1. E-rate: A Review for 2010 E-rate: A Review for 2010 - Session starts at 3pm – (slides, Nov. 10 version) Steve Sanders 608-266-3856 stephen.sanders@dpi.wi.gov Bob Bocher 608-266-2127 cell 608-212-2773 robert.bocher@dpi.wi.gov November 10 and 12, 2009

2. 2 Agenda 1. Overview of the program 2. Eligibility and discounts 3. Technology plans 4. Application forms, follow-up processes 5. Common issues 6. TEACH and BCN update Video and PowerPoint: http://dpi.wi.gov/pld/erate.html http://dpi.wi.gov/pld/erate.html

3. 3 Overview r Created by 1996 Telecom Act r $2.25 billion annually from interstate phone revenue m Can use rollover funds m WI averages $25 million annually r FCC has regulatory and legal oversight r SLD does program administration m SLD division of USAC r Eligible applicants m K-12 public and private schools, CESAs, Head Starts m Public libraries, library systems r Program has many acronymsacronyms The Telecom Act created a program to enable “access to advanced telecommunications and information services for K- 12 schools and public libraries.”

4. 4 Check your application status at http://www.sl.universalservice.org/FY3_form471/471StatusCheck.asp http://www.sl.universalservice.org/FY3_form471/471StatusCheck.asp

5. 5 What Are The Eligible Services? r Priority 1 m Telecommunications services (telco’s only)  Local/long distance, wireline and wireless, voice, video, data  FCC Nov 3 Public Notice emphasizes bandwidth m Internet access  Basic access r Priority 2 m Internal connections (2 in 5 year rule) m Basic maintenance of IC (each year) m Very few WI applicants get P2 m Funding now at 85%, may drop to mid-70s Demand exceeds funds available. Priority 1: F unded first. Priority 2: Funded starting at highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.

6. 6 2010 Eligible Services List (ESL) r Official 2010 ESL not yet released by FCC m ESL release opens 471 filing window r FCC issued draft ELS in June m Clarifies that text messaging is eligible m Email archiving is ineligible (archiving vs. storage issue) m Interactive "white boards" are not eligible m VoIP may be applied for as telecom or Internet access r FCC Nov. 3 Notice: m Expand eligible services to PCs, staff CE?

7. Eligible Services r If it’s not in the ESL, assume it’s not eligible r Must be used in an eligible location for eligible purposes r See SLD site “Determine Eligible Services”Determine Eligible Services r Ineligible components/services must be removed m Full funding may be provided as Ancillary Use r Funding requests must be cost effective r Update on TEACH and BCN USAC will not approve funding requests that have unreasonable costs compared to the marketplace. -FCC’s 2003 Ysleta OrderYsleta Order

8. 8 How Much Discount Can I Get? r Discounts range from 20% to 90% m Based on free/reduced lunch eligible m Enrollment and lunch data entered on ISES  Data now being reviewed, most districts doing revisions r DPI does not verify schools using their own data r DPI posts Excel file mid-December m DPI sends file to SLD m If you use DPI data and are contacted by PIA, contact DPI r Actual Calculating Discount Methods done on Form 471Calculating Discount Methods

9. 9 Discount Matrix Percent of Eligible Students UrbanRural Less than 1%20%25% 1% - 19%40%50% 20% - 34%50%60% 35% - 49%60%70% 50% -74%80% 75% -100%90% State average is 57%

10. 10 Technology Plans r Technology plans must be “developed” before the Form 470 is filed. (1 st step in process) r Plans must support requested services on Form 470 r Plans must be approved before service begins, usually July 1, 2010 r Technology plans must cover the entire funding year for which a service is being sought. (Can’t expire before June 30, 2011)

11. 11 Technology Plans Timelines for Information and Technology Plans Plan Expires Developed prior to 470 Filing ** Plan to DPI by: Plan Approved by: June 30, 2010Dec 2009May 1, 2010July 1, 2010 ** E-Rate Note: A change in the E-Rate technology plan requirements occurred in August 2004. Technology plans must be “ developed ”, but not approved, before Form 470 is submitted.

