Head Start E-Rate Help Desk

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E-Rate and Head Start

• E-Rate Series Webinar 5
• Form 471 Service Provider Selection

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E-Rate Series Webinar 5Form 471 Service
Provider Selection

• Presenters

Bridget Shea
Bill Welch
Kenny Acklin
OHS Head Start E-Rate Help Desk Head Start
Knowledge and Information Services 866-878-6032
erate_at_headstartinfo.org Washington DC
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E-Rate Series

• Webinar 1 Applying for E-Rate
• Webinar 2 Writing a Technology Plan
• Webinar 3 Interpreting the Eligible Services
  List the Assessment
• Webinar 4 Understanding the Competitive Bidding
  Process
• Webinar 5 Selecting Service Providers

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Polling Question
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Agenda

• Review
• Selection Criteria
• Complete Form 471
• Receipt Acknowledgement Letter
• Interview Answers (Brent Schultz)

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(No Transcript)
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Documenting the Process

• All documentation on the competitive bidding
  process and vendor selection must be kept for
  five years.
• You MUST certify and acknowledge on the Form 470
  and Form 471 (Services Ordered and Certification
  Form) that you may be audited and must retain all
  records to verify the accuracy of information
  provided.

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Selecting Service Provider

• Price Primary Factor
• Weight 28 days after filing 470 or RFP, whichever
  is later prior to selecting a service provider.
• Give adequate time for on-site walk through if
  required.

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Form 471
FORM 471

• Two Options
• File a paper copy. Download the form at
• http//www.universalservice.org/sl/tools/required-
  forms.aspx
• File On-Line at
• http//www.sl.universalservice.org/menu.asp

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Form 471
FORM 471

• PAPER FORM REVIEW
• ON-LINE FORM

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Questions / Discussion

• Form 471 Data Entry
• Block 1 Contact Information
• Block 2 Survey Information
• Block 3 (Libraries)
• Block 4 Discount Worksheets
• Block 5 Funding Requests
• Block 6 Certifications

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Receipt Acknowledgement Letter (RAL)
RAL

• Acknowledgement - Form 471 has been completed
  provides important deadlines and reminders
• Opportunity to identify errors make
  corrections. Corrections can be made on your copy
  of Form 471 RAL and mailed back to USAC.

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Guest Presenter

• Brent Schultz
• Opportunities, Inc.

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Questions / Discussion

• Review
• Completing Form 471
• Receipt Acknowledgment Letter

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More Training

•  Monthly Update today after this webinar USAC
  website.
• Fun with Forms and Tech Plans Repeat September
  in October
• Fun with Forms on Friday Form 470/471 and other
  helpful information

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• For Discussion and Reference during our monthly
  update

