1. JACK O’CONNELL State Superintendent of Public Instruction 1 E-Rate for California E-Rate for California Beginner Applicants

2. JACK O’CONNELL State Superintendent of Public Instruction 2 E-Rate Acronyms BEN – Billed Entity Number CIPA – Children's Internet Protection Act FCDL – Funding Commitment Decision Letter FRN – Funding Request Number SPIN – Service Provider Identification Number SSD – Service Start Date RAL – Receipt Acknowledgement Letter (Form 471) RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch Program NIF – Non-Instructional Facility PIA – Program Integrity Assurance USAC Link: http://www.usac.org/sl/tools/reference- area.aspx http://www.usac.org/sl/tools/reference- area.aspx BEN – Billed Entity Number CIPA – Children's Internet Protection Act FCDL – Funding Commitment Decision Letter FRN – Funding Request Number SPIN – Service Provider Identification Number SSD – Service Start Date RAL – Receipt Acknowledgement Letter (Form 471) RNL – Receipt Notification Letter (Form 470) NSLP – National School Lunch Program NIF – Non-Instructional Facility PIA – Program Integrity Assurance USAC Link: http://www.usac.org/sl/tools/reference- area.aspx http://www.usac.org/sl/tools/reference- area.aspx

4. JACK O’CONNELL State Superintendent of Public Instruction 4 Who Administers the E-rate Program? The federal E-rate program is overseen by the Federal Communications Commission (FCC) and is administered by the Schools and Libraries Division (SLD) of the Universal Service Administrative Company (USAC) –FCC makes the rules and regulations for the E-rate program

5. JACK O’CONNELL State Superintendent of Public Instruction 5 How is USAC related to the FCC? Comprehensive information about the E-Rate program is available at the SLD website: http://www.usac.org/sl/ USAC is a not-for-profit corporation appointed by the FCC to act as the administrator of the E-Rate program

6. JACK O’CONNELL State Superintendent of Public Instruction 6 California Department of Education (CDE) & State Library Do Not Administer the Federal E-Rate program.  CDE & State Library have no statutory authority to administer the federal E-Rate program  CDE & State Library only provide general information about the E- Rate program including: training and outreach, reference materials, and other publicly available SLD/USAC resources

7. JACK O’CONNELL State Superintendent of Public Instruction 7 Eligibility - Schools Schools must provide elementary or secondary education as determined under state law. Schools may be public or private institutional day or residential schools, or public charter schools. Schools must operate as non-profit businesses. Schools cannot have an endowment exceeding $50 million.

8. JACK O’CONNELL State Superintendent of Public Instruction 8 Pre-K and Adult Ed State law, in conjunction with E-Rate rules, determines eligibility of Pre-K (Head Start), Adult Ed and Juvenile Justice Reference the following for California eligibility: http://www.usac.org/sl/applicants/ste p01/non-traditional-k-12/k-12- eligibility-table.aspx http://www.usac.org/sl/applicants/ste p01/non-traditional-k-12/k-12- eligibility-table.aspx

9. JACK O’CONNELL State Superintendent of Public Instruction 9 Eligibility – Libraries Libraries must be eligible for assistance from the California state library administrative agency under the LSTA (Library Services & Technology Act) Libraries must have budgets completely separate from any schools (including, but not limited to, elementary and secondary schools, colleges and universities). Libraries cannot operate as for-profit businesses.

10. JACK O’CONNELL State Superintendent of Public Instruction 10 E-Rate Identification Numbers Billed Entity Number - BEN –http://www.sl.universalservice.org/Util ities/BilledEntitySearch_Public.asphttp://www.sl.universalservice.org/Util ities/BilledEntitySearch_Public.asp Service Provider Identification Number - SPIN –http://www.sl.universalservice.org/For ms/SPIN_Contact_Search.asphttp://www.sl.universalservice.org/For ms/SPIN_Contact_Search.asp

11. JACK O’CONNELL State Superintendent of Public Instruction 11 E-Rate Process 1.E-rate Technology Planning – What are my goals? 2.Form 470 – Start Application Process 3.Competitive Bidding & Selecting your vendors 4.Form 471 – Request for Funding 5.PIA (Program Integrity Assurance) Review 6.Funding Commitment 7.Form 486 Receipt of Services Confirmation 8.Form 472 – BEAR and Form 474 – SPI – Invoicing “Getting the Money” 9.Other Forms as needed

12. JACK O’CONNELL State Superintendent of Public Instruction 12 E-Rate Cycle Funding Year is July 1 – June 30 Funding commitments are made by funding year (services starting on or after July 1 and ending on or before the following June 30) The Window –Form 471 application window –Opens mid to late fall and closes late January to early February –This year Funding Cycle July 1, 2010 to June 30, 2011 (Funding Year 13)

13. JACK O’CONNELL State Superintendent of Public Instruction 13 1. E-Rate Technology Planning

14. JACK O’CONNELL State Superintendent of Public Instruction 14 Purpose of the Tech Plan Tech plans ensure that schools and libraries are prepared to effectively use the requested services to integrate telecommunications and internet access into the educational program or library services that they provide to students. Tech plans should support and validate services, i.e., priority one services, Telecommunications (cell, data, voice, long distance, etc.) and Internet Access, and priority two services, both Internal Connections (IC) and Basic Maintenance of Internal Connections (BMIC).

