ERate for California

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ERate for California

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For use on Block 4 of the Form 471. JACK O'CONNELL. State Superintendent. of Public Instruction ... JACK O'CONNELL. State Superintendent. of Public Instruction ... – PowerPoint PPT presentation

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Title: ERate for California


1
E-Rate for California

2
Agenda
  • General Program Information
  • Technology Plans
  • Competitive Bidding and the Form 470
  • Form 471
  • PIA (Program Integrity Assurance)
  • Form 486 Invoicing
  • Program Updates Gotchas
  • Audits, Appeals, Cost Effectiveness and Other
    Reviews
  • USAC Tools Training Materials, DRT
  • California Teleconnect Fund
  • Q and A
  • Afternoon
  • Form 471 Tour
  • Tour of USAC Web Site
  • Calnet 2

3
The California Department of Education
(CDE)does not administerthe federal E-Rate
program.
  • CDE has no statutory authority to administer the
    federal E-Rate program
  • CDE only provides general information about the
    E-Rate program including training and outreach,
    reference materials, and other publicly available
    SLD/USAC resources

4
1. General Program Information
5
Discount Calculations
  • Calculated based on two factors
  • Percentage of students eligible for National
    School Lunch Program http//www.usac.org/sl/applic
    ants/step05/discount-matrix.aspx
  • Urban or Rural status of Entity
    http//www.usac.org/sl/applicants/step05/urban-rur
    al/

6
http//www.usac.org/sl/applicants/step05/discount-
matrix.aspx
7
Discount Calculationsand Entities
  • Instructional Facilities will have a discount
    that comes straight from Matrix
  • Non-Instructional Facilities will use District
    Weighted Average (District Office, Maintenance,
    Bus Barn, Gardeners Shed, etc)
  • For use on Block 4 of the Form 471

8
Eligibility
  • Schools Elementary, Secondary, Charters,
    Private, Religious, Adult Ed (conditional),
    Pre-K, Juvenile Justice
  • Libraries public, separate from school
    libraries
  • Consortia any combination of the above

9
Non-Instructional Facilities (NIFs)
  • Are eligible for Priority 1 services,
    telecommunications and internet access
  • Are NOT eligible for Priority 2 services,
    internal connections, UNLESS they are essential
    for the effective transport of information to an
    instructional building of a school or to a
    non-administrative building of a library

10
Non-Instructional Facility (NIF)
  • Scenario One NIF as a hub. This NIF is
    essential for the transport of info to the
    Schools and is eligible for P2 funding

11
Ineligible for Priority 2 NIF
  • Scenario Two NIF as an end-point. The schools
    would maintain service if the NIF were removed,
    therefore the NIF is ineligible for P2 support

12
Eligible Services - Categories
  • Four categories of service
  • Priority 1 (funded first)
  • Telecommunications Services
  • Internet Access
  • Priority 2 (starts with neediest applicants)
  • Internal Connections
  • Basic Maintenance of Internal Connections

13
Eligible Services List
  • Posted on USAC website (http//www.usac.org/sl/too
    ls/eligible-services-list.aspx)
  • Provides guidance to applicants and service
    providers on the eligibility of products and
    services under E-rate
  • Organized by category of service
  • Revised and updated each year in advance of the
    application window

14
FY09 Draft ESL updates
  • Eligible
  • Ethernet
  • VoIP user licenses
  • Ineligible
  • E-mail Archiving
  • Intranet Web Hosting
  • Video-on-Demand Servers
  • Softphones

15
Telecommunications Service
  • The transmission, between or among points
    specified by the user, of information of the
    users choosing, without change in the form or
    content of the information as sent and received.
  • Examples ATM, T-1, Centrex, Local and Long
    Distance Telephone Service, Cellular Service and
    Paging Service
  • Rule of thumb
  • USAC funds the various types of services
  • USAC does NOT fund end-user equipment - e.g.,
    telephone sets

16
Internet Access
  • Basic conduit access to the Internet
  • Examples T-1, DSL, DS-3, and Wireless service
  • Rule of thumb
  • USAC funds the conduit to the Internet
  • USAC does NOT fund content

17
Internal Connections
  • Components at the applicant site that are
    necessary to transport information to the school
    or library.
  • Examples Access Points, Routers, Switches, Hubs,
    Wiring, PBXs and Codecs
  • Rule of thumb
  • USAC funds items that get the information to the
    classroom or room in the library
  • USAC does NOT fund end-user equipment such as
    telephones (including IP telephones) or laptops

18
2 in 5 Rule
  • Applies to Internal Connections funding requests
    only
  • Is entity specific
  • Implemented in Funding Year 2005

