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E-Rate for California Intermediate/Advanced Applicants. Agenda. General Info E-rate Technology Planning Discount Calculations Eligible Services Forms 470/471 Procurement/Competitive Bidding Program Compliance and Updates E-rate Gift Rules Post-Commitment Processes Appendices

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Presentation Transcript
agenda

Agenda

General Info

E-rate Technology Planning

Discount Calculations

Eligible Services

Forms 470/471

Procurement/Competitive Bidding

Program Compliance and Updates

E-rate Gift Rules

Post-Commitment Processes

Appendices

California Teleconnect Fund (CTF)

Alternative Discount Mechanisms

Interconnected VoIP

Invoice Reconciliation

Prepare a Form 471

slide3
The role of CA Dept of Ed and State Library

General Information about E-rate

  • 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
slide5
Intermediate/Advanced Presentation

E-Rate Technology Planning

slide7
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 all Erate services applied for, especially priority 2 services, Internal Connections (IC) and Basic Maintenance of Internal Connections (BMIC).
  • Purpose of the Tech Plan
  • Technology Planning
technology plan review
Technology Plan Review
  • FFC rules require an “approved” technology plan when receiving E-rate discounts for priority 2 services (there are 2 types of tech plans that can be used: an EETT or E-rate only).
  • Find your public charter, district or COE Tech Plan status at: http://www.cde.ca.gov/ls/et/rs/techplan.asp
  • *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.
  • Tech Plan must be “written” prior to posting Form 470.
  • 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.
  • Must cover all 12 months of the funding year (July 1 – June 30).
  • 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.
  • Tech plans must include all services (both current and future) for which E-Rate discounts are sought.
  • 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

10. Leverage the technology expertise of your CTAP regional assistance: CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp

4 required elements of a technology plan used for e rate
4 Required Elements of a Technology Plan Used for E-rate
  • Clear statement of goals and realistic strategy for using telecommunications and information technology to improve education or library services.
  • Professional Development strategy to ensure staff understands how to use technologies to improve education or library services
  • Needs Assessment of telecommunication services, hardware, software, and other services that will be needed to improve education/library services
  • Evaluation process to monitor progress towards goals and allows for mid-course corrections in response to new developments as they arise

Budget:No longer required in the tech plan but USAC will likely request this information during PIA or other application reviews. Best practice would be to put a budget with appropriate fund sources highlighted in your E-rate related documentation files.

the two tech plans
The “Two Tech Plans”
  • Enhancing Education Through Technology (EETT):
  • Executive Summary/Introduction
  • Stakeholders
  • Curriculum
  • Professional Development
  • Infrastructure
  • Adult literacy
  • Research
  • Funding and Budget
  • Monitoring/Evaluation
  • http://www.cde.ca.gov/ls/et/ft/eettfortechplans.asp

E-Rate Only Plan:

  • Goals
  • Professional Development
  • Needs Assessment
  • Evaluation Process

Tech Plan Help

www.usac.org/sl/

applicants/step02/

slide11
The final dates to submit your EETT Tech Plan to CTAP for approval are:
    • Cycle A: October 7, 2011
    • Cycle B: December 16, 2011
    • Cycle C: April 13, 2012
  • EETT Tech Plan Cycle Dates
  • Technology Planning
slide12
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])
  • Must include a sufficient level of detail and cover all services (priority 2) for which E-Rate discounts are being sought on the Form 470(s) and subsequent Form 471(s).
  • Must be approved by the start of services (July 1) or the filing of Form 486, whichever is earlier
  • 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
  • Combination E-rate/EETT Tech plans must be submitted to your CTAP region for approval: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp
  • Must include all four required elements (as noted previously) regardless of the type of plan being used (E-rate only or EETT)
  • “Must Do” Reminders
  • Technology Planning
slide13
Service Providers may notact 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, required for priority 2 - internal connections, and basic maintenance
  • Additional reminders
  • Technology Planning
slide14
E-rate Plans: John Vardanega, jvardane@cde.ca.gov, 916-323-2241
  • EETT Plans: Doris Stephen, dstephen@cde.ca.gov, 916-324-9943
  • CTAP: http://www.cde.ca.gov/ls/et/rs/ctapcoordinators.asp
  • CTAP Tech Plan Builder: http://myctap.org/index.php/techplan/tpb
  • Libraries: Rushton Brandis, rushbrandis@library.ca.gov , 916-653-5471
  • Help
  • Technology Planning
slide16
Intermediate/Advanced

Presentation

Discounts

slide17
Calculate the discount rate for each individual school
  • School District average = weighted average of the schools
      • Multiply E-Rate discount by total student population of the school to get weighted product
      • Add all weighted products and divide by total students in school district
  • Discounts are based on schools actually receiving services in the FRN (may not be all schools in the district)
  • Schools/School Districts
  • Calculating Your Discount
slide18
Calculate the total percentage of students eligible for NSLP in the school district in which the building is located
  • Use the urban/rural status of the county or census tract in which the library outlet is located
  • Individual Libraries
  • Calculating Your Discount

Library Systems

  • Calculate the E-Rate discount for each library outlet
  • Calculate the simple average of the library outlets
    • Add discounts for each outlet and divide by total number of outlets
slide19
NIFs on the campus of single school/library and that serve only that entity, get the discount of that school/library Separate entity number necessary only if public right-of-way is crossed
  • NIFs that serve multiple schools/libraries, and without classrooms or public areas, get shared discount for the school district/library system
  • NIFs that serve multiple schools and with classrooms use the snapshot method to get discount
    • Snapshot method: Choose a specific day and determine the NSLP eligibility of the student population that is in class on that day
  • Non-Instructional Facilities (NIFs)
  • Calculating Your Discount
slide20
School under construction
    • Population is known = use that data
    • Population is unknown = use district shared discount
  • Library under construction
    • Same as regular individual library outlet
  • Private/Charter Schools
    • Population is known: use that data
    • Population is unknown: apply for 20% but can amend with actual figures if obtained later
  • New School Construction
  • Calculating Your Discount
slide21
Allow for socio-economic survey to be used to establish reimbursement rate and reduce paperwork for schools
  • Applicant uses approved NSLP eligibility percentage to calculate discount rate
  • Schools submit base-year documentation to support discount rate
  • If extension is granted, applicants can submit extension approval letter to support discount rate
  • Provisions 1, 2, and 3
  • National School Lunch Program
slide22
All Head Start students meet free lunch guidelines under NSLP
  • Head Start entities automatically qualify for 90% discount
    • Home based Head Start is not eligible
  • Head Start
  • National School Lunch Program
slide24
Intermediate/Advanced Presentation