15. JACK O’CONNELL State Superintendent of Public Instruction 15 Technology Plan Overview 1.FFC rules require an “approved” technology plan when receiving E-rate discounts for more than basic telephone service (there are 2 types of tech plans that can be used: an EETT or E-rate only). 2.Find your public charter, district or COE Tech Plan status at: http://www.cde.ca.gov/ls/et/rs/techplan.asp http://www.cde.ca.gov/ls/et/rs/techplan.asp 3.*Decision: Decide which tech plan to use: A) E-rate only, B) EETT technology plan (best practice approach) Note: Libraries leverage your master plan in developing your technology plan. 4.Tech Plan must be “written” prior to posting Form 470. 5.DOCUMENT the existence of this “Written Plan” – i.e., Letter/E-mail from Cabinet, screen print of file name and date, and physical copy of plan. 6.Must cover all 12 months of the funding year (July 1 – June 30). 7.E-rate only plans should not cover more than 3 years; EETT tech plans that meet E- rate requirements can cover 5 years with progress review during 3 rd year. 8.Tech plans must include all services (both current and future) for which E-Rate discounts are sought. 9.Must be approved by a “Certified Technology Plan Approver” See the Technology Plan approver locator tool on the USAC website: http://www.sl.universalservice.org/reference/tech/default.asp http://www.sl.universalservice.org/reference/tech/default.asp 10.Leverage the technology expertise of your CTAP regional assistance: CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp. http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

16. JACK O’CONNELL State Superintendent of Public Instruction 16 5 Required Elements of a Technology Plan Used for E-rate 1.Clear statement of goals and realistic strategy for using telecommunications and information technology to improve education or library services. 2.Professional Development strategy to ensure staff understands how to use technologies to improve education or library services 3.Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services 4.Budget sufficient to acquire and support the non-discounted elements of the tech plan including: hardware, software, professional development and other services to implement the stated goals/strategy 5.Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise.

17. 17 The “Two Tech Plans” E-Rate Only Plan: 1.Goals 2.Professional Development 3.Needs Assessment 4.Budget 5.Evaluation Process Tech Plan Help www.usac.org/sl/ applicants/step02/ Enhancing Education Through Technology (EETT): Executive Summary/Introduction Stakeholders Curriculum Professional Development Infrastructure Adult literacy Research Funding and Budget Monitoring and Evaluation E-Rate supplemental budget analysis … and also see: www.cde.ca.gov/ls/et/rs/techplan.asp

18. JACK O’CONNELL State Superintendent of Public Instruction 18 EETT Tech Plan Cycle Dates: The final dates to submit your EETT Tech Plan for approval are: 1.Cycle A: October 9, 2009 2.Cycle B: December 4, 2009 3.Cycle C: April 9, 2010

19. JACK O’CONNELL State Superintendent of Public Instruction 19 Technology Plan “Must Do” Reminders: 1.Must be “Written” prior to posting Form 470: –It must be documented that it is written before the posting of the form 470! (Applicant must document the existence of this plan, i.e., e-mail with plan attached, memo from cabinet level about the plan being written, including the date. “DATE STAMP,” submit EETT tech plans during cycle A [final date October 9, 2009]) 2.Must include a sufficient level of detail and cover all services for which E-Rate discounts are being sought on the Form 470(s) and subsequent Form 471(s). 3.Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier 4.E-rate only plans must be approved by a “USAC Certified Technology Plan Approver” see USAC link: http://www.usac.org/sl/tools/reference/tech/default.asp http://www.usac.org/sl/tools/reference/tech/default.asp 5.Combination E-rate/EETT Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asphttp://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp 6.Must include all five required elements (as noted on Slide 15) regardless of the type of plan being used (E-rate only or EETT)

20. JACK O’CONNELL State Superintendent of Public Instruction 20 Technology Plan “Reminders” Service Providers may not act as technology plan approvers, write/create, or assist in the tech plan in any capacity Remember to include in your tech plan all the services that you apply for on Form 470/471 [telecommunications (cell, data, voice, long distance), internet, internal connections, and basic maintenance]

21. JACK O’CONNELL State Superintendent of Public Instruction 21 Technology Plan Help E-rate Plans: John Vardanega, jvardane@cde.ca.gov, 916-323-2241 jvardane@cde.ca.gov EETT Plans: Bill Fong, bfong@cde.ca.gov, 916-322-5894bfong@cde.ca.gov CTAP:http://www.cde.ca.gov/ls/et/rs/ctapcoord inators.asphttp://www.cde.ca.gov/ls/et/rs/ctapcoord inators.asp Libraries: Rushton Brandis, rushbrandis@library.ca.gov, 916-653-5471 rushbrandis@library.ca.gov http://www.library.ca.gov/services/libraries/erat e.htmlhttp://www.library.ca.gov/services/libraries/erat e.html http://www.usac.org/sl/applicants/step02/ http://www.cde.ca.gov/ls/et/rs/techplan.asp