19
Basic Maintenance of IC
  • Ensures the necessary and continued operation of
    eligible internal connection components at
    eligible locations.
  • Ex Repair and upkeep of eligible hardware, wire
    and cable maintenance.
  • Rule of thumb
  • USAC funds basic technical support of eligible
    hardware. (8 X 5, M-F)
  • USAC does NOT fund end-user support or help desk

20
Basic Maintenance of Internal Connections (BMIC)
  • Not subject to 2 in 5 rule
  • Caution
  • If a contract goes beyond what the FCC defines as
    basic maintenance, the entire contract will be
    denied
  • Eligible as recurring monthly services, i.e.
    SmartNet
  • Include the components that the BMIC Contract
    will cover on your Item 21 attachment
  • BMIC can not be 24/7 coverage

21
Manage the Cycle - Teamwork
  • Authorized signer ( Legally Authorized Signer )
  • Designated contact person (Will receive E-rate
    calls)
  • Organize paper trail
  • Written Technology Plan
  • Assessment of existing Contracts, with signatures
    and dates (expiring contracts, etc)
  • Prior years submitted applications
  • Correspondence from SLD, Service Providers, etc.
  • All bids received and evaluation documents
  • Calendar of Deadlines

22
Funding Commitment Process
  • E-rate Technology Planning What are my goals?
  • Form 470 - Starting the Application Process
  • Competitive Bidding
  • Form 471 Selecting Your Vendors
  • PIA (Program Integrity Assurance) Review
  • Funding Commitment
  • Form 486 Receipt of Services Confirmation
  • Form 472 BEAR and Form 474 SPI Invoicing
    Getting the Money

23
2. Technology Plan
24
Technology Plan Overview
  • FFC rules require an approved technology plan
    when receiving E-rate for more than basic
    telephone service.
  • Must be written prior to posting Form 470.
  • Must cover all 12 months of the funding year.
  • 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 3rd year for E-rate purposes.
  • Must include all services that the E-Rate
    discount covers.
  • Must be approved by a Certified Technology Plan
    Approver Locater Tool
  • Technology Plan approver locator tool
    http//www.sl.universalservice.org/reference/tech/
    default.asp

25
5 Required Elements of a Technology Plan
  • 1. Goals
  • 2. Professional Development
  • 3. Needs Assessment
  • 4. Budget
  • 5. Evaluation

26
Tech Plans for E-rate
  • EETT Plan for E-rate
  • Executive Summary/Introduction
  • Stakeholders
  • Curriculum
  • Professional Development
  • Infrastructure
  • Adult literacy
  • Research
  • Funding and Budget
  • Monitoring and Evaluation
  • Must also include E-Rate supplemental budget
    analysis and also see
  • www.cde.ca.gov/ls/et/rs/techplan.asp
  • E-Rate Only Plan
  • Goals a Realistic Strategy
  • Professional Development
  • Needs Assessment
  • Sufficient Budget
  • Evaluation Process
  • Tech Plan Help
  • www.usac.org/sl/
  • applicants/step02/

27
Tech Plan Written
  • Written same as created When a tech plan
    contains all required elements to support
    services requested on Form 470 USAC considers
    the plan written.
  • Must document and keep evidence of written date
    prior to filing Form 470 by e-mailing plan to
    Assistant Superintendent, memo with date
    announcing that tech plan is written, date
    stamp

28
Documentation of Tech Plan Approval
  • 1. E-rate only tech plan
  • You can expect to receive an approval letter from
    your COE or State Library as the USAC-certified
    technology plan approver. Ask your COE/State
    Library for projected approval date.
  • 2. EETT tech plan
  • You can expect to receive an approval message via
    email from CDE that confirms your EETT tech plan
    has been approved.
  • In general, CDE will make a determination
    regarding the approval of your EETT tech plan
    within 60 to 90 days of due date for review cycle
    (Cycles A, B or C).
  • View Tech Plan approval status at
    http//www.cde.ca.gov/ls/et/rs/ap/county.asp

29
EETT Tech Plan Approval
  • Due dates (cycles) for submission of EETT
    Technology Plan to CTAP for approval
  • Oct 3, 2008 Cycle A (Best practice)
  • Dec 5, 2008 Cycle B
  • April 3, 2009 Cycle C

30
Important Tech Plan Reminders
  • Include a supplemental budget analysis if using
    EETT plan as your approved E-Rate tech plan
    form located at www.cde.ca.gov/ls/et/rs/techplan.
    asp
  • Ensure all E-rate requested services/products are
    included in your technology plan