Eligible Services List (ESL)

slide25
Local and long distance service
  • Cellular
  • Digital Transmission Services
  • Etc
  • For more details refer to Beginners Presentation at http://www.k12hsn.org/programs/erate/training_materials.php
  • Telecommunications Services
  • Priority One
slide26
Broadcast “Blast” messaging
  • Monitoring services for 911, E911 or alarm telephone lines
  • Services to ineligible locations
  • End-user devices
    • Cell phone, tablet computers
  • Not Eligible as Telecom Services
  • Priority One
slide27
Two separate categories on the ESL
    • Telecommunications Services can only be provided by an eligible telecommunications carrier
    • Telecommunications* can be provided by non-telecommunications carriers via fiber in whole or in part

*Applies to Dark Fiber

  • Telecommunications Services vs Telecommunications
  • Priority One
slide28
Support for IA includes Internet Service Provider (ISP) fees as well as the conduit to the Internet
  • Other eligible IA services include:
    • E-mail service
    • Wireless Internet access
    • Interconnected VoIP
    • Web hosting
  • Internet Access (IA)
  • Priority One
slide29
Costs for Internet content
    • Subscription services such as monthly charges for on-line magazine subscriptions
  • Internet2 membership dues
  • Web site creation fees
  • Web based curriculum software
  • Software, services or systems used to create or edit Internet content
  • Not eligible as Internet Access
  • Priority One
interconnected voip aka hosted voip
Interconnected VoIP (aka Hosted VoIP)

Defined as a service that

Enables real-time, two-way voice communications.

Requires a broadband connection from the user’s location.

Requires Internet protocol-compatible customer premises equipment (CPE).

Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.

slide31
Priority One Services

May be applied for in either Telecommunications or Internet Access on Form 470.

USAC highly recommends posting in both Telecom and Internet Access.

Interconnected VoIP

slide32
Leased Dark Fiber added as Telecommunications in the FY2011 Eligible Services List
  • Allows for the lease of dark fiber as a priority one service, from any entity
  • On the FCC Form 470, file for both Telecom and Internet Access
  • On the FCC Form 471, select the Telecom box if the dark fiber is provided by a telecom carrier
    • In all other cases, select the Internet Access box
  • Leased Dark Fiber as Priority One
  • Dark Fiber
slide33
Dark fiber must be lit immediately
  • Does NOT allow for unneeded capacity or warehouse dark fiber for future use
  • Maintenance costs of dark fiber and installation costs to hook up the dark fiber are eligible
    • This includes charges for installation within the property line
  • Modulating electronics for leased dark fiber are not eligible
  • Leased Dark Fiber as Priority One
  • Dark Fiber
slide34

Installation costs to hook up the dark fiber is eligible from the eligible entity to the property line

  • Dark Fiber
  • Leased Dark Fiber as Priority One
slide35
Special Construction charges to build out connections from applicants’ facilities to an off-premise fiber network are NOT eligible
  • Dark Fiber as Priority One
  • Dark Fiber
slide36

Installation and Fiber costs between two eligible buildings, not crossing a public right of way are considered Internal Connections

  • Dark Fiber
  • Dark Fiber as Priority Two
slide37
Support for equipment and cabling on-site that transport info to classrooms or public rooms of a library
  • Subject to the Two-in-Five Rule
    • Entities can only receive funding every two out of five years
  • Internal Connections
  • Priority Two
slide39
Support for basic maintenance of eligible internal connections (BMIC) such as:
    • Repair and upkeep of hardware
    • Wire and cable maintenance
    • Basic tech support
    • Configuration Changes
  • Basic Maintenance of Internal Connections
  • Priority Two
  • Agreements or contracts must state the eligible components covered, make, model and location
  • Service must be delivered within the July 1st to June 30th timeframe
  • Two-in-Five Rule does not apply to BMIC
slide40
Standard manufacturer warranties of no more than three years remain eligible.
    • If there is a cost associated with the warranty, then the warranty is not eligible
  • Support for BMIC is limited to actual work performed under the contract
  • BMIC Updated Guidance
  • Priority Two
slide41
Applicants may make estimates based on:
    • Hours per year of maintenance
    • History of needed repairs and upkeep
    • Age of eligible internal connections
  • Applicants using the factors listed above must submit a bona fide request
  • It is not reasonable to estimate an amount that would cover the full cost of every piece of eligible equipment.
  • BMIC Updated Guidance
  • Priority Two
slide42
Flat rate contracts may be eligible however, applicants may only invoice for services actually delivered/work performed.
  • Exceptions that will not require demonstration that work was performed are:
    • Software upgrades and patches
    • Bug fixes and security patches
    • Online and telephone based technical support
  • BMIC Updated Guidance
  • Priority Two
slide43
In general, equipment may not be transferred for money or any other thing of value
  • A no-cost transfer may occur three years or more after the purchase of the equipment to other eligible entities
  • No equipment transfer may occur prior to three years from the purchase, unless the eligible entity is permanently or temporarily closing
  • Equipment transfer rules
  • Equipment Transfers
slide44
Notify USAC
  • Both the closing entity and the recipient must retain records of the transaction
    • Include the reason for the transfer
  • Records must be kept for five years after the date of the transfer
  • Records for equipment >3 years follow the traditional document retention requirements
  • Equipment transfers less than 3 years
  • Equipment Transfers
slide45
As of January 3, 2011, applicants can dispose of obsolete equipment, but no sooner than five years after the date the equipment is installed
  • Resale for payment or other consideration is allowable no sooner than five years after the equipment is installed
  • Resale or disposal is prohibited before the five years have passed.
  • Disposal of Equipment Rules
  • Disposal of Equipment
slide46
Trade-ins of equipment may be permitted if the E-rate funded equipment to be traded in has been installed for five years
    • This limitation does not apply for equipment not funded through E-rate
  • Trade-ins and Exchanges
  • Trade-ins and Exchanges
slide49
Intermediate/Advanced

Presentation

Form 470

form 470 starts competitive bidding
Form 470 – Starts Competitive Bidding
  • Be VERY familiar with eligible services and proper category
  • “Service or Function”
    • MUST provide enough detail to encourage service providers to bid
    • Broaden scope – plan for growth or reduction in number of eligible entities or bandwidth or number of lines
  • Any limiting factors to bidding should be identified unless on RFP
killer gotcha s funding denial
Killer Gotcha’s = Funding DENIAL