22. JACK O’CONNELL State Superintendent of Public Instruction 22 E-Rate Discount Calculations Calculated based on two factors: 1. Percentage of students eligible for free and reduced lunch under the National School Lunch Program (NSLP): http://www.usac.org/sl/applicants/step05/discount-matrix.aspx http://www.usac.org/sl/applicants/step05/discount-matrix.aspx or an alternate method: http://www.universalservice.org/sl/applicants/step05/alternative- discount-mechanisms.aspx 2. Urban or Rural status (Matrix) http://www.usac.org/sl/applicants/step05/discount-matrix.aspx. http://www.usac.org/sl/applicants/step05/discount-matrix.aspx - To verify your Urban or Rural Status status:http://www.usac.org/sl/applicants/step05/urban-rural/ - Census Tract Look-up Tool http://www.ffiec.gov/Geocode/default.aspx

23. JACK O’CONNELL State Superintendent of Public Instruction 23 Discount Calculations Instructional Facilities have a discount that comes from the NSLP free and reduced lunch data and the Urban/Rural Matrix Non-Instructional Facilities and libraries will use a weighted average

24. JACK O’CONNELL State Superintendent of Public Instruction 24 Urban/Rural Discount Matrix % Eligible Students for NSLP UrbanRural 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% E-Rate Discount Matrix

25. JACK O’CONNELL State Superintendent of Public Instruction 25 Free and Reduced Lunch Eligibility under (NSLP) NSLP data is reported to CDE in October of each year. (This Con App (as shown on page 46) data is finalized/posted by CDE in the following Spring) http://www.cde.ca.gov/ds/sh/cw/filesafdc.asp http://www.cde.ca.gov/ds/sh/cw/filesafdc.asp This posted NSLP data comes from the Claim Reimbursement Form from Food Services Manager for month of October Program Integrity Assurance (PIA) looks at the NSLP data that is provided by CDE - so to avoid PIA discount issues use your latest Con App data on Form 471 Keep all establishing NSLP data used on Form 471 in your records for future USAC Inquiries

26. JACK O’CONNELL State Superintendent of Public Instruction Con App Example (Consolidated Application) 25

27. JACK O’CONNELL State Superintendent of Public Instruction 27 OR

28. 28

29. SNP Sponsor Claim For Reimbursement 28

30. JACK O’CONNELL State Superintendent of Public Instruction 30 Claim for Reimbursement Reconciliation Details

31. 31 District Students Enrolled # Free and Reduced Lunches % Free and Reduced Lunches % E-Rate Subsidy Weighted Average for District Sample School District Sample School 1191473.68%80%15.2 Sample School 283632338.64%60%501.6 Sample School 31885428.72%50%94 Sample School 41216553.72%80%96.8 Sample School 51583622.78%50%79 Sample School 6105020419.43%40%420 TOTALS FOR DISTRICT2372696 1206.6 WEIGHTED AVERAGE 50.87% Calculating a Weighted Average

32. JACK O’CONNELL State Superintendent of Public Instruction 32 Non-Instructional Facilities (NIFs) Examples SCHOOLS:LIBRARIES: Administrative buildings School bus barns and garages Cafeteria offices Facilities associated with athletic activities Bookmobile garages Interlibrary loan facilities Library technology centers Cafeteria offices

33. JACK O’CONNELL State Superintendent of Public Instruction 33 Eligible Services – Basic Concepts Key reference: Eligible Services List – http://www.usac.org/sl/tools/eligible-services-list.aspx http://www.usac.org/sl/tools/eligible-services-list.aspx This List is updated Annually Priority 1 (P1) –Telecommunications –Internet Access Priority 2 (P2) –Internal Connections –Basic Maintenance on Eligible Internal Connections Note: End-user devices and content generally not eligible –PCs/PDAs-Printers-Television –Laptops-Phones-VCRs Services must be used for “Educational Purpose” - http://www.sl.universalservice.org/reference/educational_purposes. asp http://www.sl.universalservice.org/reference/educational_purposes. asp

34. JACK O’CONNELL State Superintendent of Public Instruction 34 Educational Purpose Activities that occur on library or school property are presumed to be integral, immediate and proximate to the education of students or the provision of library services to library patrons and therefore qualify as educational purposes. Customary work activities of employees of a school or library are presumed to fall under the definition of educational purposes.

35. JACK O’CONNELL State Superintendent of Public Instruction 35 2. Form 470: Starting the Application Process

36. JACK O’CONNELL State Superintendent of Public Instruction 36 Prepare For The E-Rate Cycle Technology Plan MUST be Written Existing network structure, both telecommunications and data Expected growth in telecommunication and hardware needs Preparing for the Bidding/Procurement Process Number of classrooms and computers with phone/internet access NSLP data for discount percentage Ensure (CIPA) Compliance, implementation and board approval.

