars USAC Tools FRN Status 471 Data Dump DOE Student Data Code of Federal Regulations (CFR) EPC Training Sites BEAR Training USAC News Briefs DMS Website Valid File SUNCOM Contracts Training Page Eligible Service List Past and Present

29 DATA

30 470 471 PIA Invoice FCDL Denials Reductions
Does it match the 470? 471? Student counts FRN data Quantities Service type drop down 470 471 PIA Invoice

31 EPC PREVIEW

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