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Step Description Delays
Action Item 21 provides only generic product and service description (e.g. servers or turnkey Internet Access)
Reaction Reviewer must reach out for detailed description including make and model and specific use of the server gt 15 days for applicant 1 week for PIA
Result Delays the issuance of the FCDL (and by extension, your ability to invoice). Invoicing team may look at the specifics in the Item 21 attachment to confirm eligibility of the services. gt thereafter, 1 additional week
Avoid this by Work with your applicant to provide detailed Item 21 attachments including make and model number and functions and submit with the application. Remind applicants to include function for servers, cost allocation, any certifications.
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Step Description Delays
Action Documents provided during PIA review is inconsistent with the information on Form 471
Reaction Reviewer must reach out and resolve the discrepancy gt 20 days 1 week for PIA
Result Delays the issuance of the FCDL (and by extension, your ability to invoice). gt 1 week
Avoid this by Work with your applicant to review the information that will be included in your funding requests. Ask for a copy of the submitted Item 21 If you are the one writing the contract, provide clear (and possibly separate list) of the eligible components, specific information related to invoicing (pre-payments or progress payments) and other program compliance related information.
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Step Description Delays
Action Applicant triggers criteria for Selective Review
Reaction Applicant get a Selective Review gt 60 days
Result Applicant must submit significantly more information, which takes time to gather and review. PIA may ask follow up questions. Review must go through multi-level review process Delays the issuance of the FCDL (and by extension, your ability to invoice). gt 90 days
Avoid this by Not completely avoidable but made easier by Comply with all program rules, as well as state and local laws and regulations Keep complete set of documentation
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Step Description Delays
Action Applicants requests funding for very expensive widget and/or very expensive maintenance
Reaction Applicant undergoes Cost Effectiveness Review gt 30 days
Result Applicant must gather support for why widget/maintenance was selected, and explain why such an expensive product or service is necessary Review must go through multi-level review process Delays the issuance of the FCDL (and by extension, your ability to invoice). gt 45 days
Avoid this by Ensure that the services that you are proposing are right sized. If circumstances dictate an expensive solution, be prepared to explain why that solution is necessary and cost-effective.
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Step Description Delays
Action Telecom Provider fails to file FCC Form 499 Delay total function of your time to file Form 499
Reaction Provider loses their Y and is ineligible to provide telecommunications service
Result Provider loses business as applicants are given the opportunity to change to a different provider during PIA review. Applicants that stay with you can lose their telecommunications funding.
Avoid this by Read all correspondence from USAC. File your FCC Form 499 on time Include your Filer ID on the Form 499 Make officers aware of filing requirements and importance of the correspondence.
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Step Description Delays
Action USAC Beneficiary audit discovers delivery of ineligible equipment to eligible and ineligible locations after the payment of an invoice. 1 year for audit process to complete
Reaction USAC initiates audit response process and possibly COMAD/RIDF. gt 30 days
Result Applicant must gather and submit additional information. Review teams conduct special analysis Review teams may ask additional questions. Responses may be reviewed by senior staff Funding rescinded may be recovered. Delays issuance of pending commitments Delays payment of pending invoices gt 120 days
Avoid this by Comply with program rules, state and local regulations and laws
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Step Description Delays
Action As a result of the audit, applicant must return funds to USAC and fails to pay on time
Reaction Applicants Red Light is turned on gt 30 days
Result After no payments within 30 days from the Notice of Dismissal Letter, all pending funding requests are denied. Service provider cannot invoice for the services that were in the pending requests. gt 45 days
Avoid this by Read all correspondence from USAC. Avoid the problem that resulted in the COMAD. Comply with program rules, state and local regulations and laws. Keep complete records. If invoiced by USAC pay, or if disagree, appeal within the required timeframes.
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Step Description Delays
Action As a result of the audit, service provider must return funds to USAC and fails to pay on time
Reaction Providers Red Light is turned on gt 30 days
Result All invoices are held. Payments are not forthcoming for pending invoices. Until payment is made.
Avoid this by Read all correspondence from USAC. Avoid the problem that resulted in the COMAD. Comply with program rules, state and local regulations and laws. Keep complete records. If invoiced by USAC pay, or if disagree, appeal within the required timeframes.
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Step Description Delays
Action As a result of the audit, applicant and/or SP is deemed a non-compliant auditee.
Reaction USAC initiates non-compliant auditee process. gt 30 days
Result Applicant must update their processes and procedures that lead to the audit finding and then demonstrate to USAC that additional controls have been put in place that will prevent the same problem from recurring. Funding is put on hold during this time. Review teams conduct special analysis. Responses may be reviewed by senior staff Delays issuance of pending commitments Delays payment of pending invoices If no response by due date, pending funding is denied. gt 6 months
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Step Description Delays
Avoid this by Read all correspondence from USAC. Avoid the problem that resulted in the COMAD. Comply with program rules, state and local regulations and laws. Keep complete records. Maintain a robust set of internal controls and provide training to your employees to ensure all members of your organization know the rules.
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Step Description Delays
Action Service Provider acts as the Applicants Consultant Whistleblower call comes into USAC
Reaction Application undergoes heightened scrutiny by various review teams gt 90 days
Result Applicant has to gather and submit additional documentation. Review teams conduct special analysis Review teams may ask additional questions, and even conduct on-site interviews. Application decisions reviewed by senior USAC staff Pending commitments are put on hold. Pending invoices may also be put on hold. Delays payment of pending invoices. gt 90 day
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Step Description Delays
Avoid this by Comply with program rules, state and local regulations and laws. Keep complete records. Do not act as the applicants consult, or take actions that may give the APPEARANCE of doing so. This includes providing any assistance for any competitive bidding item including the Form 470 and/or the RFP. Maintain a robust set of internal controls and provide training to your employees to ensure all members of your organization know the rules.
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Step Description Delays
Action Service provider and/or applicant engages in fraud or anti-competitive conduct, including conflict-of-interest, market allocation, collusion, bid-rigging, etc. Whistleblower call come in to USAC
Reaction Application undergoes heightened scrutiny by a variety of review teams. gt 180 days
Result Pending commitments are put on hold. Pending invoices may also be put on hold. Applicant has to gather and submit additional information. Review teams conduct special analysis Review teams may ask additional questions, and even conduct on-site interviews. Review of application by senior USAC staff
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Step Description Delays
Result Law enforcement agencies launch own investigations, possibly resulting in civil or criminal actions, including trials, which can result in fines and/or prison. gt 1 year
Avoid this by Comply with program rules, state and local regulations and laws. Keep complete records. Do not engage in illegal activity. Maintain a robust set of internal controls and provide training to your employees to ensure all members of your organization know the rules.
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IDEAS Feedback?
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Thank You !

• Presenters

Bridget Shea
Bill Welch
Kenny Acklin
OHS Head Start E-Rate Help Desk Head Start
Knowledge and Information Services 866-878-6032
erate_at_headstartinfo.org Washington DC