37. JACK O’CONNELL State Superintendent of Public Instruction 37 Manage the Cycle - Teamwork Authorized signer (Legally Authorized Signer) Designated contact person (Will receive E-rate calls, e-mail, faxes) Organize paper trail –Written Technology Plan –Assessment of existing Contracts, with signatures and dates (expiring contracts, etc) –Prior year’s submitted applications –Correspondence from SLD, Service Providers, etc. –All bids received and evaluation documents –Calendar of Deadlines

38. JACK O’CONNELL State Superintendent of Public Instruction 38 Form 470 – Contract Issues Block 2, Item 7 Know what type of contract/service you are seeking bids for

39. JACK O’CONNELL State Superintendent of Public Instruction 39 Form 470 Block 2, Items 8 – 9 Block 2, Item 1 MUST be filled out regardless of an available RFP

40. JACK O’CONNELL State Superintendent of Public Instruction 40 Form 470 Block 3 Technology Resources –Not eligible for discount but required in order to receive E-Rate funding

41. JACK O’CONNELL State Superintendent of Public Instruction 41 Form 470 Block 4 Recipients of services –Number listed should be sufficient to include all possible entities. –Including Non-Instructional Facilities Do you anticipate growth?

42. JACK O’CONNELL State Superintendent of Public Instruction 42 Form 470 Block 5 Certification and Signatures

43. JACK O’CONNELL State Superintendent of Public Instruction 43 Submit and Certify Form 470 Once the Form 470 is submitted you must 1.Certify online using a PIN, or 2.Print the certification page, sign and mail this form ASAP-- “certified mail” Print the Form 470 for your records, and note the Allowable Contract Date (ACD) –Also provided in the Receipt Acknowledgement Letter (RAL)

44. JACK O’CONNELL State Superintendent of Public Instruction 44 Form 470 Reminders Allow adequate time for the following to be completed: –Do your Form 470 NOW – Do not wait –Competitive Bidding – minimum of 28 days before selecting service provider and contract signing –Local Procurement –Board Approval –Signing Contracts Understand –Your existing services and contracts –Products and services you will need in the coming year –Eligible entities receiving services Identify E-rate category for each product and service, P1 or P2

45. JACK O’CONNELL State Superintendent of Public Instruction 45 Form 470 Reminders From SLD’s Tip Sheets DO list your requested services on your Form 470 — and your RFP if you have one. DO list your requested services in the correct categories of service (Telecommunications, Internet Access, Internal Connections, or Basic Maintenance of Internal Connections). DO mark the correct boxes in Block 2 for multi- year contracts and/or voluntary extensions. DO certify your Form 470 prior to the close of the Form 471 application window. DON’T allow a service provider that may bid on your services to fill out your Form 470. DON’T wait until the Form 471 window opens to file your Form 470.

46. JACK O’CONNELL State Superintendent of Public Instruction 46 Receipt Notification Letter (RNL) An opportunity to review application and correct minor errors ( contact name, number of eligible entities, billed entity number ) –Review immediately to determine if you need to file a new Form 470

47. JACK O’CONNELL State Superintendent of Public Instruction 47 3. Competitive Bidding/Procurement

48. JACK O’CONNELL State Superintendent of Public Instruction 48 Cornerstone of E-Rate All expiring and new contracts must be competitively bid/procured to receive E-rate funding Posting of the Form 470/RFP (which- ever is later) starts the procurement process with a minimum of 28 days to receive proposals Must respond to ALL vendors –If you choose not to, you MUST have a good reason, i.e., Spam

49. JACK O’CONNELL State Superintendent of Public Instruction 49 Competitive Procurement and Program Compliance http://www.sl.universalservice.org/reference/Best Practices.asphttp://www.sl.universalservice.org/reference/Best Practices.asp –Keep copies of all bids/proposals, winning and losing –Keep documentation on the award process and bid/proposal evaluation criteria for your award Keep all correspondence related to the procurement process Evaluation Criteria needs to be established BEFORE you release the RFP/Form 470 –Complete copies of all related contracts FOLLOW LOCAL/STATE PROCUREMENT POLICIES - This is a critical element in audits

50. JACK O’CONNELL State Superintendent of Public Instruction 50 Program Compliance Best Practice: Use standard evaluation process for all bids/proposals. Keep evaluation documentation for each bid. If you get NO bids/proposals – document this for audit purposes –Same is true if you get only ONE bid/proposal

51. JACK O’CONNELL State Superintendent of Public Instruction 51 Evaluation Criteria Price must be the most heavily weighted factor, but it may not be the only factor –Check your local procurement guidelines, sometimes the lowest price must be the only factor Can choose most responsive and responsible bid/proposal using factors other than price alone, but must DOCUMENT the choice and process Have District official SIGN and DATE the completed evaluation rubric as acknowledgement at the time of the decision by the district

52. 52 Vendor AVendor B RawWeightedRawWeighted Selection Criteria Weight* (%) Score**Score*** Score Prices/Charges40%10.420.8 Understanding of Needs15%20.310.15 Prior E-Rate Experience10%20.210.1 Prior District/Service Prov experience 10%20.210.1 Completeness of Response15%20.310.15 References10%20.210.1 Overall Ranking100%1.61.4 SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE

