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EASY AS 1, 2, 3 E-rate for Beginners PRESENTED BY: JULIE TRITT SCHELL PENNSYLVANIA E-RATE COORDINATOR OCTOBER 2011
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What is E-rate? 2 Telecommunications Act of 1996 established “Universal Service Discount Program for Schools and Libraries” Annual $2.25 billion program ($2.29 with inflation) Provides 20-90% discounts on eligible services Fund made up from charges on your phone bills FCC sets policy/USAC-SLD runs the program What is my E-rate discount? 2 factors used to determine discount
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Who is Eligible? Public libraries eligible for LSTA funding Public and private K-12 schools For-profit schools not eligible Pre-k eligible in PA (age 3+) Head Start entities eligible in PA but only if operated by a public school entity Residential facilities of school eligible beg. FY 2011 Non-instructional facilities (such as admin bldgs) are eligible Cannot have endowment exceeding $50 million 3
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E-rate Discounts: Poverty Based on National School Lunch Program Eligibility Eligibility based on % of students whose family’s income is less or equal to 185% of federal poverty level Doesn’t matter if school serves lunch or participates in NSLP Nonpublic schools use their own students’ data NSLP data at www.e-ratepa.org Don’t participate in NSLP? Income survey method available 4
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E-rate Discounts: Location Urban/Rural defined by Counties Uses Metropolitan Statistical Area data Many seem misclassified List of Rural counties on PA E-rate website – www.e- ratepa.org Under “discount calculations’ 5
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Discount Matrix for Single School/Library 6 INCOME Measured by % of students eligible for NSLP URBAN LOCATION Discount RURAL LOCATION Discount If the % of students in your school that qualifies for the NSLP......and you are in an URBAN area, your discount will be......and you are in a RURAL area, your discount will be... 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%
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Discount Calculations by Entity Schools Use straight matrix discount Districts Use weighted average of schools’ individual discounts Consortium Use simple average of members’ discounts 7
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Alternative Measures to NSLP Participation in these programs also qualifies: TANF Medicaid Food Stamps Supplementary Security Income Federal public housing assistance (section 8) Low Income Home Energy Assistance (LIHEAP) Can conduct family survey (whether you participate in NSLP or not) Not acceptable - Title 1, feeder schools method, principal’s estimate 8
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So Much Demand, So Little Money 9 Funding Priorities needed because demand exceeds cap of $2.29 billion Priority 1: Telecommunications and Internet Access All approved-inside the window-likely to be funded Priority 2: Internal Connections and Basic Maintenance of IC Funds go first to neediest applicants (90% discount level), then to others in order of discount until funds are exhausted
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Eligible Telecom Services (P1) 10 Basic Telecom Services Local, long distance, voice mail, cell, paging, centrex Advanced Telecom Services T-1, PRI, ISDN, lit fiber, dark fiber, etc. Leased WANs Vendor equipment located on customer premises Installation of eligible telecom services Including most taxes and surcharges and custom calling features Hosted VOIP (can also be under Internet Access)
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Ineligible Telecom Services 11 900 Calls Payphone service Cost of not-publishing phone numbers Cost of additional directory listings End user equipment (phones, beepers, cell phones, fax machines, etc.) Late fees, admin fees Paper statement fees
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Internet Access (P1) 12 Eligible: Basic conduit access E-mail service Laptop aircard service Basic webhosting Blackberry/data services Hosted VOIP Ineligible: Filtering AntiVirus/AntiSpam Website creation tools
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Eligible Internal Connections (P2) 13 Network and phone wiring Routers Switches, hubs Certain network servers Video codecs VOIP equipment System operating software For eligible equipment only Wireless access points Private branch exchange (PBXs) Installation Limited maintenance Only for actual work performed Software/patches/online support
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P2: To Apply or Not to Apply? FY 2004 – down to 81% FY 2005 – down to 80% FY 2006 – down to 86% FY 2007 -- down to 81% FY 2008 -- down to 87% FY 2009 -- down to 77% FY 2010 – all requests funded FY 2011 – down to 90% so far 14
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WHO IS ELIGIBLE? WHAT IS ELIGIBLE? HOW TO DISCOUNTS? 15 Questions?
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General Framework 16 PlanBid ApplyApproval! Receive Services Pay Full Invoices USAC Pays Applicant Pay Discounted Invoices USAC Pays Vendor
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Step 1: Technology Plan! 17 Beginning with FY 2011, E-rate will not require technology plan for Priority 1 services Priority 2 requests must have approved technology plan containing these 4 criteria H Goals and Strategies for using technology H Needs Assessment H Professional Development Evaluation Must be “written” before Form 470 is filed and must cover full 12 months of NEXT funding year 3 year max Nonpublic tech plan approvers on SLD website
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Step 2: Competitive Bidding 18 All E-rate services must be competitively bid Every year unless under a multi-year contract that was bid under E-rate rules initially MTM services Even… if no competition in your area
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How? Must Use Form 470 19 Must file a Form 470 online All 470’s posted on SLD web site Cannot select vendor until 29 th day after 470 is posted But must have Form posted on web at least 29 days before the Form 471 window close (example: March 24 close = Feb 24 deadline) Don’t wait this long Be sure to list services in correct category If unsure, post in several categories Read the Instructions !
