E-Rate Training

Report
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Common E-Rate Terminology
Post Filing Processes
Funding Awards
Receipt of Services
Invoicing/Applying Funds
Priority Two Project Considerations
School Documentation
Follow-up and Tracking of Funds
6th Report and Order Overview of Changes
2012/2013 Reminders
Contact Information
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FCC: Federal Communications Commission
USAC: Universal Service Administrative Company
E-Rate: Education Rate
Priority One: recurring telecommunication services
Priority Two: internal connections
Consultant: provides applicant with E-Rate consulting support
Service Provider: provides applicant with services related to recurring
telecommunication services or internal connections
RAL: Receipt Acknowledgement Letter
PIA Review: Program Integrity Assurance; first level of application review
BEN: Billed Entity Number; a unique number assigned to the applicant,
like a social security number
PIN: a unique number assigned to an applicant’s authorized
representative to be used for filing and certifying forms online; it acts
like a banking PIN
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Application #: a unique number assigned to a form 471 when entered in
to the online E-Rate system; each form 471 receives a unique number
FRN: funding request number; a system generated number assigned to
each funding request on a form 471
FCDL: funding commitment decision letter; a letter that is generated by
USAC to communicate funding decision/s
Appeal: a pre-defined process for appealing a funding decision
Forms 470, 471, 472, 473, 474, 486, 500: will be defined in presentation
SPIN: Service Provider Identification Number; a unique number assigned
to service providers
CRN: Consultant Resource Number, a unique number assigned to an ERate consultant
SPI: Service Provider Invoicing; a discounted method to apply E-Rate
funding
BEAR: Billed Entity Application RE-imbursement; a method for receiving
re-imbursements of E-Rate funding
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RALs
Application Review/PIA
Other Reviews
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Applicants and service providers receive a Form 471 Receipt
Acknowledgment Letter (RAL) to confirm receipt of a timely-certified
Services Ordered and Certification Form (Form 471).
Applicants should carefully review the RAL and must notify USAC of any
data entry errors by the date specified in the letter.
If data entry or ministerial and clerical errors have occurred applicants
may make allowable corrections to their Form 471 without submitting a
new Form 471. The applicant must make the correction(s) to the RAL
Allowable Correction Section and submit the correction(s) to USAC
within 20 days of the letter date above the recipient's address in the
RAL.
RAL corrections are included in the original scope of work, therefore IR will
complete on behalf of the applicant
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Each application is reviewed to ensure that Universal Service Fund support is
committed only for eligible products and services as well as eligible uses by
eligible entities.
Review of All 471 Applications
USAC reviews all Services Ordered and Certification Forms (Form 471) to
verify the accuracy of discount percentages and ensure that support is
committed only for eligible products and services. USAC is committed to
issuing timely Funding Commitment Decision Letters but its ability to meet
that goal depends on efficient processing of application reviews.
Applicants can help speed up application reviews by:
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Submitting a complete Form 471 including required certifications and Item 21
Attachments for each funding request
Responding to requests for additional or clarifying information within 15 days
Verifying that USAC has correct contact information
Compliance Audits
PIA reviews are included in the original scope of work, therefore IR will complete on
behalf of the applicant
USAC may conduct other levels of review
 Select Review
 Procedural Audits
 Program Compliance Audits
These types of reviews are outside of the original scope of work. If IR’s
support is desired, a new agreement will be needed. Please keep in
mind that these reviews are time sensitive.
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Following application review, USAC issues one or more
Funding Commitment Decision Letters (FCDLs) to both the
applicant and the service provider(s)
Describes the services funded and not funded by FRN and
other relevant information for reminders and deadlines
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You may elect to begin receiving Priority One services or acquire
Priority Two hardware/equipment prior to an FCDL, but you can
only do so on July 1, 20XX or after
If you elect to begin before an FCDL award, you have to pay all
costs in full and seek re-imbursement at a later time and upon
receipt of an approved FCDL
IR will notify you directly and provide a copy of your official funding
commitment decision letter once received. IR will also file any
changes/appeals and begin the Receipt of Services process for your
school.
Changes
 Reduction in award amount
 Service Substitution Change
 Service Provider Change
 SPIN Changes
Appeals
 Appeal a denial of funds
Reduction / Cancellation of awards: Form 500
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The Form 500 Application is the mechanism used for requesting
modifications to submitted FRNs. Within this application you can
submit reduction requests (there is no mechanism to request
additional funding), change contract beginning and ending dates,
and cancellation of an FRN (be sure….as there is no opportunity to
change your mind afterwards).
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It should be noted that it is the school’s responsibility to register
reductions and cancellations of FRNs.
IR can file Changes for the applicant but since it is not within the
original scope of work, additional hourly fees will be charged.
A Closer Look of What’s Involved: Form 500
Information Needed to Complete the Form:
 FRN information…vendor, SPIN number, amount, etc..
 Authoritative staff’s contact information
Best Practices: Form 500
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Make changes as you need them…do not put off for later as this
typically leads to the form not being filed in time to be of use to
the school
Make a copy of the completed form for your own records
Mail at Post Office using the “Notification of Receipt” service.
