E-rate 102: Completing form 470

Report
FUNDING YEAR 2012:
COMPLETING FORM 470
Funding Year 2012:
July 1, 2012-June 30, 2013
2012-13 School Year
Topics for today’s session
1.
2.
3.
4.
5.
What are some helpful resources?
What is the purpose of form 470?
Form 470: Common errors made in filing
What’s new with the E-rate program in 2012?
Form 470: We’ll walk through the online
form
Numbers to remember
• SLD Client Service Bureau
– 1-888-203-8100
• Pam Jacobs (schools and districts)
– 515-975-0071
– [email protected]
• Jay Peterson (public libraries)
– 515-281-4499
– [email protected]
Online resources
• Actual online filing:
www.sl.universalservice.org/menu.asp
• Funding commitments/disbursements:
www.e-ratecentral.com
• Iowa E-rate information
www.iptv.org/iowa_database/erate
What is the purpose of form
470?
What is the purpose of form 470?
• To open the competitive bidding process for
the E-rate services you seek.
• This form is required prior to filing form 471.
• There is a required 28-day “waiting period”
between form 470 filing and 471 filing.
E-rate Timelines
1. Complete an E-rate tech plan (required if applying
for priority 2; not required if only filing for priority
1)
2. Form 470 (File any time between now until early
December)
3. Wait at least 28 days after filing form 470
4. Select provider and sign contract (if applicable)
5. Form 471 (deadline is likely early March 2012).
Form 471 is often called “the application”
6. Answer questions/call from PIA (March-?)
7. Funding commitment decision letter
8. Form 486
9. No discounts on bills? File form 472/BEAR form
4-pronged test for Eligibility
Requirements for eligibility:
– Must be an eligible product or service
– Used by an eligible entity
– Used at an eligible location
– Used for an eligible purpose
Do I file form 470 every year?
Question:
Do I have to file a form 470 every year?
Answer:
Yes, if you are applying for month-to-month services,
you must file form 470 every year.
Yes, if you want to sign a new contract, you must file a
form 470.
No, if you have an existing multi-year contract that
meets certain conditions (more info is provided later
in this presentation)
Form 470: How many separate 470
forms to file?
Your choice!
• You may file one form 470
OR
• You may file a separate form 470 for each type
of service
• Recommendation: If you are applying for
internal connections or basic maintenance, file
a separate form 470 for these priority 2
services
Common Errors in filing form 470
Form 470: Common errors made in
filing
Error 1: Applicants don’t wait
the full 28 days before
choosing a service provider or
signing a new contract
FIX: Wait at least 28 days!
Form 470: Common errors made
in filing
• Error 2: Applicants do not properly keep
records of their bid evaluation process.
• Fix: (See the following slide for guidance).
Bid evaluation process
SLD is getting more particular about
documenting a fair and open bidding process
1. Have a written process for evaluating bids and criteria for
selection prior to selecting your provider and signing a
contract.
2. Keep a record of bids received!!! (not just the winning bid).
3. Complete your bid evaluation document, even if you just
received one bid.
4. Date the completed bid evaluation document to show you
waited at least 28 days to make your vendor selection.
Must I accept the lowest bid?
• No, not according to e-rate rules…but cost must be
the primary consideration
• Other factors might be prior experience of vendor,
qualification of personnel, financial stability of the
company, service that meets the needs of your
school/library, in-state preference
• For sample bid document, see
http://www.usac.org/_res/documents/sl/pdf/2007_t
raining/samples-checklist-vendor-selectiontemplates.pdf
May we sign a contract?
• Yes, but only after the “allowable
contract date” of 28 days
• Include contingency language in case you
don’t get funded, especially for internal
connections
What if we already have a contract for 1213 school year?
• Did you already file form 470 in a previous
year “establishing” this contract? (If you’re not
sure your 470 qualifies to “establish” a multi-year contract,
contact me and I’ll check it over with you).
• Does the contract cover ALL of 12-13 school
year?
• If both above statements are true, you do not
need to file form 470 for this service. You will
have to file form 471 in order to get funding.
Form 470: Common errors made in
filing
Error 3: Not enough quantity and/or capacity
requested for telecommunications services
and/or Internet
FIX: Don’t limit your capacity. Use words like
“no less than 8 cellular phone lines” or
“minimum of 3 mps”. Avoid using words like
“8 phone lines.”
Cellular data services
• Very important:
If you are filing for cellular data services (e.g.