31
Technology Plan Help
  • SLD - http//www.usac.org/sl/applicants/step02/
  • Libraries - http//www.library.ca.gov/services/lib
    raries/erate.html
  • CDE - http//www.cde.ca.gov/ls/et/rs/techplan.asp
  • CTAP http//www.cde.ca.gov/ls/et/rs/ctapcoordinat
    ors.asp

32
Contact Information
  • State Library Rushton Brandis,
  • (916) 653-5471, rbrandis_at_Library.ca.gov
  • CDE John Vardanega,
  • (916) 323-2241, jvardane_at_cde.ca.gov
  • CDE Tech Plans Bill Fong,
  • (916) 322-5898, bfong_at_cde.ca.gov
  • Department of General Services (CMAS) Mary
    Gilbert,
  • (916) 375-4377, mary.gilbert_at_dgs.ca.gov
  • K-12 HSN/Butte COE Russ Selken, 530-532-5678,
    rselken_at_bcoe.org

33
Technology Plan Help
  • SLD - http//www.usac.org/sl/applicants/step02/
  • Libraries - http//www.library.ca.gov/services/lib
    raries/erate.html
  • CDE - http//www.cde.ca.gov/ls/et/rs/techplan.asp
  • Recent News Brief from SLD - http//www.usac.org/s
    l/tools/news-briefs/preview.aspx?id116

34
3. Competitive Bidding and the Form 470
35
Preparation for Posting of Form 470
  • Document ALL of your eligible existing services,
    contracts and their expiration dates
  • Identify existing contracts and services
  • Expected growth (P1 and P2)
  • National School Lunch Program (NSLP) data for
    discount percentage
  • Identify bidding restrictions (i.e., CMAS,
    geographic restrictions, etc.)

36
Forms 470
  • Indicates the services and categories of service
    which you are seeking discounts
  • Must be based on tech plan
  • Must be posted for 28 days
  • Indicates if you are planning/have issued RFP
  • Can only correct this by posting new Form 470
  • Indicates any special requirements and/or
    disqualification factors
  • Indicates who will be receiving the services

37
File Online!
  • Once the Form 470 is posted you must
  • Certify online using a PIN, OR
  • Print the certification page, sign and mail
  • Mail this form immediately
  • View form online to get the Allowable Contract
    Date
  • Also provided in the Receipt Acknowledgement
    Letter

38
Special Notes for Form 470 Processing
  • When does the 28 day bidding period begin?
  • The day that ALL material for public viewing
    (i.e. RFP) is made available
  • AND
  • The day the Form 470 is posted online
  • If RFP is released AFTER the posting of the Form
    470 the 28 day bidding period begins with the day
    the RFP was released

39
Form 470 Reminders
  • Allow adequate time
  • Competitive Bidding minimum of 28 days
  • Local Procurement
  • Board Approval
  • Signing Contracts
  • CMAS - Letter of Intent (LOI)
  • CALNET 2 3 signatures needed
  • Understand
  • Your existing services
  • Products and services you will need in the coming
    year
  • Identify E-rate category for each product and
    service, P1 or P2

40
Receipt Notification Letter (RNL)
  • GOLDEN Opportunity to review application and
    correct minor errors
  • http//www.universalservice.org/_res/documents/sl/
    pdf/sampleletters/470RNL.acc.pdf

41
Competitive Bidding
  • Fair and open competitive bidding process
  • Avoid conflicts of interests
  • Independent Consultant vs. Service Provider
  • Applicant vs. Service Provider
  • Follow the rules FCC, State and local
  • Read the contract fine print
  • Document the process!!!

42
Competitive Bidding and Program Compliance
  • http//www.sl.universalservice.org/reference/BestP
    ractices.asp
  • Keep copies of all bids, winning and losing
  • Documentation on the award process and the
    rationale for the bid award
  • Complete copies of all related contracts
  • Best Practice Use standard evaluation process
    for all bids. Keep evaluation documentation for
    each bid.

43
Program Compliance
  • If you get NO bids document this for audit
    purposes
  • Same is true if you get only ONE bid
  • You may need to be proactive in soliciting for
    bids (If not using CMAS)

44
Evaluation Criteria
  • Price must be the most heavily weighted factor
  • Do not include Intent to Award or Evaluation
    Criteria in CMAS Request for Proposal
  • Can choose most responsive and responsible
    response, but must DOCUMENT the choice and
    process
  • Have District official SIGN and DATE the
    completed rubric as acknowledgement

45
SAMPLE SAMPLE SAMPLE SAMPLE SAMPLE
46
Form 470 Multi Year Contracts
  • You may not need to file Form 470 every year if
  • The language on the Form 470/RFP covered all
    services on the contract AND
  • The applicant indicated on the Form 470 that a
    contract was being sought AND
  • The applicant indicated on the Form 470/RFP that
    a multi year contract (perhaps w/voluntary
    extensions)

47
Contracts
  • Must be signed AFTER 28 days have elapsed but
    BEFORE you file your Form 471
  • Must be signed and dated by BOTH parties
    applicant and service provider
  • CALNET 2 ATO must have three signatures to be
    binding contract
  • Be prepared to explain documents that dont look
    like a traditional contract.