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Online Form 470 20
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Get 470 Information Immediately! Posted 470 available immediately on SLD web site to view Online 470 shows: Posting date of application Earliest date that your contract can be signed and thus 471 submitted Date that certification page was received at the SLD 21
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Step 3: Bid Evaluation After 470 is posted for at least 28 days, review all bids received for all services Create bid evaluation matrix Price of eligible services/components MUST be the most heavily weighted factor Keep: documentation of criteria used to select vendor all winning and losing bids bid evaluation matrix all correspondence between applicant and all vendors (winning and losing) 22
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Step 3: Bid Evaluation What should you do if you receive no bids? Document via an email or file memo that no bids were received Existing Services: can continue to receive services from existing service provider New Services/Procurement: Solicit bid from willing vendor (who is not your brother-in-law) Make sure price is cost-effective 23
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Step 4: Filing the 471 24 Form that requests discounts (funding) Filed by entity that actually pays the bills Shows discount calculations Lists which 470 was used to bid services, provides contract signing dates, contract amounts Must be filed by close of 471 filing window FY 2012 window dates: Not Yet Announced Will likely be first week in January – mid March
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Step 4: Item 21 Attachments Item 21 attachments provide descriptions of actual services Because no space to do so on the 471 Must have separate description for each FRN (funding request/Block 5) Detailed list of products with associated prices that add up to funding request List # of lines, speed, and description of service File online or on paper (online preferred) Beginning FY 2011, Item 21 attachments MUST be submitted by Form 471 deadline Keep 471 Security Code to access Online Item 21 Attachment system 25
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Step 5: PIA Review 26 Program Integrity Assurance (PIA) Review Checks for rule compliance Eligible services Eligible entities Appropriate discount Nearly all applicants receive PIA contact
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Step 5: SLD Mails FCDL 27 FCDL = Funding Commitment Decision Letter Tells you which funding requests (block 5’s) of Form 471 are approved or denied Provides information for the next form -- Form 486 Can appeal if you don’t agree with your decision
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Step 6: Applicant Files Form 486 28 Must be postmarked no later than: 120 calendar days after the Service Start Date featured on the Form 486 or 120 calendar days after the date of the Funding Commitment Decision Letter whichever is later. Signifies that it’s OK for SLD to pay any invoices Lists who approved tech plan (if required) Certifies CIPA compliance
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CIPA 29 Childrens’ Internet Protection Act Any applicant receiving Internet access or Internal Connections funding must: Have a board-approved Internet Safety Policy Filter Internet going to all computers/devices Requires schools’ Internet Safety Policies include "... educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response." This means that schools will be required to teach online safety to students as a prerequisite to receiving E-rate funding Effective July 1, 2012
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How Do You Get E-rate $? 30 Two choices Discounts on bills (your vendor invoices USAC) or Reimbursement process (applicant pays bills in full, then invoices USAC) Applicant submits Form 472 – BEAR Form for reimbursement Must select one method or the other for entire year Can be different choice for each funding request
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eCertification/PINs E-rate PINs can be used to file E-rate forms online PIN assigned to a person and is specific to that entity while employed at that entity Not given to an entity No way to request a PIN Must sign a paper certification of a 470, 471 or 486 SLD will mail them a PIN in a small white mailer Can still submit these forms online, but cert page must be signed and mailed to USAC PIN then may be used to 470, 471, 486, and BEAR Forms 31
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Paying Your Share Applicants required to pay non-discounted portion of cost Cannot be waived by the vendor Vendor cannot provide a “grant” Funding must be in budget or draft budget Must keep all invoices and copies of cancelled checks for 5 years after last day to receive service 32
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Can You Request Extensions? Depends on the form and requirement Form 470 – no Form 471 – no Form 486 – no but they will send a reminder letter and you can then file if you missed the original deadline Form 472 BEAR – yes. Must be submitted by original deadline Service delivery – recurring services – no Services must be delivered between July 1 – June 30 Service delivery – non-recurring services – yes Installations and equipment purchases have until Sept 30 If applicant needs more time, they must request extension prior to Sept 30 PIA inquiries – yes If you cannot provide the info by the deadline, you may request extension, but it may not be granted 33
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Resources to Remember 34 SLD web site: www.usac.org/sl SLD Help Desk: 888-203-8100 PA E-rate listserve E-mail me name/e-mail address to subscribe jtschell@comcast.net PA E-rate website: www.e-ratepa.org
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