Retain all such receipts as part of your documentation
There is no “deadline” on when to file. This form is based on a
school’s need for modifying certain items within an FRN.
Typically, submitted forms are addressed between 3-5 weeks.
Service Substitution is a change in the products and/or
services specified in the Services Ordered and Certification Form, FCC
Form 471.
Criteria to meet for service substitutions:
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The substituted services or products have the same functionality as
the services or products contained in the original proposal.
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The substitution does not violate any contract provisions or state or
local procurement laws.
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The substitution does not result in an increase in the percentage of
ineligible services or functions.
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The requested change is within the scope of the controlling FCC
Form 470, including any Requests for Proposal, for the original
service.
Service Substitution process for initiating:
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Meet criteria for service substitutions
Make application for substitutions
USAC review of service substitutions
Timeline for Requests / Corrections to Installed components
Service Substitutions initiated by service providers due to discontinued
products
IR can file Service Subs for the applicant but since it is not within the original
scope of work, additional hourly fees will be charged.
SPIN Changes
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Operational SPIN Changes
May only be requested by the applicant. The SLD permits
Operational SPIN changes when an applicant certifies that (1) the
SPIN change is allowed under its state and local procurement rules,
(2) the SPIN change is allowable under the terms of any contract
between the applicant and its original service provider, and (3) the
applicant has notified its original service provider of its intent to
change service providers.
Operational SPIN changes must be postmarked or received no earlier
than the date of the Funding Commitment Decision Letter (FCDL)
and no later than the last date to submit an invoice
SPIN Changes
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Corrective SPIN changes
A request to change a SPIN that usually does not change the actual service provider.
There are three categories of SPIN corrections that the SLD will consider upon written
request:
1. Data entry error
2. The original service provider has, in part or whole, merged with, or been acquired
by, another company
3. Other instances when the service provider indicated on the Form 471 was
changed, and the applicant did not initiate the change
Corrective SPIN changes must be postmarked or received no earlier than the date of
your Receipt Acknowledgment Letter (RAL), unless you have been contacted by the
SLD about this application, and no later than the last date to submit an invoice.
IR can file SPIN changes for the applicant but since it is not within the original scope
of work, additional hourly fees will be charged.
Lets look at how to make CHANGES…
Online Instructions
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Can no longer switch vendors because of lower price
Must select vendor that received the next highest point value in
the original bid evaluation, assuming there was more than one
bidder
If only one original bidder, an applicant may select a substitute
service provider that satisfies its needs most effectively and
efficiently
An applicant will not be required to initiate another competitive
bidding process by submitting a new Form 470
Split FRNs when transitioning to new service is acceptable
Can submit new 470 in mid-year if you want to switch for any
other reason or want to sign new multi-year contract
An Appeal is a request to USAC to address any challenges and support
in regards to a negative award finding or related to extension of time
due to extenuating circumstances (i.e. hospitalization, death, etc..).
Appeals must be received or postmarked no later than 60 days after the
date of USAC's decision letter. It should be noted an appeal process
could take anywhere from several months to several years to come to a
conclusion.
Specific process for initiating an Appeal:
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Compose a letter/narrative identifying the nature of the appeal
request (on letterhead).
Utilize on-line request capability through SLD homepage under
“submit a question”
Include any supporting documentation that justifies your request
If appropriate, IR can file Appeals related to the original scope of work
at no additional cost.
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Establishing Roles
Begin Receipt of Services
Getting Set up with Service Providers
Establish who at your school will be responsible for the following:
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Setting up service installs/start dates, project starts, signing service
provider related paperwork/work orders, etc..
Liaison to Intelagent Resources to provide relevant service related
materials, i.e. invoices
Intelagent Resources will handle the following on behalf of the applicant:
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Form 486 filing (Receipt of Services form)
Setting up invoicing method with each Service Provider - SPI/BEAR
Filing and monitoring of the BEAR re-imbursement process
Relevant Forms
Form 486 – Informs USAC that services and/or equipment identified within a
filed 471 has either been received or is process of being received and allows
for the program to start receiving and process corresponding requests for
funds.
Form 472 – Also known as the “BEARS” (Billed Entity Applicant
Reimbursement ) Form is used to inform USAC of the school’s intent to
submit an invoice for reimbursement of discounts.
Form 474 – Also known as “SPI”. The Form 474 informs USAC of the
amount of the discounts provided to eligible schools and libraries and for
which the service provider seeks universal service support.
Form 500 – Is used to request changes within filed FRNs (i.e.: contract dates,
reductions in originally requested funds, cancellation of the entire FRN)
Important Reminder:
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You may begin your service pre-funding, but you will have to
pay the invoices in full until award, unless otherwise
established with your service provider
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Depending on when you are awarded, your discount options
may change. For example the service provider may not allow
credits/discounts after a certain timeframe and you will
have to file BEAR re-imbursements
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Service providers may have their own unique process for
setting up a customer for E-Rate discounts, but discounts are
only offered via credit (SPI) or re-imbursement (BEAR).