48
4. Form 471
49
Form 471 Your application for Funds
  • Must be filed every funding year
  • This is your actual funding request
  • Based on posted on Form 470(s)
  • One or more funding requests
  • This is your Who, What, When, Where, How
  • Service providers chosen
  • Services being requested
  • Dates for services
  • Service Delivery locations
  • Signed contracts or tariffed services

50
Form 471 Filing Deadline
  • The Window for the Form 471 filing window has not
    been announced yet.
  • If you are on CDE E-rate List SERV, you will be
    notified when FCC determines filing deadline,
    which then determines Form 471 filing deadline
  • If you receive USAC weekly newsbriefs,
    notification will be published there.
  • Must be submitted BEFORE close of window
  • SLNewsBrief_at_lists.universalservice.org
  • http//www.cde.ca.gov/ls/et/ft/eratelyrisserv.asp

51
Form 471 Filing Deadline
  • Submit BEFORE close of window
  • DEADLINE DATE ??

52
Form 471 Best Practices
  • Get a Partner
  • Do your own Timeline of milestones
  • File Online
  • Certify BEFORE close of window
  • Online if using PIN
  • By trackable mail if you do not use your PIN
  • File EARLY!!
  • Do everything before Deadline
  • Allow enough time to fully complete process
    paperwork
  • Organize your paperwork

53
Keep Your Dates in Order
  • Remember the correct order for dates
  • Allowable Contract Date (28 days after 470)
  • THEN
  • Contract Award Date
  • THEN
  • Form 471 filing
  • THEN
  • Form 471 Certification date
  • ALL BEFORE
  • Window close

54
Form 471
  • Apply Online http//www.sl.universalservice.org/
    menu.asp
  • Form 471 Test page http//usactrain.solixinc.com
    /TrainingSiteWarning.asp?

55
Form 471 donts
  • DONT file Priority One and Priority Two funding
    requests on the same Form 471
  • DONT forget to wait at least 28 days after any
    mandatory processes associated with your
    competitive bidding before selecting a service
    provider or signing any contracts
  • DONT submit your Form 471 BEFORE signing all
    related contracts
  • DONT forget to CERTIFY your submitted
    application (whether electronic or paper
    certification)

56
Form 471 Reminders
  • Separate your Priority 1 and Priority 2 funding
    requests onto separate Form 471s.
  • Verify that you are using correct establishing
    Form 470 number on each Block 5 Funding Request.
  • Choose the correct category of service (e.g.,
    Telecom, Internet, etc.)
  • Check your math, check it again
  • Review your application
  • Validate the information

57
Pre-Commitment Review
  • Things to do before PIA contacts you
  • Submit your Item 21 Attachments online or paper.
  • Place application number(s),FRN(s), Attachment
    ID, and page numbers on Item 21 Attachments
  • Indicate Bandwidth when you are requesting
    telecom or Internet access
  • Indicate the entities receiving services and
    locations
  • Clearly label ineligible items and costs
  • Indicate product make and model for each product
    requested
  • Provide a detail product or service description

58
Item 21 Attachment
  • Samples available on USAC website
  • http//www.sl.universalservice.org/reference/Form4
    71item21Attachments.asp
  • Remove ineligible costs be careful
  • 30 rule 30 or more of funding request dollar
    value cannot be for ineligible products and
    services. the entire request may be denied
    unless
  • Can be rectified during your PIA process Remove
    it-Split it up- separate FRN
  • Work with service provider(s) to create your Item
    21 attachment(s)

59
Reciept Acknowledgment Letter Process
  • Opportunity to verify information one more time
  • Three weeks from date of letter to submit
    corrections
  • http//www.usac.org/_res/documents/sl/pdf/samplele
    tters/471RAL.pdf

60
One Last Chance.
  • 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

61
5. Program Integrity Assurance
62
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

63
PIA Reviewer
  • Be nice to your reviewer even if they are not
    nice to you!!!

64
Be Responsive
  • Respond promptly, be sure to answer questions in
    their entirety
  • Document communication with PIA, send e-mail to
    PIA as a confirmation of your phone conversations
  • Ask for more time if you need it
  • Be advised that if you ask for more time the
    Reviewer will move on to another application
  • Dont assume that Reviewer has all of the
    information you sent in as part of your Item 21
    attachment.