Smartphone-type services or wireless
“card” service), indicate this on form 470 in
two places: Telecom services and Internet
services
• When you get to form 471, you will select only one of
the above types of service
Form 470: Common errors made in
filing
Error 4: Form 471 requests services not listed on
form 470 (forgot some services on form 470)
FIX: You may file more than one form 470 (but
must wait 28 days before selecting a service
provider and signing a contract)
Question
• What about companies that offer bundled services?
(such as phone service and Internet in one package)
• How do I fill out form 470? (which category of
service?)
– Answer: Internet may be provided by a either a
telecommunications provider or non-telecommunications
provider. If you’re considering bundled service across 2
categories, you must state on form 470 under telecomm
services category that you will consider bids bundled with
Internet service. Also repeat the same description under
the Internet category too.
Question?
• What if I put a service in the wrong
category? (e.g. put “local phone
service” as Internet?)
– Answer: May result in NO FUNDING!
If in doubt, list under 2 categories on
form 470 (e.g. telecomm services and
Internet)
Question?
• What about the section of the eligible
services list that isn’t category specific?
– Answer: To date, telecomm and Internet
are leased services. Internal connections
MAY be purchased goods and services.
What’s new for E-rate funding
year 2012?
What’s new with E-rate for funding
year 2012?
New item 1: CIPA (applies only to
districts/schools/AEAs)
By July 1, 2012, amend your Internet safety policy (if
you haven’t done so) to provide for monitoring of
online activities of minors and the education of
minors in appropriate online behavior, including
interacting with other individuals on social
networking sites and in chat rooms, cyberbullying
awareness and response.
CIPA changes
Your school/district/AEA is not required to have
a new public notice and hearing for this policy
change (assuming you have record of previous
action)
If you don’t have a record of the public notice
and hearing for the original establishment of
the Internet safety policy, it is recommended
that you refresh the record by posting public
notice and holding a public hearing.
CIPA reminders
CIPA reminders: The following are already
required if requesting discounts on Internet
and/or internal connections:
1. Internet safety policy
2. Public notice of – and public meeting or
hearing on – the Internet safety policy
3. Technology protection measure (filter)
CIPA reminders
Your school/district/AEA does not have to buy
an Internet safety student curriculum!
There are plenty of great/free online resources.
See http://onguardonline.gov
Also see Common Sense Media (requires free online
registration):
www.commonsensemedia.org/educators/curriculum
www.commonsense.com/internet-safety-guide/
www.commonsense.org/cyberbullying-toolkit
www.thinkfinity.org/common-sense-media
CIPA reminders
Local school and library authorities must
determine what matter is inappropriate for
minors.
Social networking sites are not automatically
considered harmful to minors.
Put into local policy how your school or library
locally interprets the requirements and make
sure your implementation aligns with the
policy. (Do what you say you’re going to do).
CIPA reminders
The following is not yet determined by FCC.
Public comment likely to be sought on the
following type of question:
Do CIPA requirements apply to the use of
portable devices owned by students and
library patrons when those devices are used in
a school or library to obtain Internet access
funded by E-rate?
CIPA reminders
Keep some sort of documentation to show
filtering/technology protection measure is in
place (e.g. bill from vendor of filtering
software; sample of a couple computer logs
showing filtering, etc.)
(Schools/districts/AEAs only): Keep some sort of
documentation that the education of minors
occurs (e.g. copy of the curriculum used;
sample lesson plan from teachers, etc.)
CIPA resources
For a detailed discussion of CIPA requirements:
Children’s Internet Protection Act website guidance
Form 486 Instructions
Form 479 Instructions
For more details on CIPA, see recent USAC training
slides at http://www.usac.org/sl/about/trainingsessions/training2011/fall/presentations.aspx#presentations
What’s new for E-rate funding year
2012?
New item 2: Have the deadlines been set?
No, the deadlines are not yet set.
However…..
• USAC predicts the 471 “window” will open in early
January and close in early-mid March.
• To meet the 28-day waiting period between filing
form 470 and filing form 471, it is recommended that
you file form 470 no later than early December.
What’s new with E-rate for the 2012
funding year?
New item 3: Eligible Services List
http://transition.fcc.gov/Daily_Release
s/Daily_Business/2011/db0928/DA11-1600A2.pdf
Eligible services for funding year
2012
If you want more examples and updated details
on eligible services, take a look at the USAC
training slides on eligible services, especially:
• Basic maintenance of internal connections
• Leased dark fiber as priority 1 service
http://www.usac.org/sl/about/trainingsessions/training2011/fall/presentations.aspx#presentations
What’s new for E-rate funding year
2012?
