INTRODUCTION TO E RATE FY

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1 INTRODUCTION TO E RATE FY Intro Session Agenda» Introduction to KSLLC» E Rate Basics» Acronyms & Terms» Resources» Q&A 7/7/ Kellogg & Sovereign Consulting, LLC 1

2 Introduction Polling Questions The KSLLC Team E Rate RHC OUSF Debi Sovereign* Christina Bailey* Rachel Botts Jermol Coureur Mai Fields* Ben Godwin Adam Godwin Susie Godwin Riley Harpole Bridgette Hider Alex Linam Kennedy Payne Teagan Vick* Jennifer Williams Mandy Wood* Jane Kellogg* Stacy Simpkins Marci White Shannon Tice Sharhonda DoDoo Shelby O Dell Alex Ballard *Certified E rate Management Professional 4 Kellogg & Sovereign Consulting, LLC 2

3 E RATE BASICS 5 E Rate Organization FCC USAC Schools & Libraries Division 6 Kellogg & Sovereign Consulting, LLC 3

4 7 USAC s Erate Productivity Center EPC pronounced Epic» Kellogg & Sovereign Consulting, LLC 4

5 USAC EPC Overview Acronyms & Terms» Account Administrator: An EPC user who can manage users, permissions, and related entities for an organization such as a school, library, service provider, consortium, or consulting firm» Add or remove existing user: This process allows a user to add or remove an existing user to an organization, including adding a consultant as a user for an applicant entity» My Landing Page: My landing page provides you with a specific list of your entities, FCC Forms, customer service cases and tasks assigned to you. It also includes several links to important information including reports, forms and USAC s website to locate additional information 10 Kellogg & Sovereign Consulting, LLC 5

6 E RATE APPLICATION PROCESS 11 E Rate Timeline Form 470 & (Optional) RFP Sept Dec Form 486 Receive Funding Form 471 Jan Mar Funding May Sept 12 Kellogg & Sovereign Consulting, LLC 6

7 KSLLC Process Timeline» July Sept: Recommend Service Provider demonstrations for applicants» August December: Prepare RFP Questionnaire online at Sept December: Post Form 470 & RFP competitive bidding period» Sept January Host fair and open bidding process» Oct Jan Select winning bids, gather and sign contracts» Jan Mar Form 471 filed online at EPC Portal» Mar June Approve E rate Board Resolution to pay non discount portion of requested services.» April 1 Installation for Category 2 equipment may begin (Install by September 30)» May June USAC begins issuing funding commitments» July Start service recurring services (funding period ends June 30) 13 E Rate Budget» In December, 2014, The FCC set the E rate funding cap at $3.9 billion for each funding year.» The cap was previously $2.25 billion» Cap is adjusted for inflation each year (beginning in 2010). Currently $3.99 billion is available and $3.2 billion was requested for » Once each year, FCC can roll over unused funds from previous funding years into the current funding year 14 Kellogg & Sovereign Consulting, LLC 7

8 Who is Eligible? Schools and School Districts Non traditional facilities Conditionally by state see Eligibility Table Libraries and Library Systems Consortia of eligible entities Groups that band together to aggregate demand and negotiate lower prices (regional consortia, statewide networks) Eligibility Table : traditional/eligibility table.aspx 15 Acronyms & Terms» Annex: An annex is a classroom or facility that is part of a school or library which is geographically separate but maintained through the same entity and considered part of that entity by the state» Manage Annexes: This function allows you to add or remove an annex for an individual school or library in EPC» Manage Organization: This function allows you to update information about an entity or a BEN in EPC» FCC Form Kellogg & Sovereign Consulting, LLC 8

9 E Rate Rules Congress directed the Federal Communications Commission (FCC) to establish the E rate program in 1996 The FCC sets rules and policies through orders Policies are defined in the text of orders Appeal Decisions Universal Service Administrative Company Schools & Libraries Division (USAC/SLD) develops procedures for specific actions, such as how to process applications 17 E Rate Discount 20 90% Discounts are based on percentage of students eligible for the National School Lunch Program (NSLP) and Urban or rural status of entity» Schools calculated by district Total free reduced lunch students/total enrollment» Libraries Use school district in which the library is located» Library Systems Use school district in which the main library is located 18 Kellogg & Sovereign Consulting, LLC 9

