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E-rate: Text Version of the Year 2004 Presentation

Text alternative for the E-rate Year 2004 Powerpoint Presentation.

Slide 1

E-rate/California Teleconnect Fund(CTF) Training for Year 2004
Version 4.0
California Department of Education E-rate/CTF Training Collaborative
October 2003

Slide 2

Workshop Objectives
  • Provide unbiased guidance to apply for E-rate and CTF telecommunication discounts.
  • Provide information about program changes.
  • Provide state, local, and vendor perspectives.
  • Provide information references.

Slide 3

E-rate and CTF Application Process

October 2003

Slide 4

What is E-rate?
  • E-rate (“Education-rate”) is a federal program, officially known as Universal Service Fund (USF), Schools and Libraries
  • The annual fund is $2.25 billion. It is administered by the Schools and Libraries Division (SLD).
  • The fund offers 20-90% discounts on telecommunications, Internet service, and internal connections.

Slide 5

What is CTF?
  • California Teleconnect Fund (CTF) is a state program administered by the California Public Utilities Commission (CPUC). The fund is now $55 million annually.

Slide 6

California Teleconnect Fund (CTF) Program

A Program of the California Public Utilities Commission (CPUC)

Slide 7

Purpose of the CTF Program
  • The CTF offers 50% discounts on monthly recurring costs of telecommunications services to eligible entities.

Eligible entities

  • Schools and libraries
  • Hospitals and health clinics
  • Community Based Organizations
  • Consortia of eligible entities

Discounts

  • 50% below the rates (tariff or negotiated rate) charged to other businesses for the same services or their functional equivalents

Slide 8

How the CTF Is Funded

Funded by all end users of telecommunications services through a surcharge on their telecommunications bills

Slide 9

Services That Qualify for a CTF Discount
  • Measured business or its functional equivalent
  • Switched 56 or its functional equivalent
  • Integrated Services Digital Network (ISDN) or its functional equivalent
  • T-1
  • OC3-OC192

Slide 10

Charges/Taxes Eligible for CTF Discount
  • Monthly recurring charges
  • Company-specific surcharge/surcredit
  • CPUC user fee
  • Federal excise tax
  • 911 tax
  • Local/city Tax – Variable
  • The taxes and surcharges or surcredits covered by the CTF Program are based only on the approved CTF discount amounts.

Slide 11

Charges Not Discounted by CTF
  • Nonrecurring charges (e.g., installation charge)
  • Usage charges

Slide 12

CTF Application Process

Applicant submits CTF application to CPUC with all required information (e.g., IRS tax-exempt statement)

New CTF application and instructions are available at:
http://www.cpuc.ca.gov/static/telco/public+programs/ctf_faq.htm. (Outside Source)

Slide 13

CTF Application Process
  • The CPUC calculates discounts based on the date the application is received by the CPUC.
  • Once the application is approved by the CPUC, it is not necessary to reapply for CTF discounts.
  • Applicants inform telecommunications providers of changes or additions to lines/services to receive CTF discounts for additional services.

Slide 14

Applying for E-rate

Forms 470, 471, and 486

Slide 15

E-rate
  • Eligible entities: schools and libraries
  • Eligible services
  • Eligible uses – new definition

Slide 16

Discount Percentages
  • Number of students eligible for National School Lunch Program
  • Rural and urban designation

Slide 17

Funding Priorities
  • Priority One – Telecommunications and Internet access
  • Priority Two – Internal connections

Slide 18

E-rate Application Steps
  • File Form 470 to request services.
  • Receive Form 470 acknowledgment letter.
  • File Form 471, Request for Funding.
  • Receipt Acknowledgement Letter (RAL) from SLD
  • SLD Review Form 471.
  • Review and correct Funding Commitment Decision Letter
  • File Form 486 (Aug 2003) and Form 486 notification.
  • Receive discounts.
  • Modify funding requests on Form 500.
  • Reference: http://www.sl.universalservice.org/applicants/processflow.asp (Outside Source)

Slide 19

Why File a Form 470?
  • It’s required for competitive bidding and procurement of services.
  • It initiates the application process.
  • It describes the technology services being sought.

Slide 20

Form 470 - Items to Consider
  • Calculate your E-rate discount.
  • Choose an E-rate application strategy.
  • Design an education technology plan.
  • Identify your non-discounted costs
  • File online by applying for user ID and PIN.
  • Applicant PIN Request System https://slpin.universalservice.org/SL_PIN/NECAServlet.jrun?hszAction=START&hszCommand=REQUEST&szUserType=SLD

Slide 21

Online Form 470
  • Apply online at http://www.sl.universalservice.org/menu.asp (Outside Source).
  • Select either the “Form 470 PDF” or “Form 470 Interview.”
  • Print each page of the application as you complete it online before selecting "Next" to move to a new screen.