12. 12 CIPA/NCIPA Compliance (Children's Internet Protection Act) See DPI’s CIPA FAQ at: http://dpi.wi.gov/pld/cipafaq.html  Compliance with CIPA required for: o Internet access o Internal connections o But not telecommunications  CIPA requires filtering and having an Internet Safety Plan  New law will require Internet safety policy to 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.

13. 13 Form 470 posted Wait 28 Days Pick vendor, sign contract Submit 471 Tech Plan before 470 RNL RAL Select vendor, cost main factor. If no bids, applicant selects provider. E-Rate Flowchart* (Part 1) * See also the SLD’s flowchart See also the SLD’s flowchart Oct - Dec Dec – Feb ?

14. 14 PIA Review Form 486 – Service Start FCDL - Decision BEAR (472) Discount on bills Form 500 (optional) SLD mails applicant and service provider a BEAR approval letter. Applicant can appeal a denial of funding to the SLD within 60 days of date on FCDL. SLD mails applicant and service provider a 486 approval letter. E-Rate Flowchart (Part 2) July – Oct April - Aug

15. 15 Forms and Deadlines Form or EventDeadline or Dates Funding Year  July 1 through the following June 30; Current year is 2009. Applying for 2010. Form 470  Starts request for services. Must be posted at least 28 days before the filing Form 471. Note (1) timeframe for all bids (2) Form 471 filing closing date. Will receive Receipt Acknowledgement Letter – RAL. 470 deadline will be late Dec. or Early Jan. Form 471  Tells SLD what services you want, the provider, costs, schools getting services, discount %, contract or MTM, etc. Will probably be due early February 2010. Will receive Receipt Notification Letter – RNL. PIA review  SLD’s Program Integrity Assurance (PIA) staff review all applications, which can take over 8 months. PIA will contact you with questions. FCDL sent  Starting late April, Funding Commitment Decision Letters sent to applicants. This continues for months. Form 486  Confirms start of service. Must be received/postmarked within 120 days after FCDL date or 120 days after the Service Start Date, whichever is later. Form 472 / Form 474  Get discounts on bills (#474) or reimbursements (#472). Received or postmarked no later than 120 days after the date of the Form 486 Notification Letter or 120 days after the last date to receive service, whichever is later. Appeals  Must be received within 60 days of date on the FCDL. DPI can help with appeals.

16. 16 Form 470

17. 17 Form 470 r 470 begins bidding process, must be filed for 2010 470 begins bidding process m If you have no contract for the requested services  Often tariffed or monthly telco or Internet service m If a contract expires on or before June 30, 2010 r File 470 once for length of multi-year contracts or contracts with voluntary extensions m 470 and any RFP must indicate this  Check 7a and b and both options under b m In out years on the 471, site the original 470 r Be sure to file for correct category of service

18. 18 Form 470 r Can file the 470 now for 2010 services m Be certain to have draft Tech Plan r File one 470 for all services, or file separate forms for each service r 470 must be posted on SLD website for at least 28 days before you select a provider or sign a contract r See “Form 470” in News Briefs (10-30 Brief)News Briefs 10-30 Brief Form 470 drop dead filing date is 28 days before 471 deadline. But do not wait until then! 137 WI applicants have already filed 236 form 470s.

19. 19 Form 470 and Competitive Bidding r Must have a fair and open bidding processfair and open bidding process m Bid document (RFP) optional, is a local decision m All vendors are treated the same; have access to same information m Vendors cannot be involved in your 470 m Applicant’s consultant cannot be associated with vendor r Must choose most cost-effective bidcost-effective bid m Cost must be primary factor m Non-eligible products/services not part of cost effectiveness m Fully document your bid review process and any decision(s)  Record dates of any decisions, actions taken, etc.

20. Online Forms Training Site (http://sldtraining.usac.org) 470 options See Oct 3, ‘08 News Brief for training site information. News Brief

21. 21 Checking all to keep all options open.