65
If corrections are needed
  • Services Cost Allocations
  • Work with the service provider to identify the
    ineligible services, so they are clearly
    identified
  • On the Item 21 Attachment identify the
    ineligibles services and associated costs
  • Prepare a revised Form 471 Block 5 to reflect
    the cost allocations
  • Best Practice Break out FRN with PIAs
    assistance
  • Entity Removal
  • On the original Form 471 Block 4 worksheet
    identify the entities to be removed
  • Prepare a revised Form 471 Block 4 worksheet if
    new discount calculations and student counts
  • On the Block 5 funding request, indicate your
    revision to the dollars requested based on the
    share of the funding request for the entities
    being removed

66
What Happens After PIA Review
  • A Decision FCDL (Funding Commitment Decision
    Letter)
  • Funded
  • Not Funded
  • As Yet Unfunded (Priority 2 requests)
  • Cancelled
  • IMPORTANT Check all entries in the FCDL
    carefully to make sure there are not data entry
    errors.

67
Post-Commitment
  • Review the FCDL for Accuracy
  • Read the FCDL comment to determine if
    modifications have occurred to the FRN to ensure
    you invoice for the correct services.
  • Verify SPIN, discount, fund request, start and
    end dates, and contract number (if applicable)
  • If you disagree with the decision, you may file
    an appeal.

68
What next?
  • FCDL should be your trigger to file subsequent
    forms
  • Starts deadline clock for appeal on denial(s)
  • Note Appeals must be done within 60 days of the
    date of FCDL

69
6. Form 486 Invoicing
70
Purpose of 486
  • Notifies USAC that entity is ready to receive
    services, services have started or are scheduled
    to start and invoices can be paid
  • Certifies that Tech Plan is approved and meets
    program requirements
  • Certifies status of compliance with Childrens
    Internet Protection Act (CIPA)
  • Do NOT miss Form 486 deadline for your district
    LATE FILINGS WILL LOSE
  • http//www.universalservice.org/sl/applicants/step
    10/form486-filing-information.aspx

71
What is the Form 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 SLD will send letter
    giving reminder to file Form 486 (Alaska
    Gateway order)
  • Take this letter seriously you have 20 days from
    date of the SLD letter to take action!

72
Form 486 Compliance Review
  • USAC may review Form 486 for compliance with
    program requirements for technology planning
    before the form is successfully processed.
  • If Form 486 undergoes review, USAC does not issue
    a Form 486 Notification Letter until all
    compliance issues have been resolved. (i.e.
    Approved Tech Plan)

73
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

74
Receipt of Funds
  • One of two ways
  • Applicant pays entire bill up-front and gets
    reimbursed
  • Form 472 (BEAR) BEAR submitted by Applicant
  • Service Provider applies discounts to bills and
    submits invoices to USAC for reimbursement
  • Form 474 (SPI) filed by Service Provider

75
Special Note on Form 472
  • Note Form 472 (BEAR) cannot be filed if
    applicant is also receiving California
    Teleconnect Fund (CTF) discounts on same
    services.
  • Applies only to Telecommunications (data-voice)
  • Internet services may also be eligible for CTF
    discounts

76
Important Reminders
  • Print and retain copies of everything
  • Keep E-Rate files organized
  • Create a timeline of E-Rate deadlines
  • Share this information with others at your site

77
7. Program Updates Gotchas
78
Forms
  • Form 470
  • Be careful when specifying services
  • Understand the categories of service
  • Can combine all services that cover Priorities 1
    and 2 on the same Form 470
  • Form 471
  • File separate forms for Priorities 1 and 2
  • File separate forms for different discount bundles

79
California Pre-K and Adult Ed
  • These student populations are eligible for E-Rate
    discount in California except
  • Adult Ed. enrichment VS secondary curriculum
  • Children under age of 3
  • Treat same as traditional classrooms or
    facilities
  • Obtain entity numbers and establish poverty level
  • Head Start is 90
  • May use alternative discount methods
  • Be sure to add their plans to your District
    technology plan to ensure compliance

80
Non-Instructional Facilities Priority Two GOTCHA
  • Educational Purposes Priority 2
  • Priority 2 services to Non Instructional
    Facilities (NIFs) are eligible ONLY IF those
    internal connections are essential for the
    effective transport of information to an
    instructional building of a school or to a
    non-administrative building of a library.