Wrong category of service

Forgot to add a service

Said you didn’t have an RFP when you really do have one, and the reverse

slide52
Intermediate/Advanced

Presentation

Competitive Bidding/

Procurement

fair and open competitive bidding is a program requirement

Fair and Open Competitive Bidding is a Program Requirement

Avoid conflicts of interests

  • Independent Consultant vs. Service Provider
  • Applicant vs. Service Provider

Follow and UNDERSTAND the rules – FCC, State and local

  • Board Policy
  • California Public Contract Code
  • Bid Limits/Thresholds: http://www.cde.ca.gov/fg/ac/co/bidthreshold2010.asp
  • Master Contracts

Document the process!!!

slide54
Determine the types of service the applicant will seek on a FCC Form 470/RFP
  • Prepare, assist applicants with filling out the FCC Form 470/RFP
  • Sign, certify and/or submit FCC Form 470
  • Assist or run the competitive bidding process for the applicant, which includes preparing or conducting the bid evaluation and selection process.
  • Service providers CANNOT:
  • Competitive Bidding
slide55
Ask clarifying questions when bids or descriptions are vague or generic
  • Service providers CAN:
  • Competitive Bidding
slide56
Have a relationship with service providers that would unfairly influence the outcome of the competition
  • Furnish service providers with inside competitive information
  • Have ownership interest in a service provider’s company competing for services
  • Violate gifts rules
  • Applicants CANNOT:
  • Competitive Bidding
slide57
Have pre-bidding discussions with potential bidders as long as that doesn’t lead to one bidder having “inside” information
  • Attend product demonstrations
  • Encourage and seek vendors to bid
  • Do research to determine what cost-effective solutions are available
  • Applicants can:
  • Competitive Bidding
slide58
FCC rules refer to RFPs generically but they may have a variety of names (Request for Quotes, Request for Bids)
  • FCC rules do not require RFP but state and local procurement rules may
  • Must be available to bidders for at least 28 days from the posting of whichever is released last, the RFP or the Form 470
  • Retain a copy of the RFP, including evidence of publication date and any solicitation
  • MUST indicate any special requirements and/or disqualification factors
  • FCC Form 470 & RFPs
slide59
Applicants must ensure that they post for the correct category or categories of service (Non-allowable m&c correction.)
  • Sufficient detail in FCC Form 470
    • Cannot provide generic descriptions (e.g., “All eligible telecom services” or “Digital Transmission Services”)
    • Cannot provide laundry lists of products and services
  • Addendums or changes to the RFP may require applicants to re-start the 29 day period when there is a significant change to the original scope of the procurement
  • FCC Form 470 & RFPs
slide60
Setting eligible services requirements
    • Applicants may require service providers to provide services that are compatible with one kind of system over another (e.g., Cisco compatible).
    • Applicants cannot state make and model on FCC Form 470 or RPF, but may state equivalent make & model (e.g., “IBM router 628 or similar functionality”)
    • Applicants should avoid using specific manufacturer’s name to request a service (e.g., Don’t use Kleenex, use tissue instead)
  • Imposing Restrictions
  • FCC Form 470 & RFPs
slide61
Vendor selection criteria should be posted with the RFP
  • Vendor evaluation begins after 29-day waiting period
  • Follow your vendor selection criteria
  • Price of the eligible goods and services must be primary factor overall (the most cost-effective)
  • Other factors, including other price factors, can be considered as well but they cannot be weighted equally or higher than cost of the eligible goods and services
  • Bid Evaluation
  • Vendor Selection
slide62
Sample Bid Evaluation Matrix

Competitive Bidding

slide63
Solution must be cost-effective
  • An existing contract can be used as a bid response to your posted FCC Form 470
    • Post 470, evaluate all bids & existing contract, memorialize your decision if existing contract is selected – BE CAREFUL, A NEW BID MAY BE REQUIRED, EVEN FROM EXISTING VENDOR
  • No bids or one bid (email yourself noting the fact)
  • Retain all vendor selection documentation
    • Winning and losing bids, correspondences, memos, bid evaluation documents, etc.
  • Selecting the Winning Bidder
  • Vendor Selection
avoid sham bidding
Avoid Sham Bidding
  • “I want to stay with my incumbent”
  • Must respond to all legitimate inquiries
    • Bidders can’t just send spam, but you have to talk to bidders, too
    • Providers that are being stonewalled may contact USAC for assistance
  • Cost to transfer to another provider alone is not by itself a good enough reason to stay with incumbent
  • Avoid appearances of a “done deal”
  • Don’t post for something you don’t want
  • If plans change, have a plan to communicate with potential bidders
slide65
Can’t use E-Rate to get free ineligible products and services
  • Must deduct the value of the “free stuff,” discounts, trade-ins, etc., from the pre-discount amount in order get equal comparison between offerings
    • Cost allocation is NOT required when the product/service (e.g., “free” cell phones) is available to the public or a class of subscribers (not just E-Rate)
  • A proportionate cost allocation is required between eligible and ineligible components.
  • Cost of eligible goods and services cannot be inflated to cover the “free” ineligible products and services
  • Free Services
  • Vendor Selection
piggyback clauses and state master contracts smc
Piggyback Clauses and State Master Contracts (SMC)
  • Clause in a contract signed between provider and another entity allowing others to purchase off the same contract
    • Must be permissible under state & local regs
    • The contract or RFP must allow for other entities to be added
    • You must still post your own Form 470, AND conduct your own competitive bid evaluation
    • If applicant proactively looks for “bids” by going to the State Contract, they must compare all available bidders on the SMC
    • Contract Award Date = Date you decided to purchase off State Contract.
slide67
State master contract that was competitively bid and put in place by a State of CA for use by others {city, county government, K-12 public schools, etc.}
  • Awarded by State of CA to AT&T and Verizon
  • Resulting award was four (4) Master Service Agreements (MSAs):
    • MSA 1 – awarded to AT&T
      • Voice, Data & Video Services
    • MSA 1 – awarded to AT&T
      • Long Distance Network Based Services -
    • MSA 3 – awarded to Verizon
      • Internet Protocol (IP) Voice, Data & Video Services
    • MSA 4 – awarded to Verizon
      • Broadband Fixed Wireless Access (BFWA) Data Services -
  • Each MSA is a five-year contract and included an option for two (2) one-year extensions
  • What is CALNET 2?
  • CALNET 2
slide68
State of CA issued CALNET 2 RFP in 2005 for P1 (Telecom & Internet Services).
  • State issued E-rate Form 470 #267290000544188 in conjunction with RFP.
  • CALNET 2 contracts, MSA 1 and 2 awarded to AT&T, signed on 1/30/2007.
  • The current expiration date is now set for January 29, 2014
    • The State exercised the option to extend the CALNET 2 contract by two (2) years
    • The FCC allowed the extension to the original expiration date for E-Rate purposes via a waiver
  • E-Rate Background
  • CALNET 2
slide69
Current AT&T CALNET 2 customers automatically have option to continue receiving services under CALNET 2 through “new” expiration date of 1/29/14.
  • AT&T Customers were NOT REQUIRED to sign any additional documentation to continue receiving existing CALNET 2 services.
    • Note: Requests for new Service Categories and/or requests for new optical services will require new documentation.
  • If non-State customer does not want to continue receiving CALNET 2 services beyond 1/29/12, non-State customer may terminate ATO with no penalty, provided ATO has been in effect for minimum of two yrs.