10 E Rate Discount Matrix INCOME Measured by % of students eligible for the National School Lunch Program URBAN LOCATION Discount RURAL LOCATION Discount CATEGORY 2 DISCOUNT % If the % of students in your school that qualifies for the National School Lunch Program is and you are in an URBAN area, your discount will be and you are in a RURAL area, your discount will be Less than 1% 20% 25% Same 1% to 19% 40% 50% Same 20% to 34% 50% 60% Same 35% to 49% 60% 70% Same 50% to 74% 80% 80% Same 75% to 100% 90% 90% 85% 19 Acronyms & Terms» Service Provider Identification Number (SPIN): Unique number assigned by USAC to service providers seeking payment for participating in a USF program. A SPIN is also used to verify delivery of services and to arrange for payment.» Billed Entity Number (BEN): an identification number assigned by USAC to each school or library building» FCC Form Kellogg & Sovereign Consulting, LLC 10

11 Acronyms & Terms What is a funding year?» A funding year (FY) runs from July 1 to the following June 30.» FY2018 runs from July 1, 2018 to June 30, Recurring services (e.g., monthly telephone services and Internet) must be delivered by June 30. Non recurring services (e.g., equipment and installations) must be delivered and installed by the September 30 following the funding year, and this deadline can be extended. 21 Acronyms & Terms» Non instructional Facility (NIF): a school building with no classrooms or a library building with no public areas NIFs are eligible for Category 1 services NIFs are eligible for Category 2 services only if necessary to provide effective transport of information to classrooms or public areas of libraries 22 Kellogg & Sovereign Consulting, LLC 11

12 Acronyms & Terms FUNDING YEARS USAC References beginning date 07/01/ /30/2019 = FY 2018 Program year # Based on first year of the program: = Program Year = Program Year Polling Questions Kellogg & Sovereign Consulting, LLC 12

13 Eligible Services List for Categories of Service CATEGORY ONE CATEGORY TWO» Services used to connect broadband or Internet to eligible locations, or services that provide the basic conduit access to the Internet. Data Transmission Services and Internet Access, and Voice Services are Category One services.» Voice service eligible but being phased out.» Internal connections services needed to enable high speed broadband connectivity and broadband internal connections components. Category Two includes local area networks /wireless local area networks (LAN/WLAN), eligible broadband internal connections components, basic maintenance of eligible broadband internal connections components, and managed internal broadband services. 26 Kellogg & Sovereign Consulting, LLC 13

14 Data Transmission Services and Internet Access Category 1» Fiber (Lit and Dark)» OC 1, OC 3, OC 12, OC n» Wireless Service (e.g. microwave)» Satellite Services» DS 1, DS 2, DS 3» Ethernet» T 1, T 3, Fractional T 1» Frame Relay» SMDS» Cable Modem» DSL» ATM» Telephone Dial up» Broadband over Power Lines» Self provisioned Broadband Network E Rate Eligible fiber options Leased Lit Fiber Leased Dark Fiber Self Provisioned Owned by provider Owned by provider Owned by applicant Provisioned by provider with charges for service IRU or Lease Operations and maintenance responsibility of applicant 28 Kellogg & Sovereign Consulting, LLC 14

15 What is special construction? Special construction refers to the upfront, non recurring costs associated with the installation of new fiber. 1. construction of network facilities; 2. design and engineering; and 3. project management. Does not include network equipment necessary to light fiber. 29 Eligible voice services subject to phasedown» Local, long distance, 800 service» POTS» Interconnected VoIP» Circuit capacity dedicated to providing voice service» Centrex» PRI/ISDN» Radio Loop» Satellite telephone service» Shared telephone service» Wireless telephone service including cellular voice» Data and text messaging must be cost allocated 30 Kellogg & Sovereign Consulting, LLC 15

16 Voice Phase down For FY2018, the reduction to voice services is 80% Circuit phasedown varies** 31 Eligible Services Category 2 Eligible Broadband Internal Connections Subject to the Category Two Budget Access points Cabling Caching Firewalls Switches Routers Racks UPS Wireless LAN Controllers Improvements, upgrades and software necessary to support eligible broadband internal connections components Functionalities listed here that can be virtualized in the cloud, and equipment that combines eligible functionalities are also eligible. 32 Kellogg & Sovereign Consulting, LLC 16

17 Managed Internal Broadband Services (e.g. Managed Wi Fi) Subject to the Category Two budget Services provided by a third party Operation, Management, And/or monitoring of eligible broadband internal connection components The third party may manage the school or library s equipment or provide the equipment as part of a lease. 33 Basic Maintenance of Internal Connections Subject to the Category Two budget Support for basic maintenance of eligible internal connections such as:» Repair and upkeep of hardware» Wire and cable maintenance» Basic tech support» Configuration changes Support for BMIC is limited to actual work performed under the contract. 34 Kellogg & Sovereign Consulting, LLC 17