53. JACK O’CONNELL State Superintendent of Public Instruction 53 Form 470 – Multi-Year Contracts You may not need to file a new Form 470 if the originating Form 470 meets the criteria below: –The language on the originating Form 470/RFP covered all services on the contract AND –The applicant indicated on the originating Form 470 that a contract was being sought AND –The applicant indicated on the originating Form 470/RFP that a multi-year contract was being sought (perhaps w/voluntary extensions) Note: Determine if you entered on previous year Form 471 that applicable FRN was on contract

54. JACK O’CONNELL State Superintendent of Public Instruction 54 Competitive Procurement Reminders DO ensure a fair and open competitive procurement process. All service providers must be treated equally and cannot be given biased or privileged knowledge of the procurement process. DO select the most cost-effective service provider, with price as the primary factor. DO keep ALL records relating to the bid/proposal evaluation process (correspondence with potential vendors, winning and losing bids, worksheets, evaluation criteria, contract, etc.). Note in a memo if one (or no) bids are received. DO remember that contracts must be signed and dated by the applicant and service provider before filing the Form 471. Remember to sign a contract after waiting at least 28 days after the posting of the Form 470/RFP

55. JACK O’CONNELL State Superintendent of Public Instruction 55 CONTRACT REMINDERS Contract Reviews: Do not wait until the last minute –Allow time for board approval processes and signatures –Know what constitutes a fully executed contract, i.e., Board Approval, etc. Some contracts may require 2 or more signatures/dates to be fully executed

56. JACK O’CONNELL State Superintendent of Public Instruction 56 4. Form 471 : Application for Funding

57. JACK O’CONNELL State Superintendent of Public Instruction 57 Form 471 – Your Application for Funding Detailed information on services, service providers selected, and contracts Discount calculation information Must be filed every funding year –(even on multi-year contracts) Contains certifications of compliance Includes one or more funding requests

58. JACK O’CONNELL State Superintendent of Public Instruction 58 Organize Your Paperwork BEFORE Starting Form 471 Block 2: Impact of services description (bandwidth information and population served) Block 4: Entity numbers for all locations receiving service Block 4: NSLP and enrollment data, Urban or Rural designation Block 5: SPINs for selected service providers Block 5: Copies of SIGNED contracts (with award date and end date) and estimated costs (recurring and non recurring) Block 6: Budget Information

59. JACK O’CONNELL State Superintendent of Public Instruction 59 Recurring vs. Non-recurring Costs Separate Recurring from Non-recurring costs in Block 5 of the Form 471 (Note: A funding year starts on July 1 and ends on June 30) –Recurring services must ALWAYS be received by June 30 –Non-recurring services have an extended deadline to be completed by September 30 following the close of the funding year. Check Contract dates to align with deadline Deadline can be extended for certain circumstances

60. JACK O’CONNELL State Superintendent of Public Instruction 60 Form 471 Deadline Best Practice (Do it EARLY!): –File Online (Application Window changes every application year) –Do not combine Priority 1 and Priority 2 services on the same Form 471 –Submit BEFORE close of window –Certify BEFORE close of window Online if using PIN By trackable mail if you do not use your PIN ** Bishop Perry Order – 15 day grace period for certifications made after the deadline http://www.usac.org/_res/documents/sl/pdf/List-of- Correctable-Ministerial-and-Clerical-Errors.pdf http://www.usac.org/_res/documents/sl/pdf/List-of- Correctable-Ministerial-and-Clerical-Errors.pdf

61. JACK O’CONNELL State Superintendent of Public Instruction 61 Item 21 Attachments Used to prove your request –Substantiating documentation that proves the pre-discount cost of services or products –Should be clear and concise Samples available on USAC website –http://www.sl.universalservice.org/reference/For m471item21Attachments.asphttp://www.sl.universalservice.org/reference/For m471item21Attachments.asp

62. JACK O’CONNELL State Superintendent of Public Instruction 62 Item 21 Attachment Identify and remove ineligible costs Work with service provider(s) to create your Item 21 attachment(s) Include your Item 21 with your application Ensure that your Item 21 and Form 471 totals match

63. JACK O’CONNELL State Superintendent of Public Instruction 63 Missed Deadline? Form 471 is not submitted before the close of “the window” or is not certified within the grace period: –The application will not be considered for funding

64. 64 RAL Process Applicants should carefully review the Form 471 RAL and must notify USAC of any data entry errors within 15 DAYS of the postmark date of the RAL. http://www.usac.org/_res/docu ments/sl/pdf/sampleletters/471 RAL.pdf

65. JACK O’CONNELL State Superintendent of Public Instruction 65 Receipt Acknowledgement Letter “RAL” This is a GOLDEN Opportunity to correct your Form 471 and your ONLY opportunity. –You can increase the funding request during RAL (but no other time), change discount amount, change contract date, etc. If you need a correction, do this during the 15-DAY RAL period. (You may be able to make some corrections during PIA, but DO NOT RELY on PIA process)