- If termination occurs within two yrs of execution, early termination fees may apply.

  • Status of CALNET 2
  • CALNET 2
contracts
Contracts

Must be signed AFTER 29 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

READ AND UNDERSTAND THE FINE PRINT!

Allow enough time to take contracts to Board for approval (if required by Board policy)

Be prepared to explain documents that don’t look like a traditional contract.

slide73
Intermediate/Advanced

Presentation

Form 471

form 471 your application for funds

Form 471 – Your Application for Funds

Must be filed every funding year

This is your actual request for funding

This is where you specify…Who, What, Where, When, & How

WHO: Service providers chosen

WHAT: Services being requested

WHERE: Service Delivery locations

WHEN: Dates for services

HOW: Costs for services and terms

slide75

Form 471 – Your Application for Funds

  • Include ALL NIFS that will be receiving discounted services
  • Separate Priority 1 and Priority 2 services on two different Forms 471
  • Separate Recurring from Non-Recurring charges
    • Recurring – Block 5, Question “C”.
    • Non-Recurring – Block 5, Question “H”.
  • Contract expiration date for non-recurring services - September30(coincides with deadline for delivery of services for non-recurring charges)
slide76

Form 471 – Your Application for Funds

  • Priority Two Filing Strategies
    • Create multiple Block 4s to identify different groups of sites.
    • Create multiple Forms 471 for widely varying discounts
      • i.e. – one Form 471 for 70% and one for 90%
form 471 reminders deadly errors
Form 471 RemindersDeadly Errors

DON’T file Priority One and Priority Two funding requests on the same Form 471

DON’T forget to wait at least 29 days after any mandatory processes associated with your competitive bidding before selecting a service provider or signing any contracts

DON’T submit your Form 471 BEFORE signing all related contracts

DON’T forget to CERTIFY your submitted application (whether electronic or paper certification)

item 21 attachment

Item 21 Attachment

MUST be submitted by the end of the Form 471 filing window

Avoid TMI (Too Much Information) Syndrome – PIA will thank you

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)

application review fcdl

Application Review & FCDL

Be Responsive to PIA reviewer

Answer all PIA reviewer questions

Establish a working relationship with PIA reviewer

Request additional time if you need it to respond

When you do receive your FCDL, review it thoroughly

You have 60 days from date of FCDL to submit an appeal if you do not agree with the funding decision(s).

slide82
Intermediate/Advanced

Presentation

Program Updates and Compliance

slide83
5 years from last date to receive service in electronic format or paper
  • Any document from a prior yearthat supports current year must be kept for at least 5 years from last date to receive service
    • E.g., Contract from 2005, used to support FY 2012 recurring service FRNs, must be kept until at least June 30, 2018
  • Applicants & service providers must retain ALL documentation that shows compliance with all FCC rules.
  • Retain Documents to Show Compliance
  • Document Retention
slide84
Consultant authorization such as Letter of Agency

Document Examples, e.g.:

  • Competitive Bidding Documents – include all bids winning and losing
  • Compliance review documents (PIA, TPA, CIPA, Invoice)
  • Invoices, bills, contracts
  • Asset registries, inventory logs
    • NSLP discount documentation (including CON App, etc.)
    • Technology plans in effect for each Funding Yr
    • NOTE:See complete list on USAC website
  • Retain Documents to Show Compliance
  • Document Retention
slide85
Intermediate/Advanced

Presentation

Children’s Internet Protection Act (CIPA)

slide86
SCHOOLS – By July 1, 2012, amend your existing Internet safety policy (if you have not already done so) to provide for the education of minors about appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms, and cyberbullying awareness and response.
  • LIBRARIES – No new requirements.
  • Overall - several existing statutory requirements have been codified and others have been clarified.
  • New requirements under CIPA
  • New for Funding Year 2012
slide87
New requirements come from the Protecting Children in the 21st Century Act, which updated the Children’s Internet Protection Act.
  • Internet safety policies for schools must be updated on or before July 1, 2012 to provide for:
    • The education of minors about appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms
    • Cyberbullying awareness and response
  • Additional Information on New Requirements
  • CIPA - FCC Report and Order
slide88
“Social networking” and “cyberbullying” are not defined, nor are specific procedures or curricula detailed for schools to use in educating students
    • Congress’ intent is that local authorities should make decisions in this area.
    • Resources are available to assist in this process if needed – e.g., OnGuard Online.gov
  • Additional Information on New Requirements
  • CIPA - FCC Report and Order
slide89
Schools do not need to hold a new public meeting or hearing about amendments adopted to meet the new requirements unless required to do so by state or local rules.
  • Forms 486 and 479 will not be amended because the existing language includes a certification of compliance with all statutory requirements.
  • Instructions for these forms will be revised to list the new requirement from the Protecting Children in the 21st Century Act.
  • Additional Information on New Requirements
  • CIPA - FCC Report and Order
slide90
Do not impose additional obligations but codify existing statutory requirements.
  • Simplify the application process by including important definitions.
  • Will not require re-filing forms.
  • Resolutions to the current rules detailed in the Order
  • CIPA – Rule Revisions
slide91
15 Day Rule eliminated (CORRECTIONS ONLY)
    • RNL & RAL corrections can be submitted until the FCDL is issued
  • PIA will ask if this is a ministerial or clerical error
    • Tell us what error occurred
    • Provide a reasonable explanation
    • Documentation may be requested
  • Corrections of Ministerial & Clerical Errors
  • New for Funding Year 2011
slide92
Spelling errors
  • Simple addition, subtraction, multiplication or division errors
  • Transposed letters and/or numbers
  • Misplaced decimal points
  • Failing to enter an item from the source list (e.g., NSLP data, uploading Block 4 data, FRN, etc.)
  • Detailed list of M & C Errors @ http://www.usac.org/_res/documents/sl/pdf/List-of-Correctable-Ministerial-and-Clerical-Errors.pdf
  • M&C Errors Examples – Allowable Corrections
  • New for Funding Year 2011
slide93
Starting with FY 2011 FRNs, Operational SPIN change requests can be approved when there is a legitimate reason to change providers (e.g., breach of contract or the service provider is unable to perform)
  • Operational SPIN changes cannot be approved:
    • to purchase a service or product for a cheaper price or
    • because of preference for a bidder that didn’t participate in or win the competitive bidding process
  • Operational SPIN Changes
  • New for Funding Year 2011
slide94
Operational SPIN Change Request
  • The newly selected vendor must receive the next highest point value in the original bid evaluation if more than one vendor submitted a bid
  • You can select a vendor without conducting another competitive bid if only one bid was received
  • You must state your reason for the request
  • Indicate the new SPIN start date and funding amount and the former SPIN end date and funding amount
  • Operational SPIN Changes (cont’d)
  • New for Funding Year 2011
slide95
Gifts