Item 4: Further clarification on gift rules
See the following for more details
• FCC Rules - 47 C.F.R. § 54.503(d)
• Federal Gift Rules - 5 C.F.R. § 2635.201-205
• FCC Sixth Report and Order - 25 FCC Rcd 18762 (2010)
• FCC Clarification Order - 25 FCC Rcd 17324 (2010)
Gift Rules
• Gift rules apply to everyone participating in
the E-rate program, whether public or private,
and whether operating at the local or regional
level
• Gift prohibitions are applicable year-round,
not just during the competitive bidding
process
Gift Rules
• Gifts or prizes received at conferences are
exempt from the gift rules only when such
conferences are open to the public (for free)
or meet narrowly-defined conditions as
“widely attended events.”
•
E-rate applicants who are not yet concerned about the gift rules might do well to
reflect on a recent FCC filing on behalf of the East Central Board of Cooperative
Educational Services (“ECBOCES”) which included the following point: ECBOCES
believes that it is because ECBOCES employees accepted gratuities that total no
more than $674 over a five-year period, USAC rescinded funding for FY2006,
FY2007 and FY2008, and denied funding for FY2009 and FY2010 in the aggregate
amount of $3,370,018.77.
Gift Rules
• USAC has requested gift clarification from the
FCC about several items, including what
constitutes a “widely attended event.”
• See USAC slides for examples about gifts,
especially the slides on charitable donations
and conferences and training sessions.
– http://www.usac.org/sl/about/trainingsessions/training2011/fall/presentations.aspx#presentations
What’s new with E-rate for funding
year 2012?
New item 5: Ministerial and clerical errors
• “The applicant can amend its forms to correct clerical and ministerial
errors on their FCC Forms 470, FCC Form 471 applications, or associated
documentation until an FCDL is issued. Such errors include only the kinds
of errors that a typist might make when entering data from one list to
another, such as mistyping a number, using the wrong name or phone
number, failing to enter an item from the source list onto the application,
or making an arithmetic error.”(FCC 11-60)
• New guidance (Ann Arbor decision) allows even more
examples of errors that may be corrected prior to funding
commitment decision letter.
More on ministerial and clerical
errors
What’s new?
• The 15-day rule is eliminated (for corrections
only)
– Corrections to 470 and 471 can be submitted until
the funding commitment decision letter is issued
• If you made an error and your PIA review has
already started, tell your reviewer right away
that you made an error
More on ministerial and clerical
errors
If you find you made an error and need
assistance to get it corrected, contact Pam
(schools/districts/AEAs) or Jay (libraries)
What can I do to get ready for
funding year 2012?
• Do you have/will you have new buildings?
• Have you closed any buildings? Will you have
buildings closing in 2012-13 school year?
• Are buildings changing their purpose? (once
were attendance centers and now are for
purposes such as admin offices)
• Have you reorganized with another district?
(or will you reorganize for 2012-13?)
• Have you formed a “system” (non-publics)?
Names of school buildings
Want to speed up your 2012 application review?
• Take a look at the Iowa Educational Directory for the
2011-12 school year
http://educateiowa.gov/index.php?option=com_con
tent&view=article&id=692&Itemid=2697
• Note the names of your buildings (and
district/system) in the Directory
• If changes need to be made for 2012-13 school year,
notify USAC.
• Notify me of changes as well ([email protected])
Contact USAC
Call the USAC Client Service Bureau to notify
them of changes to building names, contact
person information, corrections to building
addresses, etc.
They may request the information in writing on
school/district/library letterhead
1-888-203-8100
Completing the form 470
Form 470: What’s eligible for funding
• Requirements for eligibility:
– Must be an eligible product or service
– Used by an eligible entity
– Used at an eligible location
– Used for an eligible purpose
Form 470: What’s eligible for funding?
Five categories of services:
– Telecommunications services(priority 1)
– Telecommunications (priority 1)*
– Internet access (priority 1)
– Internal connections (priority 2)
– Maintenance of internal connections (priority 2)
*There’s no separate filing area on form 470 or 471
for this category of service.
Examples of telecomm services
•
•
•
•
•
Local telephone services
Long distance telephone service
Cell phone service
Text messaging on cell phone
Cellular data service/Internet access
(Smartphone type service or wireless access
“card” service)…also list under Internet access
• Service to bus barns, custodial facilities, etc. IS
eligible!!!!!!!