66. JACK O’CONNELL State Superintendent of Public Instruction 66 Form 471 Reminders DO ensure that you have adequate time in your process to award contracts and have them approved by the Board and signed prior to filing the Form 471. DON’T wait until the last minute. Start Process Now! DO be organized and have all documentation ready such as NSLP, contracts, SPINs, and budget prior to starting the Form 471. DO file separate Form 471 applications for Priority 1 services and Priority 2 services. DO split out requests of questionable eligibility into separate Funding Request Numbers (FRNs). DO file electronically and DO certify online before the close of the window. DO review the RAL carefully and make allowable corrections within the 15-DAY timeline. Remember to list all locations that are going to receive services including NIFs

67. JACK O’CONNELL State Superintendent of Public Instruction 67 5. PIA (Program Integrity Assurance) Review

68. JACK O’CONNELL State Superintendent of Public Instruction 68 Program Integrity Assurance (PIA) Applications are reviewed for compliance with program rules concerning areas such as: –Properly executed contracts –Discount calculation –Establishing Form 470 –Eligibility of services being requested –Eligibility of entities requesting discounted services –Proper completion of all of blocks/Item 21

69. JACK O’CONNELL State Superintendent of Public Instruction 69 Item 21 and PIA Read PIA carefully; do not ignore it or your application will be denied 15 days to respond. Don’t wait till the last day! Take action! Involve Service Providers when possible TAKE ACTION!

70. JACK O’CONNELL State Superintendent of Public Instruction 70 Be Responsive Respond promptly, answer questions in their entirety (you are given 15 days initially) Document communication with PIA, –e-mail is preferred (acknowledgement of receipt) Ask for more time if you need it –May delay your application Don’t assume that Reviewer has your original Item 21 attachment The PIA person can help clarify their questions Establish a working relationship Contact your service provider immediately when you need response information from them Contact the CDE for site validations, etc.

71. JACK O’CONNELL State Superintendent of Public Instruction 71 6. Funding Commitment

72. JACK O’CONNELL State Superintendent of Public Instruction 72 What Happens After PIA Review? A Decision – Funding Commitment Decision Letter (FCDL) –Funded –Not Funded –As Yet Unfunded (Priority 2 requests) –Cancelled IMPORTANT – Check all entries in the FCDL carefully to make sure there are no data entry errors.

73. 73 Funding Commitment Decision Letter FCDL Should be your “trigger” to file subsequent forms both for USAC and Service Providers Starts deadline clock for appeal on denial(s) – 60 Days http://www.usac.org/sl/applica nts/step09/

74. JACK O’CONNELL State Superintendent of Public Instruction 74 7. Form 486 Receipt of Services Confirmation

75. JACK O’CONNELL State Superintendent of Public Instruction 75 Purpose of 486 Notifies USAC that services have started or are scheduled to start and invoices can be paid Certifies that Tech Plan is approved and meets program requirements Do NOT miss the 486 deadline for your district –http://www.universalservice.org/sl/applicants/st ep10/form486-filing-information.aspxhttp://www.universalservice.org/sl/applicants/st ep10/form486-filing-information.aspx

76. JACK O’CONNELL State Superintendent of Public Instruction 76 CIPA Certification Items Certifies the status of Children’s Internet Protection Act (CIPA) compliance by: –Technology Protection Measure Test and Document that Filtering is working on an annual basis –Internet Safety Policy –Public Notice & Hearing Board Approval in minutes

77. JACK O’CONNELL State Superintendent of Public Instruction 77 What is the 486 deadline? Filed AFTER receipt of FCDL –Form 486 must be filed online or postmarked no later than 120 days after the Service Start Date OR 120 days after the date of the FCDL –Whichever is later –Grace period from USAC – letter giving additional 20 days to file 486 – (Alaska Gateway order) Take this letter seriously

78. JACK O’CONNELL State Superintendent of Public Instruction 78 Missed deadline? If the Form 486 is late, your Service Start Date will be adjusted to 120 days prior to the online submission or 120 days prior to the postmark. WILL affect telecommunications and internet access –Funding will more than likely be reduced MAY affect internal connections –Depends on installation date compared to service start date

79. JACK O’CONNELL State Superintendent of Public Instruction 79 Form 486 Notification Letter (486NL) Letter received after filing of Form 486 –Verify that ALL FRNs are on letter –Verify service start dates for each FRN USAC is now ready to begin receiving invoices for payment on these FRNs –Form 472 – filed by Applicant OR –Form 474 – filed by Service Provider

80. JACK O’CONNELL State Superintendent of Public Instruction 80 Form 486 Reminders DO file within 120 days of the service start date (July 1 for recurring services) or FCDL date, WHICHEVER IS LATER. DON’T wait until the last minute. DO include all applicable Funding Request Numbers (FRNs). Verify FRNs and SPINs against the Form 471 and FCDL. DO understand early filing rules if filing BEFORE July 1. DO review the Form 486 Notification Letter to verify all FRNs were included. DON’T ignore a Form 486 Reminder Letter. DO maintain open communication with your service provider regarding non-recurring services. They can not invoice USAC until the Form 486 is filed.