18 » Schools: Category Two Budgets $153.47/student, per site Minimum $9, if site has fewer than 62 students School sites with classrooms have budgets, no budget for NIFs» Libraries: $2.35/square foot Minimum $9, if less than 4,000 sq. ft» Large Urban Libraries (IMLS locales 11, 12, 21): $5.12/square foot Minimum $9, if less than 1,850 sq. ft 35 Miscellaneous Eligible Charges Taxes, surcharges and other similar reasonable charges Lease fees to rent or lease eligible components Shipping charges Training Installation and configuration» Installation may be provided by a third party 36 Kellogg & Sovereign Consulting, LLC 18

19 Acronyms & Terms» Recurring Services Services that occur every month. Examples: telephone service, Internet Access. Includes basic maintenance. Use by June 30 th of the funding year.» Non Recurring Services One time charges. Examples: installation fees, network equipment. Install by September 30 th following the FY. Extensions available if funded or changes made on or after March 1 OR upon written request. 37 Eligible Services List Polling Questions Kellogg & Sovereign Consulting, LLC 19

20 E Rate Filing for E Rate Filing FCC Form 470 & RFP Competitive Bidding FCC Form 471 Application Review & Funding FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 40 Kellogg & Sovereign Consulting, LLC 20

21 Acronyms & Terms» Request for Proposal (RFP): a bidding document which provides detailed information about requested services, locations, bid submission requirements, etc.» Some states or procurement agencies refer to these documents by other names, e.g., Invitation for Bids (IFB)» If an RFP is required by state/local procurement rules, the applicant must issue one. 41 FCC Form 470» Applicants post an FCC Form 470 and may issue an RFP (Request for Proposal) to open a competitive bidding process.» Used to identify and describe desired categories of service and function of the services.» Process must be open and fair.» Applicants must wait a minimum of 28 days after the later of the FCC Form 470 certification or RFP posting before selecting a service provider, signing a contract (if applicable).» Applicant must choose the most cost effective solution with the price of the E rate eligible products and services as the primary factor in the evaluation. 42 Kellogg & Sovereign Consulting, LLC 21

22 Acronyms & Terms» E rate Productivity Center: EPC is the account and application management portal for the Schools and Libraries (E rate) Program. Applicants, consultants, and service providers participating in the E rate Program use this tool to manage program processes and to submit questions» FCC Form 470 Receipt Notification Letter (RNL): a notification issued by USAC to the applicant that summarizes the information provided in the FCC Form 470. Available in EPC Portal News Feed» Allowable Vendor Contract Date (ACD): the date 28 days after the FCC Form 470 is posted in EPC 43 Competitive Bidding FCC Form 470 & RFP Competitive Bidding FCC Form 471 Application Review & Funding FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 44 Kellogg & Sovereign Consulting, LLC 22

23 Competitive Bidding» Applicants must ensure that the competitive bidding process is open and fair Must keep all incoming bids/correspondence with bidders and prepare to evaluate all bids received equally» All potential bidders must have access to the information from an FCC Form 470 and RFP, and they can respond to the applicant requests 45 Competitive Bidding Violations 1. The applicant has a relationship with a service provider that would unfairly influence the outcome of a competition or furnish the service provider with inside information. 2. Someone other than the applicant or an authorized representative of the applicant prepares, signs OR submits the FCC Form 470 and certification. 46 Kellogg & Sovereign Consulting, LLC 23

24 Competitive Bidding Violations 3. A service provider representative is listed as the FCC Form 470 contact person and that service provider is allowed to participate in the competitive bidding process 4. The FCC Form 470 does not describe the desired products and services with sufficient specificity to enable interested parties to submit bid responses 47 Acronyms & Terms» Bid: A service provider response to an applicant s FCC Form 470 and RFP which contains services and prices and any other information requested» Price as the primary factor: In evaluating bids, the price of the eligible products and services must be the most heavily weighted factor the applicant s evaluation of bids 48 Kellogg & Sovereign Consulting, LLC 24