22. NOTE: For “Quantity and/or Capacity” be certain to enter maximum bandwidth needed. Example for schools on BCN: “20Mbps to 100Mbps service for 3,000 teachers and students”

23. 23 Check these boxes

24. 24 Block 4 information

25. 25 Check all certifi- cations, enter authorized person (bottom)

26. 26 Use Print Preview to check all data, then Submit and certify online or via paper

27. 27 Form 471

28. 28 E-rate Form 471  Provides specific information on services, service providers selected, and contracts and/or agreements, costs, etc.  Provides discount calculation information  Must be filed each funding year m Applicant certifies compliance with all program rules m Must be postmarked or filed online by ??? m Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window 2010 Form 471 drop dead date: Likely Early-Mid Feb, 2010, 10:59PM CST

29. 29

30. 30 Block 1: Basic contact information

31. 31 Record Your security code!!

32. 32 Block 4: Calculate Discount. Adding entities (schools)

33. 33 Block 4: Calculate Discount. Adding entities (schools) one at a time

34. 34 Block 4: Calculate Discount. Adding entities (schools) NCES Codes: http://nces.ed.gov/ccd/schooLSearchhttp://nces.ed.gov/ccd/schooLSearch

35. 35 Block 5: One for each funding request. Adding entities (schools) Spin search tool http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp But VERIFY with service provider!

36. 36 Block 5: Type of service. 470 Number Contract or Month-to- month

37. 37 Block 5: Service start and end dates OR Contract award and expiration date

38. 38 Block 5: Item 21 Attachment

39. 39 http://www.sl.universalservice.org/reference/Form471item21Attachments.asp  ”You MUST attach a description of the service, including a breakdown of components, costs, manufacturer name, make and model number….”  Examples are provided in the document “Item 21 Attachments for Form 471” Block 5 — Item 21 Attachment

40. 40 Block 5: Enter Amounts. Add another block 5?

41. 41 Block 6: Certifications Have necessary resources

42. 42 Block 6: Certifications: Have Technology Plan

43. 43 Block 6: Certifications: Send Signed Certifications or PIN

44. 44 Block 6:

45. 45 Tips on Filing Form 471  File separate Forms 471 for Priority 1 and Priority 2 services  Remove ineligible costs and document or estimate eligible costs carefully (30% Rule) – (Now Bishop Perry makes less important)  Filing online speeds processing and reduces errors  Examine, correct, and save Receipt Acknowledgement Letter (RAL)  Paper forms and instructions: http://usac.org/sl/tools/required-forms.aspx http://usac.org/sl/tools/required-forms.aspx

46. 46 Receipt Acknowledgement Letter (RAL) r Form 471 Receipt Acknowledgment Letter (RAL) m Cover page of important reminders m Provides confirmation of certain information entered from Form 471  Data entry errors may be corrected within three weeks by using the RAL (including Block 4 worksheets)  Applicants can request funding reductions but not funding increases

47. 47 Funding Commitment Decision Letter (FCDL)  FCDL reports status of individual funding requests: m Funded m Not funded m As yet unfunded (internal connections) m Canceled  May receive more than one FCDL  Use info on FCDL to prepare Form 486

48. 48 E-rate Form 486  Notification that services have started and that SLD can pay invoices  Certifies that Tech Plan (if required) has been approved and covers the entire funding year.  Form 486 deadline is 120 days after service starts –OR–  120 days after date of Funding Commitment Decision Letter date, whichever is later  October 29 deadline for FCDL before July 1

49. 49 E-rate Form 472/474 (Invoices)  Invoices — Form 472 or Form 474 m BEAR (Billed Entity Applicant Reimbursement) Form 472 filed by applicant and certified by service provider after receipt and payment for services  Form due October 28, 120 days after last service date, June 30  Or 120 days after date of Form 486 Notification Letter -OR- m SPI (Service Provider Invoice) Form 474 filed by service provider after providing services and billing applicant for its non-discount share

50. 50 Issues of Waste, Fraud, Abuse r W/F/A still problem in program, mostly caused by m 90% discount, P2, complex program rules m Vendors have been debarred, people are in prisonpeople are in prison r W/F/A drives many FCC decisions m More certifications m More PIA requests for information m More audits leading to more COMADs  FCC can recoup funds going back 5 years m See SLD Fall 2009 slides on auditsslides on audits March 2009 - A former school administrator in Michigan was sentenced to four years in prison after pleading guilty to defrauding the federal E- rate program.