Slide 22

Form 470 - Blocks 1 and 2
  • Complete all requested information in Blocks 1 and 2.
  • Print and file the screen that displays the application number. You will need to refer to the application number later. Read Form 470 instructions and directions on the form.

Slide 23

Form 470 – Block 3
  • Technology assessment of services being sought – What kind of other technology is to support the effective use of E-rate equipment?

Slide 24

Form 470 – Block 4
  • Identifies recipients of services – eligible entities.
  • Identify billed entities and ineligible entities.
  • This information is required to help service providers understand the scope and location(s) of the services being sought.

Slide 25

Form 470 – Block 5
  • Certifies that discounts are for eligible schools/libraries.
  • Certifies the technology plan.
  • Certifies eligible purposes, no resale or transfer.
  • Secures access to necessary resources.

Slide 26

Form 470 – Follow-up
  • Work with potential vendors to estimate costs for Form 471.
  • Keep copies of all responses to Form 470 and bids considered.
  • Develop and keep documentation of the process for selecting a specific vendor (price is the most heavily weighted factor in the decision).
  • Select the most cost-effective provider.

Slide 27

Form 470 – Reminders
  • Procurement must be competitive and follow the rules.
  • Excessive vendor involvement is not allowed.
  • Form 470 cannot be completed by a service provider.

Slide 28

Form 471 – Request for Discounts
  • Form 471 must be preceded by the filing and posting of a Form 470 for at least 28 days.
  • Online, filing is easier and more accurate.
  • File individual Form 471 for Priority 1 and Priority 2 discounts.
  • Need to submit item 21 attachments after filing online.

Slide 29

Form 471 – Guidelines
  • Wait 28 days before signing up for services.
  • Note contract extensions and contract expiration dates.
  • Note the E-rate funding escape clause.
  • Include product or service upgrades/substitutions in contract.
  • Separate internal connections/wiring portions of contracts for highest discount schools.
  • Make sure procurement complies with local and state procurement rules.

Slide 30

Form 471 – Blocks 1 and 2
  • Block 1 is to provide information on the billed entity:
  • Contact information, billed entity number
  • Summer contact information
  • Block 2 is used to indicate changes to the contract information. Contact SLD Help.

Slide 31

Form 471 – Block 4

Slide 32

Form 471 – Block 5
  • Document the services ordered.
  • Create a separate Block 5 worksheet for each:
  • Service provider
  • Contract
  • Category of service (telecommunications, Internet, internal connections)
  • Establishing Form 470
  • Separate out ineligible services.

Slide 33

Form 471 – Block 6
  • Use Block 6 to certify form 471.
  • Submit online if you have a PIN. Attach a copy of the online confirmation page and attach that to the top of the item 21 attachment(s).
  • Justify “duplicative services” in item 21.

Slide 34

Form 471 – Item 21 Attachments
  • Label clearly to identify the correct Form 471.
  • List services/items requested (quantity, description, cost, type of cost, narrative).
  • Separate ineligible services/items.
  • Attach quote or bill from the vendor (phone bills).
  • Document nonduplicative services.

Slide 35

Form 471 Submission
  • Was Form 471 signed after contract?
  • Was Form 471 signed by an authorized person?
  • Is the applicant prepared to prove that they had the money “in the bank?”
  • Tips to handle the program Integrity Assurance team’s questions:
  • Make sure you know what it is asking.
  • Don’t answer more than you were asked.
  • Retain PIA responses for audit purposes.

Slide 36

Form 471 Receipt Acknowledgement Letter (RAL)
  • Correct data entry errors.
  • Provide or correct applicant’s contact information.
  • Correct (not change) a Service Provider Identification Number (SPIN).
  • Reduce, cancel, or split a Funding Request Number (FRN).
  • Submit corrections, if any, within 3 weeks after date on RAL.

Slide 37

Form 500
  • Modify funding requests – Cancel or reduce the FRN.
  • Modify service dates – See SLD guidance on changing service dates and contract expiration dates.

Slide 38

Keep Copies
  • All form submissions and proof of submission.
  • All bids, awards, contracts, assumptions, decisions, budgets, tech plan certifications.
  • All communications with the SLD (e-mail may be used for documentation).
  • Documents should be kept for 5 years, and organized by funding year.

Slide 39

Actions to Take After Receiving the FCDL

Actions to Take After Receiving FCDL

Slide 40

Overview
  • File a Form 486 by the deadline or else lose discounts.
  • Communicate all necessary information to service providers.
  • Document all new work done during funding year.
  • Track discounts OR file a Billed Entity Applicant Reimbursement (BEAR Form 472).