E-rate Gift Rules

slide96
Solicitation or receipt of gifts by applicants from service providers and potential service providers and vice versa is a competitive bidding violation.
  • Rules apply to everyone participating in the E-rate whether public or private, and whether operating at the local, state or federal level.
  • Must always follow FCC rules. May also need to comply with additional state/local requirements. If those provisions are more stringent than federal requirements, failure to comply with them will be a violation of FCC rules.
  • Gift Rules
  • E-rate Gift Rules
slide97
Gift prohibitions are applicable year-round, not just during the competitive bidding process
  • Prohibition including soliciting and receiving any gift or thing of value from an applicant or a service provider participating in, or seeking to participate in the E-rate.
  • Service providers may not offer or provide any gifts to applicant personnel involved in the E-rate or vice versa.
  • Gift Prohibitions
  • E-rate Gift Rules
slide98
“Modest refreshments not offered as part of a meal, items with little intrinsic value intended for presentation, and items worth $20 or less, including meals, may be offered or provided , and accepted by any individuals or entities subject to this rule, if the value of these items received by any individual does not exceed $50 from one service provider per funding year.” See 47 C.F.R. § 54.503(d)(1).
  • Single source = all employees, officers, representatives, agents, contractors, or directors of the service provider.
  • Gift Rule Exceptions
  • E-rate Gift Rules
slide99
A Service Provider has offered a school district employee lunch at a local sandwich shop three times during the course of the year. The value of the school district employee’s meal is $9 each time. The total value of the gifts is $27. No other gifts are received by this employee from this provider. The meals fall in the $20 per instance and $50 per annum exception and there is no rule violation.
  • Gift Rule Exceptions Examples
  • E-rate Gift Rules
slide100
A library employee and his spouse are invited by a service provider to attend a play, tickets to which have a face value of $30 each. The aggregate market value of the gifts offered on this single occasion is $60, $40 more than the $20 amounts that may be accepted for a single event or presentation. The employee may not accept the gift of the evening of entertainment. He and his spouse may attend the play only if he pays the full $60 value of the two tickets.
  • For more details/examples: http://www.usac.org/_res/documents/sl/pdf/2010_training/Applicant-6th-Order.ppt
  • Gift Rule Exceptions Examples
  • E-rate Gift Rules
slide101
Gifts to family and friends when those gifts are made using personal funds of the donor (without reimbursement from the employer) and are not related to a business transaction or business relationship are exempt. See 47 C.F.R. § 54.503(d)(3).
  • Gift rules are not intended to discourage companies from making charitable contributions, as long as those contributions are not directly or indirectly related to an E-rate procurement. See 47 C.F.R. § 54.503(d)(4).
  • Gift Rule Exceptions
  • E-rate Gift Rules
slide102
A service provider’s spouse is the town librarian. The service provider employee may give the librarian a birthday gift exceeding $20, as long as it is not reimbursed by the company, and is being given based on their personal relationship.
  • Three service provider employees invite a tech director to join them at a golf tournament at their company’s expense. The entry fee is $500 per foursome. The tech director cannot accept the gift even though he has an amicable relationship with the service provider employees. Since the fees are paid by the company, it is the business relationship, not the personal relationship that is the motivation behind the gift.
  • Gift Rule Exceptions Examples
  • E-rate Gift Rules
slide103
Return any tangible item to the donor, or pay the donor its market value, or, if perishable, the item may be given to an appropriate charity or shared within the office or destroyed. See CFR 2635.205(a).
    • To avoid public embarrassment to the seminar sponsor and E-rate service provider, the Superintendent did not decline a barometer worth $200 given at the conclusion of her speech on the district’s education initiatives. The Superintendent must either return the barometer or promptly reimburse the provider $200 to cure the violation.
  • Curing Violations
  • E-rate Gift Rules
slide104
With approval from the recipient’s supervisor, a floral arrangement sent by a service provider may be placed in the office’s reception area.
  • A district employee wishes to attend a charitable event to which he has been offered a $300 ticket by a service provider. Although his attendance is not in the interest of the district, he may attend if he promptly reimburses the donor the $300 face value of the ticket.
  • Curing Violations Examples
  • E-rate Gift Rules
slide105
Gift rules are not intended to discourage charitable donations as long as the donations:
    • Are not directly or indirectly related to E-rate procurement activities or decisions, and
    • Are not given with the intention of circumventing competitive bidding or other FCC rules
  • Charitable Contributions
  • Charitable Donations
slide106
Paid-for-exchange services at market rates, such as the purchase of advertising space, is neither a gift nor a charitable donation as long as it is not intended to influence the competitive bidding process.
    • For example, service providers purchasing advertising space on the high school football score board, for which they pay market rates, would not cause any violations.
  • Allowable Charitable Contributions
  • Charitable Donations
slide107
Equipment, including laptops and cell phones, may be permissible if it benefits the school or library as a whole and broadly serves an educational purpose.
    • Gifts of equipment that increase demand for a donor’s services, and thus cause the applicant to purchase more of a provider’s services, are prohibited.
      • Example: Service provider donates computers, causing a need for more Internet Access, which the provider sells to the library
  • Questionable Charitable Contributions
  • Charitable Donations
slide108
Cash, equipment, including sporting, musical or playground equipment, may be permissible if they benefit the school or library as a whole and broadly serve an educational purpose.
    • For example, a donation of books for a literacy campaign, given to a school by an E-rate service provider, would be acceptable donation that benefits the school and broadly serves an educational purpose.
  • PotentiallyAllowable Charitable Contributions
  • Charitable Donations
slide109
Service providers cannot offer special equipment discounts or equipment with service arrangements to E-rate recipients that are not currently available to some other class of subscribers or segment of the public.
    • Free phone/tablet with purchase of service contract must be available to non-E-rate customers as well
  • Donations to cover the applicant’s non-discount share
  • Unallowable Charitable Contributions
  • Charitable Donations
slide110
Travel expenses such as airfare, meals, lodging, etc. unless the meal falls below the $20/$50 thresholds.
  • Example:
    • A service provider offers to pick up the travel and lodging costs for an applicant to attend a customer appreciation event in another state. This gift is not allowable under the gift rules.
  • Unallowable Charitable Contributions
  • Charitable Donations
slide111
Equipment for a specific individual or group of individuals associated with or employed by an E-rate participant.
    • Service provider may not give a gift to a teacher who helps draft a district’s technology plan, even if that teacher does not ultimately help select the E-rate service provider.
  • Unallowable Charitable Contributions
  • Charitable Donations
slide112
Raffle tickets, prizes, or door prizes that have a retail value of over $20 violate the gift rules unless the event is open to the public.
    • “Open to the Public” means the event is free of charge and that members of the public at large typically attend such a gathering.
      • State Fair would qualify
      • State District IT Directors meeting would not qualify
  • Prizes
  • Conferences and Training Sessions
slide113
“Widely attended events” are exempt from gift rules. See 5 C.F.R. § 2635.203(g)
    • Gathering is widely attended if:
      • Employee’s attendance must be in the interest of the agency (i.e. school or library) and further its programs and operations, and
      • It is expected that a large number of persons will attend, and
      • Persons with a diversity of views or interests will be present.
    • Event is open to members from throughout the interested industry or professional or those in attendance represent a range of persons interested in a given matter.
  • Widely Attended Events
  • Conferences and Training Sessions
slide114
Food, refreshments, instruction and documents given to all attendees at Widely Attended Events are permissible.
  • Trainings offered by state, regional or local government bodies or non-profits or trade associations that include those bodies are not considered vendor promotional training
    • Vendor promotional training means training provided by any person for the purpose of promoting its products or services. See 5 C.F.R. § 2635.203(g)
  • Conferences – Permissible Actions
  • Conferences and Training Sessions
slide115
Service providers can host, sponsor, or conduct E-rate training, as long as they do not provide any gift that exceeds the gift exceptions
    • Service providers cannot provide demonstrations or help with preparation or completion of forms, or determining the services listed on the Form 470 and/or RFP.
  • Conferences – Permissible Actions
  • Conferences and Training Sessions
slide116
Training or conference regarding one or few vendors services would not meet the definition of a Widely Attended Event even if many people attended.
    • Travel expenses, lodging, meals, and entertainment associated with the event would be considered gifts and therefore violations.
    • Free attendance, when it would otherwise cost to attend, is also a violation.
  • Conferences – Impermissible Actions
  • Conferences and Training Sessions
slide117
Service providers can offer an “educational discount” on the attendance fee to a Widely Attended Event as long as it is available to all employees of schools and libraries.
  • Applicants cannot accept free attendance, paid by a service provider, even if the school or library has assigned the employee to attend the event.
  • A Service provider cannot pay for or reimburse expenses for an applicant to speak at a conference on behalf of that service provider, or in any other setting, e.g. newspaper or magazine.
  • Conferences – Registration Fees
  • Conferences and Training Sessions
slide118
Employees who are required by law to sit on the governing board of a governmental agency that acts as a service provider do not violate the gift rules when they accept meals or travel expenses required to execute their official position and duties on that board.
  • Service providers may sit on a school’s fundraising board, as long as that does not unduly influence the competitive bidding process or provide them with inside information.
  • Board Membership
  • Representation on Boards
slide119
Requirement for fair and open competitive bidding has always been in effect.
  • Rules from 6th Report and Order went into effect January 3, 2011.
  • New applicants, or applicants that are applying for the first time for a category of service, must be in compliance with rules six months prior to the posting of their first FCC Form 470.
  • Dollar limits of $20/$50 are calculated per funding year
  • Timelines for Compliance
  • Timing
slide121
Intermediate/Advanced

