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Presented by:Bob Rice, President
Triple R Consultants
E-RateTop 10 things you need to know!
©2011 Triple “R” Enterprises, Inc.
Introduction
o Who We Are
o What We Do
o Session Goal
Session Overview
o Recent Orders made by the FCC regarding USFE-Rate funding for schools indicate changes ahead for funding years 2011 and 2012
o This session will provide you with important information regarding these “new” FCC rules and how they will impact your E-Rate bidding and application processes
#10 Community Useo E-rate Discounted Services• Only some of the E-rate funded services
• Cannot charge for any E-rate funded services
• May charge fees for community use of facilities and/or computers
• Optional and based on school’s own policy(ies)
• Must be outside of school hours
o Community Use Policy(ies)• Responsible for developing policy(ies) and hours for
communityuse of facilities outside of school hours
• Urged to post these policy(ies) and hours publicly on the school’s website
#9 Program Integrity o Record Retention• Applicants and service providers must
maintainE-rate program documentation for a period of at least 5 years from the last date of receiving products and services
• If Department of Justice (DOJ) is involved, the time limit does not apply
• Archive all E-rate documents after the 5 year period expires
• E-rate requirements and list of documents to retain can be found on USAC/SLD website: http://www.usac.org/
#9 Program Integrity oGift Restrictions• Prohibits E-rate applicants from soliciting or accepting
any gift or other thing of value from a service provider participating in or seeking to participate in the E-rate program
• Consistent with the gift rules applicable to all federal agencies which permit only certainde minimis gifts
• Applicants must adhere to and follow the most stringent provision relating to the acceptance of gifts from a vendor
• Applicants have been and are required to certify on the Form 471 that they have not received anything of value or a promise of anything of value other than the services and equipment requested on the form
#9 Program Integrity o Consultant Information• Applicants must identify the consultant, if
any, used to assist in the E-rate competitive bidding and application process(s)
• Applicants must indicate on the Forms 470 & 471 whether the consultant is “Authorized”
Must have authority to procure and order products and services on the applicants behalf
Must have authority to make certifications on the applicants behalf
Must supply a Letter of Agency (LOA), upon request by USAC/SLD
#8 Program Compliance
o Program Quality Assurance Program (PQA)• The number of assessments fluctuates monthly
• Information is used to calculate estimates ofimproper payment rates across all USF programs, including E-rate
• Increases amount of document requests by USAC
• 10 days to comply with additional time - if needed
• USAC will seek to recover funds if there is a rule violation associated with payments under assessment
#8 Program Compliance
o Invoice Certifications• Service providers are required to submit
detailed invoices sent to the applicant to support the requested products and services
• Service Providers must complete, sign and date a Service Certification for SLD Invoices (SCSI)
• Applicants are required to certify that productsand services have been installed and/or received
#7 Dark Fiber o Leased Dark Fiber• Must be the most cost effective solution
and lit immediately upon installation• Categorized as either Telecommunications
or Internet Access• Limited eligibility for installation and
maintenance
o Ineligible Costs• Lighting dark fiber• Special constructions costs• Acquiring unneeded capacity
#6 Errors and Corrections
o Clerical and Ministerial Errors• 2006-Bishop Perry Order (RAL and RNL)
• 2011-FCC Order 11-60 extends the deadline forcorrections until receipt of the FundingCommitment Decision Letter (FCDL)
• May increase document requests by USAC/SLD
• Applicants must appeal to FCC for making any corrections after the FCDL date
#5 Technology Plans
oTech Plan Rules• Applicants must have a written plan before filing
the Form 470 for Priority 2 products and services only• Add a creation date on tech plan cover page• The budget element is no longer required for E-
rate
oForm Certifications• Applicants certify on Forms 470 and 471 that
their requests for services will be based on a technology plan – if required by program rules• Tech plans must be approved prior to the start of
the funding year (July 1) or the date the Form 486 is submitted to USAC – whichever is first
#4 Basic Maintenance ofInternal Connections (BMIC)
o Eligible Basic Maintenance• The agreement must specify the eligible
components covered• The service must be for basic maintenance
services only • Applicant invoice requirements
o Ineligible Basic Maintenance• Services more than basic• Unbundled warranties• Eligible vs. Ineligible service agreements
#3 Service Provider Identification Number (SPIN) Changes
o SPIN Change Requests• Corrective SPIN Changes• Operational SPIN Changes• Must comply with Form 486 deadline
o Allowable SPIN Changes (Began FY2011)
• Breach of contract• Service provider unable to perform• Newly selected service provider must be the
next highest point value in bid evaluation• Must receive FCDL prior to submitting change
#2 Competitive Bidding o Bidding Process• All E-Rate bids must be “Fair and Open”• As many bidders as possible so applicants receive
better services and lower prices• The bid must describe specific services or functions for
support - No generic or encyclopedic descriptions
o Form 470• Must be completed by the negotiating party• Must be ready to accept any/all bids• Service providers who prepare or certify forms cannot
bid• Must follow own state and local procurement laws• All tariffed/month to month services or “new” contracts
for services must be rebid each year• May use an RFP in addition to the Form 470
#1 Children’s Internet Protection Act
o CIPA Compliance• Must enforce an Internet safety policy• Must have a technology protection measure in
place (CIPA filter)
o Internet Safety Policy• Must be in place prior to receipt of service and
address specific issues• Beginning FY2012 must comply with the
Protecting Children in the 21st Century Act• Beginning FY2012 must retain a copy for 5
years• Must give reasonable public notice• Forms compliance and certifications