81
2 in 5 Rule for IC
  • Determined on an individual entity basis or
    shared worksheet (bundle)
  • All entities on a Block 4 worksheet that utilize
    approved funding for IC, are counted as taking a
    year
  • 2009 is the fifth year for the rule (if applicant
    applied in 2005)
  • Must file Form 500 to cancel FRN if approved and
    not utilized
  • Establish a matrix for tracking the UTILIZATION
    of funds for approved goods or services
  • USAC tool does not track pending or utilized,
    just funded

82
October Important Deadlines
  • Complete your BEAR for 07-08 prior to Oct 28th,
    2008
  • Pay attention to 486 deadlines, Due 120 days
    after FCDL (Note this is due Oct 28th if you
    received your FCDL for 08-09 on or prior to July
    1st)
  • Have your tech plan written PRIOR to posting your
    Form 470 for 09-10 if it expires June 30th 2009
    or sooner
  • File your Form 470 for 09-10 NOW!

83
8. Audits, Appeals, Cost Effectiveness and Other
Reviews
84
Compliance Attestation Examination
  • AKA The Big Audit
  • Directed by the FCCs Office of Inspector General
    (OIG)
  • Randomly selected by FCC
  • Annually between November and July 1st

85
Compliance Attestation Examination
  • Examine payments made during a single fiscal year
    May include examination of MUTIPLE 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

86
Examples of Rule Violations that Warrant Recovery
of Funds
  • Insufficient documentation of the competitive
    bidding process
  • 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/train
    ing-2008/fall/materials.aspx

87
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 an E-Rate Binder for EACH funding year
  • USAC Compliance Documentation Checklist for
    audits
  • http//www.usac.org/_res/documents/sl/pdf/CompDocC
    hecklist.pdf

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Who Should Be Available During Audits?
  • Person(s) who
  • filed the E-rate forms
  • 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
  • Appoint a single contact person who can manage
    interactions between auditors and staff members

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Document Retention Requirements
  • Keep for 5 years after last date of service
  • Be aware of contract dates and extensions as the
    5-year minimum may be extended
  • All USAC correspondence, including Quarterly
    Disbursement Reports
  • Make sure all departments understand
    documentation retention requirements for E-Rate
  • Align Board policy with E-rate requirements

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Technology Plan Documentation
  • Copy of Technology Plan that covers entire year
    being audited (should be part of your ANNUAL
    e-rate documentation)
  • Copy of Draft and creation date documentation
  • Proof of approval of Technology Plan
  • Supplemental Budget analysis (if using EETT Plan)
  • Summary of the technology environment and a
    high-level network diagram

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Bidding Documentation
  • Copy of State and Local procurement policies
  • Form 470 and all request for bid documentation
  • RFP/RFB/RFQ, announcements, advertisements,
    addendums, etc
  • ALL correspondence between applicant and service
    providers (email, phone log, job walk sign-in
    sheet, etc)
  • Copy of all bids received (winning and losing)
  • Document if NO bids are received
  • Bid evaluations
  • Notice of Award to winning vendor
  • Contract
  • Board Award
  • Copy of any change orders

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Invoicing Documentation
  • Proof of payment to service providers
  • Copies of warrants or cancelled checks, check
    register
  • Auditors will ask for reconciliation of payment
    by invoice
  • Copies of all invoices, phone bills
  • Invoices should be detailed
  • Copies of BEAR Forms
  • Reconciliation (by FRN) of service provider
    invoices to BEARs submitted to SLD (removal of
    all ineligible costs)
  • Copy of reimbursement check from service provider
    to prove receipt of E-rate funds if applicable

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Priority Two Services Documentation
  • Equipment purchased using E-Rate
  • Detailed vendor invoices
  • Packing slips showing date of delivery
  • Walk through or sign off that shows when services
    were delivered
  • Asset register see detailed USAC example
  • http//www.usac.org/_res/documents/sl/pdf/2007_tra
    ining/samples-checklist-inventory-list.pdf
  • Well-marked equipment
  • Service Substitution
  • Equipment Transfer documentation
  • Basic Maintenance
  • Maintenance log

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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
  • Copies of Forms 479 and/or Forms 486, if
    applicable

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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-Memo
    s/2008/SP_29-2008.pdf
  • Alternative Methods
  • Keep copies of every survey and a summary report
  • Source data and annual poverty guidelines

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Other Documentation
  • SPIN change requests including copy of notice to
    original service provider
  • School closure, consolidation or construction
    documentation
  • ALL communication regarding E-Rate
  • Service Providers
  • SLD/USAC
  • Case Numbers
  • PIA questions and responses
  • Documentation of other services necessary to make
    effective use of E-rate discounts, such as
  • Training
  • End user equipment

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Other Documentation
  • Reports from any other audits conducted that
    relate to either E-rate program or the NSLP
  • Eligible Services List for every funding year
  • Board minutes and policies relating to document
    retention or other E-rate related issues
  • Financial statements and annual budgets