Presentation

Post-Commitment Processes

form 486 review

Form 486 Review

Notifies USAC that services started or are scheduled to start and invoices can be paid

Applicant makes additional program certifications

Filed AFTER receipt of FCDL

Form 486 must be filed online or postmarked, no later than

120 days after Service Start Date

OR

120 days after FCDL date

Whichever is later

when will i get
WHEN will I get $$?
  • E-rate is a discount program
    • Funding is based on a discount on actual costs incurred not on total funded amount
    • District must experience costs before disbursements of funding are made
  • FCDL Date
    • Can be months to over a year after the start of the E-rate/fiscal year – Plan for it!
  • Form 486
    • Must be filed before any disbursements can be made
  • Invoice Deadline
    • October 28 after close of funding year for recurring services
    • January 27 after close of funding year for non-recurring services
    • Invoice Deadline Extensions are available
how will i get it
HOW will I get it?
  • It’s a long and complicated journey…
  • $$ always flows through the service provider – never directly to applicant
  • FCDL -> Form 486 -> Carrier Forms -> SPI or BEAR -> Invoice Reconciliation
  • Carrier Forms, including:
    • Grids, certifications, and data gathering forms
    • MUST be filed before the service providers will process discounts
    • TIP: Get to know the SPIN contact
how will i get it cont d
HOW will I get it? (Cont’d)
  • SPI or BEAR?
  • SPI (Service Provider Invoice) Form 474
    • Service provider invoices USAC directly for E-rate discounted amount
    • Applicant pays its share after discount (in a perfect world)
    • Required for CTF discounted services
    • Complications: timing of FCDL and posting of discounts, verification of receipt of discounts
  • BEAR (Billed Entity Application Reimbursement) Form 472
    • Prepared by applicant – applicant is responsible for calculations
    • Full costs incurred by applicant
    • E-rate funds disbursed in a check (check issued by SP)
when will i get it cont d
WHEN will I get it? (Cont’d)
  • After FCDL issued by SLD
  • After Applicant has submitted Form 486
  • After Applicant has submitted Service Provider required paperwork
  • After Service provider has processed paperwork
  • THEN:
    • If E-rate discounts are credits on the bill, it may take 2-3 bill cycles for those credits to actually be realized
    • If BEAR is filed, applicants will receive a check from Service Provider approximately four – six weeks from the time it is submitted.
did i get it
DID I get it???!!!
  • BEAR Method
    • Check received by district = full closure
    • Make sure to retain documentation on how BEAR calculations were made
  • SPI Method
    • Requires alert and methodical accounting
    • Reconciliation of bills required in order to verify if discounts are received
    • Discounts often overlap funding years – it’s a TRUE challenge!
    • Do not assume that SP calculations are correct!
deadlines extensions
Deadlines/Extensions

Invoice Deadline Extension

Must be filed in order to collect funds after invoice deadline has passed (October 28)

Implementation Deadline Extension (a.k.a. Service Delivery Deadline)

Must be filed if non-recurring services will be installed after September 29 deadline

If a service delivery extension occurs, your contract may need to be extended

(HINT: Set contracts for non-recurring services to expire September 30)