More examples of telecomm services
• Centrex
• Leased circuits (e.g. data circuit to connect
your elementary school to the high school)
• E-911 and 911 lines
• Voicemail service (not just considered
telecomm service)
Examples of telecommunications
New
category for funding year 2011
This category primarily includes “dark fiber” or
leased lit fiber provided by a non-telecomm
provider
Telecommunications
• There is no item on either form 470 or form
471 for “telecommunications.”
• On form 470, list and describe dark fiber
under both telecommunications services and
Internet services
Internet services examples
• Internet access
• Wireless Internet access (via wireless
“cards”)
• Domain Name Service (DNS) registration
• Cell phone data service (e.g. Smartphone
type service or wireless access “card”
service) for Internet access..also list under
telecommunications service
Internet service examples
–Web hosting service (not purchase of
web server)
–Firewall service if included as a part of
bundled Internet service (not purchase
of firewall software and not as a
separate line item; see ESL page 9)
Internal connections
• These are priority 2!
• Should I apply? Yes, if your
district/school/library needs the eligible
goods and services
Unused funds from previous years have been
rolled into funding year 2011. All eligible
applicants in 2010 got priority 2 funding.
Internal connections
• NOTE: priority 2 is the only category where
items may be purchased by school/library
• NOTE: Tech plan is required for all priority 2
requests!!!
• 2 in 5 rule applies for internal connections (an
eligible location may only receive E-rate
funding every 2 years out of 5)
Examples of internal connections
•
•
•
•
•
•
•
•
LANs
Routers
Switches
Hubs
Network servers
Wireless LANs/wireless access points
PBX (private branch exchange)
See ESL for more examples and details
Priority 2 Internal connections
Internal connections examples
Basic maintenance of internal
connections
• Should I apply? Yes, if you plan to have a
third party provide maintenance of
internal connections
• 2 in 5 rule does NOT apply for
maintenance (even though this is priority
2)
Basic maintenance of internal
connections
• 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
• 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
Basic maintenance of internal
connections
• 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.
Basic maintenance of internal
connections
• 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
Check out e-rate applications from
previous years
• Dig out old 470 and 471 forms
• Don’t limit yourself in bandwidth and
services (think ahead)
Form 470: Block 1
– Item 5c: “Number of Eligible Entities for which
services are sought” (How many buildings,
including locations like bus barns, that will receive
any E-rate services?)
– Item 7: Do not attempt to complete this. This
item is only completed by a paid consultant who is
filing on your behalf.
Discount Matrix
Percent of
Eligible Students
Less than 1%
1% - 19%
20% - 34%
35% - 49%
50% -74%
75% -100%
Urban
Rural
20%
40%
50%
60%
80%
90%
25%
50%
60%
70%
80%
90%
Iowa counties which are urban:
•
•
•
•
•
•
•
•
•
•
Black Hawk
Dallas
Dubuque
Johnson
Linn
Polk
Pottawattamie
Scott
Warren
Woodbury
Online filing
http://www.sl.universalservice.org/menu.asp
Should I e-certify?
• E-certify an option only if
– Your principal/supt/authorized person filed a
signed and data entered 471 and/or 486 in
previous year(s)
– Call SLD’s Client Service Bureau if you need a pin
number (888-203-8100)
– Special Pins for BEARs-only (online BEAR
filing)
What if we can’t/don’t want to ecertify?
• Print certification/signature page (as directed
on form 470)
• Have supt/director/authorized person sign
• Still recommend you use blue ink
• Mail certification/signature page with return
receipt
If you don’t e-certify
• Use the certification page from
the online filing
• DON’T just copy the cert page of
the mail-in version
Final steps:
• Print and/or electronically save a copy of the
completed 470 for your files
• Photocopy your cert page (if paper cert)
• Keep the completed copy in e-rate
notebook/files (electronic copies are fine)
• Check www.sl.universalservice.org/sl/ to see if
your form really was posted
How do I know my 470 was filed?
• 2 ways to check
– www.sl.universalservice.org/sl/
– You will receive a receipt in the mail! Keep
the receipt letter (on canary/yellow paper
for 2012)
Why should I check about filing?
• To check the “allowable contract
date”…this is the earliest date you may
file form 471!
• Don’t pick a service provider before the
28 days is up!
Are you on the helpful E-rate
listservs?
• [email protected] (primarily for
schools/districts and libraries). Send
Debbie Fiscus a message
[email protected][email protected] (primarily for
libraries). Sign up at the url or
contact Jay Peterson.
Numbers to remember
• SLD Client Service Bureau
– 1-888-203-8100
• Pam Jacobs
– 515-975-0071
– [email protected]
• Jay Peterson
– 515-281-4499
– [email protected]

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