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Other Levels of Scrutiny
  • Site Visits
  • Selective Review Information
  • Request (SRIR)
  • Cost Effectiveness Review

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Site Visits
  • Single FRN reviewed
  • On-site 4 hour visit
  • Review of
  • Asset register
  • Equipment in the field
  • Staff development
  • Invoices/payments
  • Technology plan approval
  • Competitive bidding
  • Best practices feedback

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Item 25 Selective Reviews
  • PIA on steroids
  • Intensive review of the Item 25 Block 6
  • certification from Form 471
  • Complete documentation of necessary
  • resources
  • hardware, software, professional development,
    retrofitting, maintenance
  • Competitive bidding documentation
  • Technology Plan
  • Budget matching funds and support for non
  • E-rate items

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Cost Effectiveness Review
  • Occurs during PIA
  • Must be able to justify that the selected
    solution is cost effective, not just the MOST
    cost effective
  • Bright line test
  • Routers that cost two to three times the
    commercially available price
  • Single bid received does not equal cost
    effective
  • Think about reasons why the price may be
    inflated
  • Location
  • Structural challenges
  • Anticipated growth of student population, etc

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Appeals
  • Submitted to USAC if you feel program rules were
    not upheld by the denial of funds
  • Submitted to FCC if you are questioning the
    existing program rules or if USAC denies the
    initial appeal

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USAC Appeals Approved for Limited Circumstances
  • 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
  • http//www.usac.org/sl/about/appeals/appeals-guide
    lines.aspx

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9. Tools Data Retrieval Tool and Other
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Data Retrieval Tool
  • Comprehensive data regarding status of
    applications, past and present
  • Search by Funding Year, Entity number, State,
    Type of Service, etc
  • Provides deadline information for forms
  • Columns to look at on the DRT for deadline
    information
  • B 471 Status
  • E 470 Status
  • P Commitment Status (If funded then look at R
    to see if 486 has been filed)
  • R 486 SSD (If blank, no 486 on file)
  • T FCDL date (this date 120 calculates the
    deadline for the Form 486)
  • AX BEAR or SPI
  • www.usac.org/sl

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View Prior Years Applications
  • www.usac.org/sl
  • Apply Online
  • Form 470 Search Posted
  • Form 471
  • Application Status (if you dont know the
    application number)
  • Display (must have application number)

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10. California Teleconnect Fund
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11. Q and A
  • Questions?

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Contact Information
  • State Library Rushton Brandis, (916) 653-5471,
    rbrandis_at_Library.ca.gov
  • CDE John Vardanega, (916) 323-2241,
    jvardane_at_cde.ca.gov
  • CDE Tech Plans Bill Fong, (916) 322-5894
  • K-12 HSN/Butte COE Russ Selken, 530-532-5678
    rselken_at_bcoe.org

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3. CALNET 2
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CALNET 2 - What is it and how does it fit with
E-rate?
  • Contract (s) held and administered by State
  • CALNET 2 Contract effective date 1/30/2007
  • CALNET 2 contract expiration date 1/29/2012
  • Master contract purchasing vehicle for all
    telecom services
  • Available to all Public Sector Customers
  • Competitively bid contract - Result of an 18
    month bid process (already bid)
  • Full range of products and services
  • Service Level Agreements

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CALNET 2 MSAs
  • All four MSAs were signed on January 30, 2007
  • Each MSA is for a 5-Year Term (to January 29,
    2012) with the Potential for 2 One-Year
    Extensions at the States Option (2014)
  • Each MSA is a separate contract called CALNET 2,
    along with their MSA number. They are also
    collectively called CALNET 2.
  • Until CALNET I expires you will see I and II
    or 1 and 2 after the word CALNET to try to
    avoid Contract Confusion
  • In some cases you will see just CALNET - that
    will mean both CALNET I and CALNET II as
    applicable as CALNET I phases out, it will mean
    CALNET 2

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CALNET 2 MSAs
  • MSA 1 Voice, Data Video Services ATT
  • MSA 2 - Long Distance and Network Based Services
    ATT
  • MSA 3 Internet Protocol Voice, Data, and Video
    Services Verizon Business (VzB)
  • MSA 4 Broadband Fixed Wireless Access Data
    Services VzB
  • 10 Lower Pricing Overall From CALNET I

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CALNET 2 MSAs
  • Transition of Existing CALNET Services to MSAs I
    2 No Cost
  • Transition Out Will Eventually Impact Your
    Agency CALNET I Expires by 12/03/08 based on
    Individual ATO Agreements
  • CALNET 2 Each ATO is for a Two Year Term
    When Term is Up, Can Use the MSAs Without
    another ATO For Those Services on the ATO Adding
    Services Requires New ATO, New term
  • New Pricing Starts Within 120 Days of Each
    Approved CALNET 2 ATO
  • http//www.dts.ca.gov/stnd/calnet-transition.asp