81. JACK O’CONNELL State Superintendent of Public Instruction 81 8. Invoicing - “Getting the Money” Form 472 – BEAR (Billed Entity Applicant Reimbursement) Form 474 – SPI (Service Provider Invoice)

82. JACK O’CONNELL State Superintendent of Public Instruction 82 Receipt of Funds One of two ways: 1. Applicant pays entire bill up-front and gets reimbursed Form 472, “ BEAR” – filed by Applicant (Note: Form 472 amount must represent actual eligible costs) 2. Service Provider applies discounts to bills and submits to USAC for reimbursement Form 474, or SPI – filed by Service Provider –Note: Telecommunications Services & Internet Access that are eligible for CTF Discounts must use SPI process –You cannot file BOTH a BEAR and SPI on the same FRN.

83. JACK O’CONNELL State Superintendent of Public Instruction 83 October Important Deadlines Complete your BEAR for 08-09 prior to Oct 28 th, 2009 Pay attention to 486 deadlines, Due 120 days after FCDL (Note: this is due Oct 28 th if you received your FCDL for 09-10 on or prior to July 1 st ) Have your tech plan written PRIOR to posting your Form 470 for 10-11 if it expires June 30 th 2010 or sooner File your Form 470 for 10-11 NOW!

84. JACK O’CONNELL State Superintendent of Public Instruction 84 Use actual eligible expenses to determine “Total Reimbursement Amount” – Block 1, line 8 and Block 2. –You must be able to demonstrate that you removed any ineligible costs in a BEAR review or subsequent examination Use Block 2, Item 12 for recurring services Use Block 2, Item 13 for non-recurring services Create one BEAR for each service provider. Can put multiple FRNs on one BEAR, as long as the service provider is the same. Form 472-BEAR

85. JACK O’CONNELL State Superintendent of Public Instruction 85 Form 472-BEAR Once form is filled out, it must be signed by –Applicant –Service Provider Note: BEAR can be done online Form is then mailed to SLD –SLD reviews the form –BEAR Notification is sent to both Applicant and Service Provider Check is sent to Service Provider From the date Service Provider receives funds from USAC, they have 20 days to reimburse Applicant.

86. JACK O’CONNELL State Superintendent of Public Instruction 86 Form 474 - SPI Used by Service Providers (SP) –Allows SP to apply discounts to the bill AFTER funding commitment has been issued and all relevant forms are submitted –Allows applicant to eventually pay only their non-discounted portion –Service provider Forms such as “Grid” and “Data Gathering Form” MUST be submitted Every service provider has their own process and suggested deadline Follow up with Service Provider to ensure receipt of funds Helps your district/library’s CASH FLOW ! RETURN GRIDS/Data Gathering information to Service Providers ASAP to start discounts!

87. JACK O’CONNELL State Superintendent of Public Instruction 87 Invoicing Reminders DO ensure your Form 486 is filed in a timely manner. Invoicing cannot occur until Form 486 is filed and certified. DO, if using the SPI method, ensure that all service provider forms are completed and returned in a timely manner. DO work with your service provider to verify discounts posted on your invoices. DON’T assume the discounts posted are correct. DO file the BEAR form prior to the Invoice Deadline. DON’T include ineligible costs in your BEAR form amount. DO document your BEAR form calculations and retain for audit purposes. DO file an Invoice Deadline Extension Request if your FRN does not show any or incomplete disbursement of funding by the invoicing deadline.

88. JACK O’CONNELL State Superintendent of Public Instruction 88 Audits, Appeals, Cost Effectiveness and Other Reviews

89. JACK O’CONNELL State Superintendent of Public Instruction Compliance Attestation Examination AKA “The Big Audit” Directed by the FCC’s Office of Inspector General (OIG) Randomly selected by FCC Annually between November and July 1 st These types of Audits are under review by the FCC/USAC Audits will not start until after the Form 471 window closes 89

90. JACK O’CONNELL State Superintendent of Public Instruction Compliance Attestation Examination Examine payments made during a single fiscal year – May include examination of MULTIPLE funding years! Conducted by third party auditing firms who may be on-site 2 to 8 weeks Purpose: Did applicant comply with FCC rules? (not just looking for waste, fraud, and abuse) –Applicant must be able to prove compliance with rules using strong internal controls 90

91. JACK O’CONNELL State Superintendent of Public Instruction 91 Compliance Attestation Examination Not like any audit ever performed in your District/Library DEFINITION: a ‘firm’ expresses a conclusion [opinion] about the reliability of a statement that is the responsibility of someone else How does this happen The firm must ‘get comfortable’ that there is a low likelihood that non-compliance occurred using essentially whatever means they deem necessary Internal Controls are KEY How does your District/Library maintain compliance with the various requirements of the program? The ‘opinion’ is what the FCC/OIG requires of the examiners Ultimately, USAC decides whether to pursue a recommended action

92. JACK O’CONNELL State Superintendent of Public Instruction Examples of Rule Violations that Warrant Potential Recovery of Funds Insufficient documentation of the competitive bidding/procurement process (Applicant did not follow local & state procurement rules) Lack of necessary resources – equipment not fully utilized Service substitutions not meeting criteria established in the rules Failure to pay (or show proof of payment) of non-discounted share Failure to complete services within funding year Discount calculation violation Technology Plan not approved and/or not containing required elements and requested services More specific examples located on USAC Audit training slides located at: http://www.universalservice.org/sl/about/training- presentations/training-presentations-archive/training- 2008/fall/materials.aspx 92