Applicants must extend the contract AND file a Form 500 to extend the contract expiration date in USAC’s records before an invoice dated after that date can be paid

slide133
An Invoice Deadline Extension request must be submitted to USAC
  • There is no official “form”, but there is a format & criteria for request(s)
  • Typically, request is submitted by applicant to USAC.
  • Format for request @ http://www.usac.org/sl/applicants/step11/invoice-deadlines-extension-requests.aspx
  • What if the Invoice deadline was missed?
  • Invoice Deadline
slide135
Intermediate/Advanced

Presentation

Form 500

slide136
To request one or more of the following changes to a Funding Request Number (FRN) to:
    • Change service start date on the FRN;
    • Change contract expiration date on the FRN;
    • Reduce funding amount on the FRN;
    • Cancel the FRN
  • NOTE: Once you submit a Form 500 to reduce or cancel the funding amount, it is irreversible.
  • To request adjustment to Funding Commitment $ and/or modify Receipt of Service Confirmation:
  • Form 500
slide137
Intermediate/Advanced

Presentation

Service Substitutions

slide138
Substitution of a service or product must meet the following conditions:
  • Substituted services or products have same functionality as services or products contained in original proposal.
  • Substitution does not violate any contract provisions or state or local procurement laws.
  • Substitution does not result in an increase in percentage of ineligible services or functions.
  • Requested change is within the scope of controlling FCC Form 470, including any Requests for Proposal, for the original service.

For details: http://www.universalservice.org/sl/about/changes-corrections/service-substitutions/

  • To request change in products and/or services specified in Form 471
  • Service Substitutions
slide140
Pre-commitment SPIN changes:
    • Corrective SPIN changes only (i.e., data entry errors).
    • Post-commitment SPIN changes: (as referenced previously in this presentation) 6th Report & Order restricted Operational SPIN changes as follows:
    • Operational SPIN changes must have legitimate reason to change, such as breach of contract or provider unable to perform, and
    • must select provider with the next highest point value in evaluation.

For more details: http://www.usac.org/sl/about/changes-corrections/spin-change-guidance.aspx

  • SPIN changes: Operational vs. Corrective
  • SPIN Changes
slide142
Primary purposes of audits: to ensure compliance with FCC rules and program requirements and to assist in prevention and detection of waste, fraud, & abuse
  • If you cannot prove that you followed the rules, then it will be assumed that you DIDNOT follow the rules.
    • The consequences of negative findings by an auditor can mean payback by the School/District/Library of E-rate monies… or worse.
  • Purpose of E-rate audits
  • Audits
slide143
Primary purposes of audits: to ensure compliance with FCC rules and program requirements and to assist in prevention and detection of waste, fraud, & abuse
  • If you cannot prove that you followed the rules, then it will be assumed that you DIDNOT follow the rules.
    • The consequences of negative findings by an auditor can mean payback by the School/District/Library of E-rate monies… or worse.
  • Purpose of E-rate audits
  • Audits
slide144
Primary purposes of audits: to ensure compliance with FCC rules and program requirements and to assist in prevention and detection of waste, fraud, & abuse
  • If you cannot prove that you followed the rules, then it will be assumed that you DIDNOT follow the rules.
    • The consequences of negative findings by an auditor can mean payback by the School/District/Library of E-rate monies… or worse.
  • Purpose of E-rate audits
  • Audits
slide145
E-rate audits will vary, e.g., BCAP, PQA, etc.
  • The best way to prepare for an audit is to:
    • Know and follow the program rules
    • DOCUMENT EVERYTHING and SAVE DOCUMENTATION IN ORGANIZED WAY
      • You can’t prove that the School, District, and/or Library abided by the rules if you don’t document your processes and retain supporting documents.
      • Organize your supporting documentation so that ….auditors and/or your successor(s)… can trace what you did to demonstrate that you followed all E-rate program rules.
  • EXPECT TO BE AUDITED
  • Audits
slide146
Plan ahead for an audit or review by documenting every step of the process as the work is done.

e.g., document how you conducted competitive bidding; save copies of any RFPs issued in conjunction with any Form 470s, save copies of your bid evaluation matrix and scoring of bidders, etc.

  • Create and maintain ORGANIZEDE-Rate binders for EACH funding year
  • Retain – Retain – Retain – Lessen your pain!! Retain ALL E-rate related documents
  • Contact service providers for assistance when appropriate
  • USAC Compliance Documentation Checklist for audits
    • http://www.usac.org/_res/documents/sl/pdf/CompDocChecklist.pdf
  • PREPARING FOR AUDITS
  • Audits
slide147
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
      • CIPA Compliance and Competitive Bidding Selective Reviews
  • Other Levels of Scrutiny
  • Audits
slide148
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 document retention requirements for E-Rate
    • E.g., food services data, surveys, etc., in support of NSLP participation
  • Align Board policies with E-rate requirements
  • Per 5th Report and Order: if applicant can’t prove compliance with rules through documentation, they must assume that you didn’t follow the rules
  • No documentation = Recovery of Funds

(Applicant may have to pay back USAC for E-rate monies they already received)

  • Document Retention Requirements
  • Always Be Prepared for Audits
who to contact
Who to Contact?

State Library: Rushton Brandis,

(916) 653-5471 rushbrandis@library.ca.gov

CDE/E-rate: John Vardanega,

(916) 323-2241

jvardane@cde.ca.gov

CDE/EETT: Tech Plans: Doris Stephen,

916-324-9943

dstephen@cde.ca.gov

K-12 HSN/Butte COE: Russ Selken

530-532-5678

rselken@bcoe.org

slide151
Intermediate/Advanced Presentation

California Teleconnect Fund (CTF)

california teleconnect fund overview
California Teleconnect Fund Overview

The California Public Utilities Commission (CPUC) established the California Teleconnect Fund (CTF) in 1996 and is solely funded through an all end-user surcharge placed on all intrastate telecommunications services in California.

The CTF program 50% discount on selected telecommunications services to qualifying K-12 schools, community colleges, libraries, government-owned and operated hospitals and health clinics, non-profit community based organizations, California Telehealth Network Consortium. 

Program website:

http://www.cpuc.ca.gov/PUC/Telco/Public+Programs/CTF/

who is eligible for ctf
Who is Eligible for CTF?

Schools:Public or nonprofit private schools that provide elementary or secondary education and that have endowments under $50 million.

Libraries:Libraries eligible to participate in state-based plans for funds under Title III of the Library Services and Technology Act.

who is eligible for ctf continued
Who is Eligible for CTF (continued)

Hospitals and health clinics that are owned and operated by a municipal, county government, or a hospital district.