51. 51 Contract Issues r FCC/SLD E-rate contract rules trump local policiesE-rate contract rules r Telecom and Internet may/may not be contracted services r As noted, on the 470, always check #7, options a and b r Don’t sign contract before RFP due date or before 28 daysRFP due date or before 28 days r But, you must sign/date contract before filing Form 471 m Verbal agreements are not acceptable m Quotes are not acceptable r Have contract timed to E-rate cycle

52. 52 State Master Contracts r DOA cell contract DOA cell contract m School files 471 for cell service using your own or DOA 470 m School must file 470 if using handheld device for Internet m Contract expires 6-30-10, DOA will likely extend r DOA STS, Centrex, VoIP contract DOA STS, Centrex, VoIP contract m DOA did not file 470; you must file both Form 470 and 471  471, #18, Contract Award Date (CAD) is date you selected SMC as winning bid r Can use TEACH circuits for VoIP Mark Rappe, DOA VoIP contract 608-264-9406; mark.rappe@wisconsin.gov) Gary McFall, DOA cell contract 608-266-1032 gary.mcfall@wisconsin.gov,) gary.mcfall@wisconsin.gov Mike Kessenich, DOA STS, Centrex contract 608-264-9383; michael.kessenich@wisconsin.gov

53. 53 Program Integrity Assurance (PIA) Application Review  PIA reviews all applications PIA reviews all applications m To ensure that funds are used for eligible services/products m To ensure that funds are for eligible purposes m To ensure that funds are for eligible entities m To annoy you by asking for same documents multiple times  Common PIA requests to applicants m Need more information on requested services m Competitive bidding process and contracts m Establishing Form 470 53 “Please provide the Form 470 that established the bidding for the contract extension.”

54. 54 Program Integrity Assurance (PIA) Application Review  Respond within 15 days to PIA requests  Work with service provider if needed  Respond completely to PIA questions, but no more  If needed, ask for more time or for clarification; contact DPI  17% of all WI denials: No response or insufficient info  10% of FRNs move to “Selective Review ” r Check 471 status at 471 Application Status Tool471 Application Status Tool Applicant has not provided sufficient documentation to determine the eligibility of this item No documentation was provided for item(s): item 21 attachment.

55. 55 Appeals  Funding denials can be appealed m Generally, appeal first to the SLD m Then appeal to FCC if SLD denies appeal  Must be postmarked within 60 days of denial on FCDL r FCC has been granting many appeals m But can be a year or more r Contact DPI for appeal advice and template m No appeal form  See Appeals Procedure on SLD WebsiteAppeals Procedure

56. 56 When You Need Help r SLD website: www.usac.org/sl/www.usac.org/sl/ m Fall 2009 SLD training slides Fall 2009 SLD training slides m Reference area Reference area m News Briefs News Briefs r E-rate Central, WI site E-rate Central, WI site m Enter your BEN and get info on your application r SLD Client Service Bureau: 888-203-8100 r Email: question@slcfund.org r Fax: 888-276-8736

57. 57 DPI Help r DPI’s E-rate website: m dpi.wi.gov/pld/erate.html dpi.wi.gov/pld/erate.html r DPI’s WIERATE email list: m dpi.wi.gov/pld/wieratelist.html dpi.wi.gov/pld/wieratelist.html r DPI Staff: Bob Bocher 608-266-2127; fax 608-266-2529 robert.bocher@dpi.wi.gov robert.bocher@dpi.wi.gov Steve Sanders 608-266-3856; fax 608-266-2529 stephen.sanders@dpi.wi.gov stephen.sanders@dpi.wi.gov

58. E-rate for 2010 ? Questions ? Steve Sanders 608-266-3856 stephen.sanders@dpi.wi.gov Bob Bocher 608-266-2127 robert.bocher@dpi.wi.gov November 2009