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Service providers may contact you before or after an FCDL is
issued to elect a invoicing method, please notify Intelagent
Resources when contacted
Service Provider Invoice (SPI): Form 474
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If SPI method has been set up, your Service Provider will
submit a Form 474 to USAC, as well as their annual service
provider certification, Form 473
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Your invoices should arrive with credits already applied to
your totals. For example if you are funded at 80%, your
invoice will show an 80% credit and you will be responsible
for paying the remaining 20% which should be indicated on
the statement
Billed Entity Applicant Reimbursements (BEAR)
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The Form 472 Application identifies to the SLD that the school
has received services/equipment and is seeking to be
reimbursed for the items which have already been paid in full
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A separate Form 472 Application must be filed for each
service provider
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Intelagent Resources will file BEARs on a quarterly or annual
basis for applicants on an as needed basis using the online
BEAR system
Lets look at the online filing tool…
BEAR Invoice System Login
Your infrastructure implementation strategy is
contingent on the following:
 Pre funding commitment:
July 1, 20XX or after without
receipt of FCDL)
 Post funding commitment: July 1, 20XX or after receipt of
FCDL)
Pre-funding commitment:
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Identify central point of contact for all E-Rate related business and
become familiar with E-Rate documentation especially the form 471 and
Item 21 attachments
Identify any changes or substitutions with FRNs and file appropriate ERate paperwork
Collaboratively create a project plan, project schedule and
communication strategy and share with all relevant parties
Sign any work/install orders, issue purchase orders, etc.. for July 1, 20XX
or after
As services/hardware is received, capture all E-Rate related
documentation and keep for records
Pay all invoices in full and file for BEARs after FCDL is issued
Post funding commitment:
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Identify central point of contact for all E-Rate related business and
become familiar with E-Rate documentation especially the form 471
and Item 21 attachments
Identify any changes or substitutions with FRNs and file appropriate
E-Rate paperwork
Collaboratively create a project plan, project schedule and
communication strategy and share with all relevant parties
Sign any work/install orders, issue purchase orders, etc.. for July 1,
20XX or after. Be sure to inform the service provider to SPI invoicing
so that your invoices come discounted
As services/hardware is received, capture all E-Rate related
documentation and keep for records
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Documentation Compliance Rules
Application Documentation
Post Application Documentation
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Applicants and service providers must maintain program
documentation for five years after services are received
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All applicants and service providers are required to retain
receipt and delivery records relating to the technology
plans, pre-bidding, bidding, contracts, application process,
invoices, provision of services, and other matters relating to
the administration of the Universal Service Fund
Myeratedocs: myeratedocs.com
 Password and Login required
 Contains all application paperwork from bid docs, quotes,
bid/quote responses, Forms 470 & 471, Item 21
attachments, RALs, etc..
 Contains some customer provided E-Rate materials like
the online E-Rate survey data
Contracts, Purchase Orders, Invoices, etc.:
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Purchase and Delivery of Services – Beneficiaries and service providers should
retain all documents related to the purchase and delivery of E-rate eligible
services and equipment. Beneficiaries must retain purchase requisitions,
purchase orders, packing slips, delivery and installation records showing where
equipment was delivered and installed or where services were provided. Service
providers must retain all applicable documents listed above
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Invoicing – Both service providers and beneficiaries must retain all invoices.
Beneficiaries must retain records proving payment such as accounts payable
records, service provider statement, beneficiary check, bank statement or ACH
transaction record. Beneficiaries and service providers must also be able to
show proof of service provider payment to the beneficiary of the GEAR
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Contracts – Both beneficiaries and service providers must retain executed
contracts, signed and dated by both parties. All amendments and addendums to
the contracts must be retained, as well as other agreements relating to E-rate
between the beneficiary and service provider, such as up-front payment
arrangements
You can use the Data Retrieval Tool on USAC’s site to access
applications, funding commitments and funding disbursements
Access the tool here:
Online Data Retrieval Tool
Or from the myeratedocs portal:
www.myeratedocs.com
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If your school's Internet Safety Policy (or Acceptable Use Policy) doesn't
contain at least this minimal language, you need to revise your policy
before July 1, 2012:
"The school district will educate all students about appropriate online
behavior, including interacting with other individuals on social
networking websites and in chat rooms and cyberbullying awareness
and response.“
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Internet Safety Education must specifically cover the following topics:
• Cyber-bullying
• Social Networking
• Chatrooms
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Technology Plans need to be certified by your state prior to accepting
any funds for that particular funding year
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2013 Official Application filing window will most likely open in Dec.
2012 and close the first week of Feb. 2013
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Income Data Collection Process: 2012/13 income levels have been
released. Please use this link to access this data:
http://www.fns.usda.gov/cnd/Governance/notices/iegs/IEGs.htm
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Set your application strategy meeting/conference call with IR for July
and August 2012. Proposals will be provided to schools by September
14, 2012 with expectation that contracts can be signed at October
board meetings
Remy Bibaud
Phone: 412-231-1515 or 412-334-1888
Email: remy@intelagentresources.com
Delana Murphy
Phone: 412-231-1515
Email: dmurphy@intelagentresources.com

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