E-Rate Compliance Training
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E-Rate Compliance Training Board of Education. February 3, 2011. Richard Patton E-Rate Compliance Officer. Agenda. E-Rate Overview E-Rate Application Process and Status Compliance Agreement Board Member Implications Future Needs. E-Rate Overview.

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E-Rate Compliance Training

Board of Education

February 3, 2011

Richard Patton

E-Rate Compliance Officer


  • E-Rate Overview

  • E-Rate Application Process and Status

  • Compliance Agreement

  • Board Member Implications

  • Future Needs

E-Rate Overview

  • Funded through Universal Service fees collected by telecommunications providers

  • FCC provides discounts to schools for:

    • Voice and data telecommunications

    • Internet access

    • Internal connections

    • Basic maintenance

E-Rate Overview

  • Specific criteria must be met:

    • Eligible service

    • Eligible use

    • Eligible location

  • Discounts range from 20% to 90%, depending on poverty level of students

Application Process

  • Prepare technology plan

  • Open competitive bid process

  • Select service provider

  • Determine discount and apply for funds

  • Question-and-answer process

  • Begin service after approval

  • Confirm receipt

  • Pay invoice

Compliance Agreement

  • States specific obligations that apply at least through December 31, 2013

  • Summary of key requirements

    • Establish and distribute E-Rate Policies and Procedures

    • Training of E-Rate Employees/Board Members

    • More-stringent funding preconditions and rules

    • Third-party audits/internal monitoring

    • Certifications

    • Hotline

    • Annual Compliance Report

  • HISD has fulfilled all obligations to date

Compliance Agreement

  • E-Rate Program Employee per the Compliance Agreement is defined as:

    • All HISD officers and employees who are involved in any aspect of the E-Rate Program

    • Contractors (except for service providers that provide E-Rate supported services to HISD), and consultants and other entities/individuals involved on behalf of HISD with the E-Rate Program, including individuals who:

      • Prepare, review, approve, sign, or submit E-Rate applications, technology plans, or other forms related to the E-Rate Program, or

      • Determine whether services are eligible for funding, prepare bids, or communicate or work with E-Rate Service Providers, E-Rate consultants, or USAC.

    • HISD Inspector General staff responsible for auditing and monitoring HISD’s compliance with the terms of this E-Rate Compliance Agreement and with E-Rate Program rules

Compliance Agreement

  • E-Rate Vendors/Service Providers include any external entity or individual involved in any aspect of the HISD E-Rate Program, including but not limited to:

    • Parent company

    • Subsidiary companies

    • Joint ventures

    • Resellers

    • Consultants/contractors of the above entities

    • Board members/officers/owners of the above entities

    • Employees/representatives/salespersons of the above entities

Board Member Implications

  • E-Rate Program Employees and Board Members are prohibited from accepting:

    • Any gifts, meals, entertainment, or any other thing of value from any outside entity (or any consultant or other individual representing such an entity) that provides or seeks to provide goods or services pursuant to the E-Rate Program either directly or through a joint venture or resale arrangement

  • Exception - items of de minimus intrinsic value, such as a single greeting card, basic key chain, or basic pen

  • Appearance of a conflict is as important as a real conflict

  • Potential impact of E-Rate Program violations

Board Member Implications

  • Board Members are prohibited from voting on E-Rate contracts for three years if:

    • Cumulative funds in excess of $500 in campaign contributions in a single calendar year are received from an E-Rate Vendor/Service Provider taken as a whole, or

    • Cumulative funds in excess of $2,000 in the course of any business relationship are received from an E-Rate Vendor/Service Provider taken as a whole.

  • Board Members should allow HISD to research each potential campaign contribution prior to formal acceptance or cashing such funds to evaluate impact to E-Rate Program

Board Member Implications

  • Handouts:

  • E-Rate Vendor List (Vendor Only)

  • E-Rate Vendor List (Sorted by Key Employee)

Future Needs

  • Internet Safety

    • More rigorous requirements expected

    • Evaluate safety of educational devices (Apple)

  • Internal E-Rate Workshops

  • District-wide Technology Plan