Slide 41

Form 486
  • Why file
  • When to submit (don’t miss the deadline)
  • Ways to submit
  • tips

Slide 42

Form 486 – Why File
  • No discounts until the Form 486 is filed.
  • To alert SLD that services are being provided.
  • To certify that your technology plan is approved.
  • To certify compliance with the Children’s Internet Protection Act (CIPA) compliance.

Slide 43

Form 486 Submission
  • Submit Form 486 within 120 days of FCDL date or start of service, whichever is later.
  • Submit Form 486 on paper or online.

Slide 44

Form 486 Tips

Slide 45

Steps to Take After Receipt of FCDL
  • Provide necessary information: service providers.
  • Existing Services – which FRN will fund discounts and at what percent eligibility.
  • New services – which FRN funds the project and timeline for project (may change due to date of FCDL).
  • Service substitution or SPIN changes (complete paperwork earlier in the FY).

Slide 46

Steps to Take After Receipt of FCDL

Document all new work performed during funding year:

  • All lines and circuits installed and the date of installation.
  • Dates of lines and circuits disconnected, if any.
  • Every piece of equipment installed or moved (Documentation is necessary in case of an audit in the future).

Slide 47

Steps to Take After Receipt of FCDL
  • Track discounts OR file BEAR Form 472
  • Discuss with each service provider whether discounts will appear on bills or BEAR Form 472 will be needed.
  • Work with service provider to understand where discounts appear on the bills.
  • If BEAR Form 472 is needed, pay bill in full and then follow the process at: http://www.sl.universalservice.org/form/default.asp#applicants. (Outside Source)

Slide 48

California Procurement Options

California Department of General Services

Slide 49

Purchase Options
  • Purchase from a single vendor
  • Can integrate multiple technologies
  • Purchase from multiple vendors
  • Potentially wider variety of choices
  • Make consortia arrangements
  • Leverage buying power of multiple entities
  • Purchase through State of California contracts
  • CMAS, CALNET

Slide 50

Masters/State Contracts

Slide 51

Eligible Services Available through State Contracts
  • Telecommunications services
  • Internet access services (many suppliers)
  • Internal connections

Slide 52

Contract Agreement Number

Slide 53

Contract Term

Slide 54

Contract Considerations

Slide 55

Contract Considerations

Slide 56

Contract Considerations

Slide 57

CMAS Considerations
  • Asking for CMAS-only vendors is allowed, but you must still have a competitive procurement process and evaluate multiple CMAS vendors.
  • Multiple CMAS responses allows price comparisons and competitive bidding to take place.

Slide 58

Contracts Documentation
  • Be prepared to provide legal opinion to prove such documentation constitutes a contract pursuant to California Public Contract Code.
  • Quotes are not considered contracts according to SLD rules.

Slide 59

  • Program Topics
  • Vendor Involvement
  • Managing Phone Bills
  • Reviews and Audits
  • Program Updates
  • Strategies

Slide 60

What Vendors Can Do and May Not Do in the E-rate Program

California Department of Education E-rate/CTF Training Collaborative October 2003

Slide 61

Vendor Involvement
  • What the vendor can do to help you.
  • What the vendor may not do to help you.
  • Waive the nondiscounted cost.
  • Give proper assistance in Form 470 process.
  • Assist applicants customers with tech plans.
  • Give proper assistance in Form 471 process.
  • Inappropriate roles for service providers.

Slide 62

Vendor Selection

The applicant has a duty to conduct a fair, open, and competitive procurement process that seeks the most cost-effective solution to its technology needs. Price must be the most important factor under consideration but should not be the only consideration.

Slide 63

Vendor Qualifications
  • Vendor/service provider’s (SP’s) experience
  • Ability of SP to meet deadlines
  • Proximity of SP to work site
  • Quality of work and ability to manage the project
  • Ability to provide necessary maintenance and help
  • Prior E-rate experience

Slide 64

Appropriate Role of Vendor/Service Provider

Before submission of the Form 470, service providers should:

  • Understand the requirements of the E-rate technology plan requirements
  • Understand the E-rate program rules, requirements, and timelines.
  • Offer unbiased technical assistance that does not have an undue influence on the applicant’s ability to follow the open, fair competitive bidding process.

Slide 65

Appropriate Role of Vendor/Service Provider

Before submission of the Form 470: (Continued)

  • Provide assistance within guidelines of the E-rate program.
  • Provide input ONLY on development of the Request for Proposal (RFP).
  • Wait 28 days before signing contract with vendor/service provider.

