E-rate: A Review for 2011 – Session starts at 10am –

1. November 19 , 2010, 10am – 12:30pm E-rate:AReview for 2011– Session starts at 10am – Steve Sanders 608-266-3856stephen.sanders@dpi.wi.gov Bob Bocher 608-266-2127 (cell 608-212-2773) robert.bocher@dpi.wi.gov Slides: http://dpi.wi.gov/pld/ppt/eratereview2011.ppt

2. Agenda • Overview of the program • Eligibility, changes for 2011 and discounts • Technology plans • Application forms, follow-up processes • Contracts • TEACH and BCN update

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

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

5. What Are The Eligible Services? • Priority 1 • Telecommunication services (telco’s only) • Local/long distance, wireline and wireless, broadband • Telecommunications (any entity) • Dark and lit fiber • Internet access • Basic access • Priority 2 • Internal connections (2 in 5 year rule) • Basic maintenance of IC (each year) • Very few WI applicants get P2 • 2010 funding may drop to 80%? When demand exceeds funds available. Priority 1: Funded first. Priority 2: Funded starting at highest discounts (90%, 89%, 88%, etc.). Seldom funded <80%.

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

7. 2011 E-rate Changes* • Dark/lit fiber eligible from any entity** • No technology plan required for P1 services • Changes to Forms 470/471 • Strengthens competitive bidding process • Cannot accept anything of value from service providers** • EDU 2011 program (off-premise wireless connectivity) • Restricts unbundled warranties** • Restricts Operational SPIN changes** • Not addressed: • Discount matrix, P2 funding, service provider board issue * *Seeking more info from FCC * FCC Sixth Report and Order, Sept 23, 2010

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

9. Discount Matrix State average is 60% (was 54% in 2005)

10. Info & Technology Planning • Certified plans required for • Districts getting any (P1 or P2) E-Rate discount for current services (2010-2011) must have an approved plan that expires no earlier than June 30, 2011. • Participation in NCLB II D activities - approved plan will be necessary to apply for a EETT FY11 competitive and/or formula grants in March ’11 (assuming Congressional funding) • E-Rate Central advises all their schools that have 60% or higher discount rate to have an approved plan in case the P2 funding dips that low. (That would imply that they will encourage them to apply for P2 in the upcoming round)

11. Info & Technology Planning • DPI encourages continued technology planning even though you may not need a certified plan • Tie into district goals. Strategic plan or school goals or school improvement plan • DPI will continue to approve technology plans… and will be working on a digital reporting mechanism in collaboration with districts… a Google Docs Template???? Want to give DPI technology planning input? http://tinyurl.com/techplanwi

12. CIPA/NCIPA Compliance (Children's Internet Protection Act) • Compliance with CIPA required for: • Internet access • Internal connections • But not telecommunications • CIPA requires filtering and having an Internet Safety Plan • New law requires Internet safety policy to include educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response. See DPI’s CIPA FAQ at: http://dpi.wi.gov/pld/cipafaq.html

13. E-Rate Flowchart* (Part 1) Tech Plan before 470 (P2) Form 470 posted RNL Dec/Jan Select vendor, cost main factor. If no bids, applicant selects provider. Wait 28Days Pick vendor, sign contract RAL Submit 471 Feb *See also the SLD’s flowchart

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

15. Forms and Deadlines

16. Form 470 • Block 1: Applicants address and ID info • Block 2: Summary of the services being requested • Telecom • Internet • Internal connections • Block 3: Technology resources • Block 4: Entities that will receive the services • Block 5: Certifications and signature

17. Form 470 • 470 begins bidding process, must be filed for 2011 • If you have no contract for the requested services • Often tariffed or monthly telco or Internet service • If you have contract but it expires before July 1, 2011 • File 470 once for length of multi-year contracts or contracts with voluntary extensions • 470 and any RFP must indicate this • Check 7a and b and both options under b • In out years on the 471, site the original 470 • Be sure to file for correct category of service

18. Form 470 155 WI 470s have already been filed. • Can file the 470 now for 2011 • New form likely early Jan • File one 470 for all services, or file separate forms for each service • 470 must be posted on SLD website for at least 28 days before you select a provider or sign a contract • See “Form 470” in News Briefs Form 470 drop dead filing date is 28 days before 471 deadline. But do not wait until then!

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

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

21. Check all to keep all options open (gone in rev. form).

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

23. Check these boxes (gone in rev. form).

24. Block 4 information (16c gone in revised form).

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

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

27. Form 471

28. E-rate Form 471 • Provides specific information on services, service providers selected, and contracts and/or agreements, costs, etc. • Provides discount calculation information • Must be filed each funding year • Applicant certifies compliance with all program rules • Must be postmarked or filed online by ??? March XX ??? • Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window • NEW Item 21 attachments may have to be filed by deadline!!!!! (still hoping for change in this).

30. Block 1: Basic contact information

31. Record Your security code!!

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

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

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

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

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

37. Block 5 — Item 21 Attachment • ”You MUST attach a description of the service, including a breakdown of components, costs, manufacturer name, make and model number….” • NEW Item 21 attachments may have to be filed by deadline!!!!! (still hoping for change in this). • Examples are provided in the document “Item 21 Attachments for Form 471” http://www.sl.universalservice.org/reference/Form471item21Attachments.asp 37

38. Block 5: • Enter Amounts. • Add another block 5?

39. Block 6: Certifications Have necessary resources

40. Block 6: Certifications: Tech Plan (P2 Only)

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

42. Block 6:

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

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

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

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

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

48. Program Integrity Assurance (PIA)Application Review • PIA reviews all applications to ensure compliance with rules • Respond within 15 days to requests • Work with service provider if needed • Respond completely to PIA questions, but no more • If needed, ask for more time or for clarification; contact DPI • 10% of FRNs move to “Selective Review” • Check 471 status at 471 Application Status Tool • Applicant has not provided sufficient documentation to determine the eligibility of this item • No documentation was provided for item(s): item 21 attachment.

49. Issues of Waste, Fraud, Abuse • W/F/A still problem in program, mostly caused by • 90% discount, P2, complex program rules • Vendors have been debarred, people are in prison • W/F/A drives many FCC decisions • More certifications • More PIA requests for information • More audits leading to more COMADs • FCC can recoup funds going back 5 years • See SLD Fall 2009 slides on audits • Recent FCC IG questions to WI schools not targeting schools November 2010. U.S. DoJ settles two lawsuits for $16.25 million alleging that Hewlett-Packard Co. violated E-rate competitive bidding rules at the Dallas and Houston School Districts.

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