25 Applicants select a Provider After the close of the competitive bidding process (on or after the Allowable Contract Date), they will: 1) Evaluate all bids received 2) Select service provider(s) 3) Sign a contract, if applicable 4) Prepare & submit an FCC Form Suggested Bid Evaluation Matrix Factor Points Vendor 1 Vendor2 Vendor 3 Possible Price of the ELIGIBLE goods and services Prior experience w/ vendor Personnel Qualifications Responsiveness Technical Merit Price Other Costs Total Kellogg & Sovereign Consulting, LLC 25

26 FCC Form 471 FCC Form 470 & RFP Competitive Bidding FCC Form 471 Application Review & Funding FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 51 FCC Form 471» Service providers may assist with Form 471» Applicant provides information on the service providers and eligible services chosen» Applicant must identify the eligible sites which will receive services» Applicant calculates and reports how much support they are seeking for the year» Applicant includes discount calculation information» Applicant certifies compliance with program rules 52 Kellogg & Sovereign Consulting, LLC 26

27 Acronyms & Terms» Funding Request Number (FRN): A unique number that USAC assigns to each funding request in an FCC Form 471.» Form 471 Filing Window: The period generally between mid January and mid March (prior to the start of the funding year) when forms filed are treated as having been received on the same day and are considered for funding before any other forms filed after the window closes 53 WARNING! RAL IS ACKNOWLEDGEMENT FORM 471 RECEIPT ACKNOWLEDGEMENT LETTER (RAL) IS NOT A FUNDING LETTER» BE SURE TO WAIT FOR APPROVAL OF FUNDING (FCDL) BEFORE BEGINNING SERVICE» OR GET WRITTEN BOARD APPROVAL THAT THEY WILL PAY 100% PRIOR TO INSTALLING SERVICES THAT ARE NOT YET FUNDED! 54 Kellogg & Sovereign Consulting, LLC 27

28 Application Review & Funding FCC Form 470 & RFP Competitive Bidding FCC Form 471 Application Review & Funding FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 55 Acronyms & Terms» Program Integrity Assurance (PIA): After you file and certify an FCC Form 471 within the filing window, Program Integrity Assurance (PIA) reviewers at USAC check the information on your form for completeness and accuracy and may have additional questions for you to answer. All applications go through an initial review and a final review.» Funding Commitment Decision: notification issued by USAC to the applicant and the service provider that contains commitment decisions on funding requests. 56 Kellogg & Sovereign Consulting, LLC 28

29 Application Review & Funding During Application Review, PIA will contact the APPLICANT to:» Check the eligibility of the schools &/or libraries and their discount levels» Verify that the services requested are eligible for discounts» Give applicant an opportunity to make allowable corrections to applicant s form» In some cases, ask for additional verification of applicant s compliance with program rules» Service provider may be contacted by the applicant for additional information about the service provider s bid. 57 Application Review & Funding» Following application review, USAC issues a funding notification to both the applicant and the service provider(s). Both may go to their EPC Home Page to generate and view the FCDL in Excel format» Applicants and Service Providers should carefully review the funding notice for details on approved or denied requests and your next steps» If funding is reduced or denied, the applicant or the service provider can consider filing an appeal of the USAC decision with USAC within 60 days. 58 Kellogg & Sovereign Consulting, LLC 29

30 Application Review & Funding» Service Provider will work with applicant directly to begin service» Both parties must follow contract terms» Ensure procedures are in place and IN WRITING if any work is done or products provided prior to funding 59 E Rate Filing Polling Questions Kellogg & Sovereign Consulting, LLC 30

31 FCC Form 486 FCC Form 470 & RNL Competitive Bidding FCC Form 471 & RAL Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 61 FCC Form 486 Purpose» FILED BY APPLICANT KSLLC files our clients Form DAY DEADLINE from service start date or issuance of FCDL» Notify USAC that applicant s eligible services have started or been delivered and invoices for those services can be processed and paid» Report applicant s status of compliance with CIPA 62 Kellogg & Sovereign Consulting, LLC 31

32 Acronyms & Terms» FCC Form 486 Notification Letter: An EPC notification in your News Feed issued by USAC to the applicant and service provider after an FCC Form 486 has been processed (KSLLC submits this form on your behalf)» Children s Internet Protection Act (CIPA): A law that mandates certain Internet safety policy and filtering requirements for recipients of E rate Program discounts for services other than telecommunications services. 63 FCC Forms 472 & 474 Invoicing FCC Form 470 & RNL Competitive Bidding FCC Form 471 & RAL Application Review & FCDL FCC Form 486 FCC Forms 472 (BEAR) & 474 (SPI) 64 Kellogg & Sovereign Consulting, LLC 32