93. JACK O’CONNELL State Superintendent of Public Instruction 93 How To Prepare For The Audit Follow All E-rate Rules Retain – Retain – Retain – Lessen your pain!! Document, Document, Document! Plan ahead for an audit by documenting every step of the process Create E-Rate binders for EACH funding year Contact your service providers USAC Compliance Documentation Checklist for audits http://www.usac.org/_res/documents/sl/pdf/Comp DocChecklist.pdfhttp://www.usac.org/_res/documents/sl/pdf/Comp DocChecklist.pdf

94. JACK O’CONNELL State Superintendent of Public Instruction 94 Who Should Be Available During Audits? Person(s) who –filed the E-rate forms (such as consultant) –managed the bidding and award process –reviewed and approved invoices –prepared E-rate invoices –is responsible for budget (CBO) –is responsible for NSLP documentation –is knowledgeable about the network and the location of equipment –provided service (if needed) Appoint a single contact person who can manage interactions between auditors and staff members

95. JACK O’CONNELL State Superintendent of Public Instruction 95 Document Retention Requirements Keep for 5 years after last date of service –Be aware of contract dates and extensions –All USAC correspondence, including Quarterly Disbursement Reports Make sure all departments understand documentation retention requirements for E-Rate Align Board policies with E-rate requirements

96. JACK O’CONNELL State Superintendent of Public Instruction 96 Audit “Gotchas” No documentation of a “draft” technology plan at time of Form 470 filing (FY 2005 onward) No record of reconciliation of service provider invoices Internal Control deficiencies Asset Management Accounts Payable procedures Understanding procurement rules/guidelines

97. JACK O’CONNELL State Superintendent of Public Instruction 97 CIPA Documentation Internet safety policy Local governing board adoption of the Internet safety policy The date and a copy of the minutes of the public hearing regarding the Internet safety policy [Local Board adopted policy] Internet filtering reports Copies of invoices for Internet filtering services (and filtering reports, keep these on an annual basis) Copies of Forms 479 and/or Forms 486, if applicable

98. JACK O’CONNELL State Superintendent of Public Instruction 98 Discount Documentation NSLP Method –Proof of discount calculations including source data and reports –Auditors may ask for a sampling of actual NSLP applications –USDA and FCC agreement http://www.fns.usda.gov/cnd/Governance/Policy- Memos/2008/SP_29-2008.pdf

99. JACK O’CONNELL State Superintendent of Public Instruction Other Levels of Scrutiny H.A.T.S Visits Helping Applicants To Succeed Primarily for applicants that have had funding issues in the past Welcome the help…do not be afraid Special Compliance Reviews Typically during PIA Item 25 Selective Review Cost Effectiveness Review 99

100. JACK O’CONNELL State Superintendent of Public Instruction 100 Appeals Submitted to USAC if you disagree with a decision (denial) - approved in very limited circumstances. Appeals to USAC must be submitted within 60 days of the denial When the appeal makes it clear that USAC erred in its initial review When the applicant provides USAC with information it did not provide when the original request was made When USAC obtains policy clarification or new policies that impact the original decision Submitted to FCC if you are questioning the existing program rules or if USAC denies the initial appeal Appeals must be submitted within 60 days of a USAC denial

101. JACK O’CONNELL State Superintendent of Public Instruction 101 Reminders After Posting the Form 470 –WAIT AT LEAST 29 DAYS BEFORE: Selecting a service provider Signing a contract Signing and dating the Form 471 Submitting the Form 471 MUST OCCUR IN THIS ORDER Both Applicant and Service Provider must sign and date all contracts. Work with Telecom to consolidate their bills Form 471 must be filed before filing window closes

102. JACK O’CONNELL State Superintendent of Public Instruction 102 Reminders Create YOUR OWN timeline of E-Rate deadlines –Opening and closing of the Form 471 –Form 486 deadline based on FCDL Be aware of timelines and adhere to them Share this information with others at your site (keep administration informed) Have a backup person (succession planning) Keep E-Rate files organized Print and retain copies of everything –USAC Link to Document Retention: http://www.usac.org/sl/about/audits/e-rate- binder.aspx. http://www.usac.org/sl/about/audits/e-rate- binder.aspx Additional 2009 USAC Training Audit Information: http://www.usac.org/sl/about/training- presentations/training-presentations-archive/training- 2009/fall/materials.aspx http://www.usac.org/sl/about/training- presentations/training-presentations-archive/training- 2009/fall/materials.aspx

103. JACK O’CONNELL State Superintendent of Public Instruction 103 Contact Information State Library: Rushton Brandis, (916) 653-5471, rushbrandis@library.ca.govrushbrandis@library.ca.gov CDE: John Vardanega, (916) 323-2241, jvardane@cde.ca.gov CDE: Tech Plans: Bill Fong, (916) 322- 5894, bfong@cde.ca.govbfong@cde.ca.gov K-12 HSN/Butte COE: Russ Selken, 530-532-5678rselken@bcoe.orgrselken@bcoe.org