Community based organizations (CBOs):

must be a tax-exempt organization as described in Section 501 (c)(3) or 501 (d) of the Internal Revenue Code, Title 26 of the United States Code and must also have a Form 990.  

Second, they must offer health care, job training, job placement, 2-1-1 referral services and information (approved by the Commission), educational instruction, or a community technology program offering access to and training in the Internet and other technologies.

California Community Colleges

California Telehealth Network Consortium

qualified organizations may receive 50 discount on the following telecommunications services
Qualified organizations may receive 50% discount on the following telecommunications services

Measured Business service

Centrex, PBX Trunks

ISDN service

DS1 service

DS3 service

Up to and including OC-192 services, or their functional equivalents

Internet access services, with certain exceptions, as defined under the FCC’s website

Multi-Protocol Label Switching

Service Providers may use different terminology to “name” their CTF-eligible services. Contact the applicable Service Provider for more details which billing components and named services are eligible for CTF discounts.

Not all billing elements associated with the above named services may be eligible for CTF discounts, e.g., usage is not eligible, federal taxes and surcharges not eligible, etc.

internet services eligible for ctf effective 12 1 2008
Internet Services eligible for CTF, Effective 12/1/2008:

The definition of Internet Access is the same as that used by the FCC.

Internet definition can be found @ http://fjallfoss.fcc.gov/edocs_public/attachmatch/FCC-08-265A2.pdf

Eligible Internet Services include:

landline; and

satellite/wireless Internet access, including cellular data plans and laptop cards

Service Providers may use different terminology to “name” their CTF-eligible services. Contact the applicable Service Provider for more details which billing components and named services are eligible for CTF discounts.

Not all billing elements associated with the above named services may be eligible for CTF discounts.

sb1102 impact on participating schools and libraries
SB1102 IMPACT ON PARTICIPATING SCHOOLS AND LIBRARIES

CTF service providers are required to apply the California statewide average E-rate percentage before calculating the CTF discount (this calculation only reduces customer’s eligible dollar amount considered for CTF discounts; it does not provide the customer an E-rate discount) on eligible services, where applicable.

“NEW “ (effective 7/1/12)….Community based organizations (CBOs) that offer Head Start programs will see CTF discounts stacked, just as with schools and libraries

services that are ineligible for e rate but eligible for ctf
Services that are Ineligible for E-rate, but eligible for CTF

If an applicant is a public or private school or public library, eligible to receive E-rate discounts, but subscribe to telecommunications services that are ineligible E-rate discounts, those services will not be affected by SB1102.  

CTF applicant is required to provide documentation to their carrier identifying each CTF service/circuit ID and the reason why they are ineligible for E-rate discounts.

Contact your carrier to inquire what paperwork they require to accommodate for these situations.

E.g., currently, data plans for wireless are only eligible for E-rate if used on campus. Off campus usage is not currently eligible. If school or library is not applying for E-rate for the data plans or is cost allocating only for a portion of the off campus usage & is applying for CTF for the card, customer must submit CTF Eligible/E-rate Ineligible Services form (annually) to receive 50% discount CTF discounts without stacking.

who to contact160
Who to Contact?

State Library: Rushton Brandis,

(916) 653-5471 rushbrandis@library.ca.gov

CDE/E-rate: John Vardanega,

(916) 323-2241

jvardane@cde.ca.gov

CDE/EETT: Tech Plans: Doris Stephen,

916-324-9943

dstephen@cde.ca.gov

K-12 HSN/Butte COE: Russ Selken

530-532-5678

rselken@bcoe.org

slide161
Intermediate/Advanced Presentation

Alternative Discount Mechanisms

slide162
NSLP eligibility based on student’s family being at or below 185% of federal poverty levels
  • Income Eligibility Guidelines (IEG) published annually by U.S. Department of Agriculture
  • Other alternative discount methodologies seek to determine if a student meets the NSLP IEG threshold
  • Alternative Discount Mechanisms
  • Alternative Discount Mechanisms
slide163
Programs that meet the IEG threshold for the NSLP:
    • Medicaid
    • Food stamps (SNAP)
    • Supplementary Security Income (SSI)
    • Section 8 Housing Assistance
    • Low Income Home Energy Assistance Program (LIHEAP)
    • Food Distribution Program on Indian Reservations
  • Acceptable Mechanisms
  • Alternative Discount Mechanisms

Unacceptable Mechanisms

  • Programs that do not meet the IEG threshold for the NSLP:
    • Temporary Aid to Needy Families (TANF)
    • Title 1
    • Scholarship programs
slide164
If school can establish that one sibling in a family is eligible for NSLP, then it can count the other siblings in the same family as eligible for NSLP even if the other siblings do not participate .
  • Sibling Match
  • Alternative Discount Mechanisms
slide165
Must be sent to all families whose children attend the school
  • Surveys must contain at least student and family name, size of family, income level of family or acceptable alternative mechanism
  • Surveys are valid for two years
  • NSLP application forms are never anacceptable survey instrument
  • Surveys
  • Alternative Discount Methods
slide166
If a survey is sent to all households of its students, and
  • If at least 50% of surveys are returned
  • School may extrapolate the data to 100% of its students
  • Example:
    • 100 families received the survey; 75 returned them
    • 25 of the 75 families are eligible for NSLP
    • 25/75 = 0.33
    • School can report 33% of all students are eligible
  • Survey Extrapolation
  • Alternative Discount Methods
slide167
Ensure that the same students are not double counted.
  • Surveys cannot be combined with other alternative discount methods if you have extrapolated
  • Provisions 1-4 cannot be combined with other alternative discount methods since they include extrapolation
  • Keep detailed records to show that the same students were not double counted
  • Combining Alternative Discount Methods
  • Alternative Discount Methods
slide168
Feeder School Method
    • Extrapolating from elementary to secondary schools
  • Principal’s Survey/Estimate
    • Based on administrators’ knowledge of some of their students
  • Title I eligibility
  • Neighborhood poverty measurements
  • Ineligible Discount Calculation Methods
  • Alternative Discount Methods
slide169
Intermediate/Advanced Presentation

Interconnected VoIP

(Hosted; Priority 1)

slide170
Leased VoIP or PBX equipment are NOT eligible for Priority One funding.

By removing the VoIP or PBX equipment, the local voice network will cease to function. This equipment is eligible ONLY as Internal Connections.

Interconnected VoIP

slide171

Interconnected VoIP

A gateway may be leased with eligible Priority One VoIP service.

A gateway is considered a single basic terminating device.

slide172

Interconnected VoIP

A multipurpose leased router may be eligible for Priority One funding if, as seen in this example, the internal data and voice network functions without dependence on the leased router.