33 BEAR or SPI Method BEAR SPI Acronyms & Terms» BEAR Billed Entity Applicant Reimbursement (FCC Form 472) The BEAR Form is an FCC form that schools and libraries submit to USAC after paying for services in full, to request reimbursement for the discount on those services. Reimbursement directly to the applicant, through EFT Form 498 must be completed in order to receive EFT» Form 498: The Service Provider and Billed Entity Identification Number and General Contact Information Form is used to collect contact, remittance, and payment information from service providers and applicants receiving universal service support. Service providers must fill out this form to participate in any of the universal service programs. As of July 1, 2016, applicants who choose the Billed Entity Applicant Reimbursement (BEAR) payment method will need to file this form to receive an ID number (498 ID) for reimbursement payments. 66 Kellogg & Sovereign Consulting, LLC 33

34 Acronyms & Terms» SPI Service Provider Invoice (FCC Form 474):The Service Provider Invoice Form is an FCC form that service providers submit to request reimbursement for discounted eligible services already provided to the schools or libraries on their customer bills. *Note* Applicants can choose their method of invoicing; service providers cannot force applicants to use a particular method. 67 Invoicing Requirements» BOTH Applicants and Service Providers receive funding notification from USAC in EPC for the services being invoiced» Applicants must file an FCC Form 486 and certify in EPC» Applicants using the BEAR invoicing method MUST have a Form 498 on file with USAC» Service Providers must file an FCC Form 473 each funding year FCC Form 473 is the Service Provider Annual Certification. Must be current prior to invoicing USAC. 473 can be filed after USAC has announced the opening of the application filing window. 68 Kellogg & Sovereign Consulting, LLC 34

35 Acronyms & Terms» BEAR Notification Letter: A BEAR (FCC Form 472) Notification Letter is sent to the service provider and the applicant after a BEAR form has been processed by USAC.» Quarterly Disbursement Report: A report issued by USAC to the applicant detailing all invoicing activity (BEARs and SPIs) for all funding years that occurred during the previous quarter.» FCC Form 473 Service Provider Annual Certification (SPAC): The Service Provider Annual Certification Form is an FCC form that service providers file annually to certify that they will comply with program rules and guidelines. This must be filed before USAC will pay invoices. 69 Deadlines» FCC Form 470 Posted a minimum of 28 days before the filing of the FCC Form 471, keeping in mind the FCC Form 471 application filing window opening and closing dates FCC Form 471 Certified online in EPC NO LATER than 11:59 p.m. EST on the day of the close of the FCC Form 471 application filing window (exact date will be posted on USAC website) 70 Kellogg & Sovereign Consulting, LLC 35

36 Deadlines cont d» FCC Form 486 Received or postmarked no later than 120 days after the date of the USAC Funding Commitment Decision Letter or the service start date, whichever is later» FCC Form 472/ FCC Form 474 Certified online no later than 120 days after the date of the FCC Form 486 Notification Letter or the last date that the applicant can receive service from the provider in the funding year at issue, whichever is later EXAMPLE: Last date to receive recurring service for FY is June 30, Add 120 days and last date to invoice is October 28, Deadlines cont d» Appeals An appeal is a request to reconsider a decision. FCC or USAC Deadline to appeal: no later than 60 days after the date of decision letter» Beneficiary and Contributor Audit Program (BCAP): Run by USAC, and carried out by auditors trained in universal service and program audit requirements, these audits of beneficiaries and contributors serve to identify noncompliance with program rules and amounts of recoverable funds.» Commitment Adjustment (COMAD): The process by which a funding commitment is reduced because of program rule violations. 72 Kellogg & Sovereign Consulting, LLC 36

37 Resources» Social Media» We have revamped our social media presence please like and follow us to get updates, tips, important alerts, and information. Twitter: Facebook: LinkedIn: beta/ » Kellogg & Sovereign Consulting, LLC Kellogg & Sovereign Consulting, LLC 37

38 E Rate Post funding Polling Questions Workshop Evaluation Your opinion matters greatly. Tell us how well we met your E Rate education needs today: 76 Kellogg & Sovereign Consulting, LLC 38

39 FINAL QUESTIONS & WRAP UP 77 CONTACT Your E Rate Professionals, Kellogg & Sovereign Consulting, LLC, for further questions or assistance Stadium Drive Ada, OK info@kelloggllc.com 78 Kellogg & Sovereign Consulting, LLC 39