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CALNET 1 to CALNET 2
  • State Posted Form 470 267290000544188 on Sept 15,
    2005
  • Includes Telecommunications Services
  • Did NOT Include ISP
  • Limited Internal Connections (extended demarc)
  • CALNET 2 Contract was signed on January 30th,
    2007 (State Master Contract)
  • CALNET 2 http//www.dts.ca.gov/stnd/calnet-II/cal
    netII.asp
  • RFP http//www.dts.ca.gov/stnd/calnet-II/revised-
    calnetII-rfp.asp
  • May wish to post your own form 470 for all
    services you will apply for (See additional
    hand-outs)
  • Do your own analysis to determine best choice for
    your agency
  • Three Signatures are required on a CALNET 2
    contract

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CALNET 2 MSAs 1 and 2 includes
  • MSA 1
  • High Speed Optical Services (Enhancements and
    Additional Services)
  • ATM
  • Opt-e-MAN
  • CSME
  • Enhanced Data Services
  • MPLS (AVPN)
  • Remote VPN (Anira)
  • Interlata Data Services
  • Internet Services
  • Unified Messaging
  • Enhanced Centrex Features
  • VoIP
  • Business Centrex lines
  • Voice mail
  • Local trunks
  • Frame relay
  • MSA 2
  • Enhanced Toll Free
  • Long Distance Voice
  • Audio Conferencing
  • Net Conferencing
  • Complete Suite of Call Center Capabilities
  • ACD
  • IVR

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IP Voice, Data, and Video Services (MSAs 3
4)Internet Protocol (IP) based solutions to
provide voice, video, and data services
  • Voice Over IP (VOIP) Services
  • Converged Services VOIP
  • Converged Services - IP Transport
  • Converged Services - Required Premise Equipment
  • IP Contact Center Services
  • Other IP Services
  • Wiring and Support Services

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SLD Guidance for E-rate Yr 11
  • See Page 5 of SLD Decision Grid for SLD guidance
    (handout and next slide)
  • Clients either
  • post own Form 470 OR
  • use States Form 470 267290000544188, posted on
    9/15/2005.

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SLD Decision Grid
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How to decide if schools/libraries should post
their own Form 470?
  • Are the services you are seeking included in
    States RFP?
  • Are services you are seeking included in States
    Form 470?
  • Telecommunications services (Priority 1 services)
  • Limitations to States Form 470
  • Form 470 did not include Internet Access
  • Form 470 included Internal Connections defined
    as Service or Function Extended D-Marc
  • Form 470 did NOT include Basic Maintenance on
    Internal Connections (Priority 2 services)
  • You can do a specific form 470 if the service you
    need is not covered by the state form 470 (see
    the limitations described above as examples)

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Moving from CALNET to CALNET 2 Steps in
Ordering
  • Work with your Account team to sign ATO create
    product list attachment
  • To be legal binding contract, CALNET 2 contract
    requires 3 signatures customer ATT State
  • ATO
  • Attachment to ATO (product list attachment for
    svcs to be covered by ATO) has to be initialed by
    customer

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CALNET 2 Multiple SPINS
  • CALNET 2 awarded to two service providers
  • Each Service Provider may have multiple SPINs
  • Verify SPIN with service provider BEFORE filing
    the Form 471

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CONTACTS
  • CALNET Transition Questions and Requests for
    Information
  • Phone (916) 657-9150
  • Email stndhelpme_at_dts.ca.gov
  • CALNET Transition Homepage
  • URL www.dts.ca.gov/stnd/calnet-transition
  • Statewide Telecommunications and Network Division
    Homepage
  • URL www.dts.ca.gov/stnd
  • Department of Technology Services Homepage
  • URL www.dts.ca.gov
  • DTS-STND and Contractors CALNET Homepages, etc.
  • www.calnet.ca.gov

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CALNET 2 Contract Resources ATT
  • www.CALNETII-Info.com
  • Customer Sales Support Center
  • 877-972-6279
  • CALNET Billing
  • 877-9-CALNET, 877-922-5638
  • Account Team
  • Contact your account team
  • Bev Agron, E-rate Specialist (925) 824-0615
  • calnet.ca.gov (select ATT logo)

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CALNET 2 Contract ResourcesVerizon Business
  • Verizon Business
  • 800-477-0221
  • http//calnet2.verizonbusiness.com
  • http//CALNET.ca.gov (click on Verizon link)
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