Slide 66

Appropriate Role of Vendor/Service Provider

After submission of the Form 470:

  • Provide information on products and services being offered.
  • Assist the applicant in the creation of the Form 471 item 21 attachment documentation.
  • Provide a quote or a bill and a copy of the contract.
  • Provide quantity, product/service description, unit cost, extended pre-discount cost.
  • Visit the site if all bidders are allowed to do so.

Slide 67

Appropriate Role of Vendor/Service Provider After the FCDL
  • Assist with service substitution information and SPIN change requests (if required).
  • Provide easy-to-understand account information.
  • Review billing arrangements with applicant (discounts or reimbursements).
  • Provide current information on SPIN numbers and legal names.
  • Remind applicants of deadlines and timelines.
  • Encourage compliance with program rules.

Slide 68

Service Providers May Not
  • Complete or sign applicant’s Form 470 and Form 471.
  • Serve as the contact or evaluator on Form 470.
  • Serve as a technology plan approver.
  • Prepare an applicant’s Request for Proposal (RFP).
  • Enter into a contract prior to the required 28-day waiting period.
  • Provide “Alternative Funding” grants or foundations as payment applicant’s undiscounted portion of the service provider’s bid. See http://www.sl.universalservice.org/reference/freeservices.asp. (Outside Source)
  • Make determinations on product or service eligibility.

Slide 69

Service Providers May Not

Slide 70

Consequences for Violation of Program Rules
  • Denial of funding.
  • Cancellation or adjustment of funding.
  • Audit or other investigation.
  • Criminal investigation.

Slide 71

County Office of Education (COE) as a Service Provider
  • The SLD views intermediate service agencies, such as county offices of education, that provide services to be the same as any other vendor. COEs must must follow the same rules.

Slide 72

Managing Phone Bills

October 2003

Slide 73

Managing Phone Bills
  • Summary billing.
  • Applying for nondiscounted costs.
  • Summary billing and your E-rate Form 471.
  • What to do before requesting summary bills.
  • What to expect from summary bills.
  • Other phone bill management strategies.

Slide 74

Summary Billing Preparation
  • Check to see if your carrier has summary billing.
  • Get a list of all telecommunication lines.
  • Decide how you want the bill to be organized.
  • Convert all billed telephone numbers and working telephone numbers to the same billing cycle.
  • Determine level of detail (eligible/ineligible, by site, voice/data, etc.).

Slide 75

Summary Bills
  • Summary pages
  • Detail pages for each billed telephone number and working telephone number
  • Tracking costs for filing your Form 471
  • Makes Item 21 attachments easier
  • Separates ineligible numbers
  • Lists E-rate discounts

Slide 76

Phone Bill Strategies
  • Always pay current charges.
  • Request a check for credits accumulated.
  • Build an E-rate process tracking system.
  • Use summary billing to track your discounts.

Slide 77

Review and Audit Readiness

Documenting Compliance with E-rate Program Rules.

Slide 78

Documentation for Audits and Reviews
  • Program Integrity Assurance (PIA) reviews
  • Selective reviews
  • Audits

Slide 79

Minimum Processing Standards
  • Correct form.
  • Complete applicant information.
  • Complete submission of form.
  • File online to ensure you have met minimum processing standards.

Slide 80

PIA Reviews
  • The PIA team checks for eligibility of entity.
  • The PIA team checks for eligibility of service.
  • The PIA team verifies discount rate calculation.
  • Applicant should be aware of timelines to respond to the PIA team.

Slide 81

Selective Reviews - Item 25

Preparing for Selective Reviews October 2003

Slide 82

Selective Reviews
  • They are used by the SLD to verify:
  • Competitive bidding and vendor selection
  • Form 471 item 25 certification, “Can you use and support the product and services requested?”
  • Ability to pay for nondiscounted costs
  • Technology plan
  • They are conducted at the billed entity level.

Slide 83

Tips on Selective Reviews
  • Provide the requested information in 14 days.
  • Request an extension of time if necessary.
  • Document the approval of the extension (date, SLD contact, extension date).
  • Fax or e-mail requested information to SLD.
  • Contact PIA representative to establish a relationship.

Slide 84

Competitive Bidding – Vendor Selection
  • Provide RFP or reason for not providing an RFP.
  • Keep all bid responses, not just the one selected.
  • Document how you selected the vendor and keep the documentation. Remember: cost must be the heaviest weighted factor, but there can be other factors.

Slide 85

Item 25 Certification
  • Documentation of your ability to pay for your share of E-rate discounts.
  • Estimates of non-E-rate hardware, software, professional development, retrofitting, and maintenance investments that are necessary to make effective use of the E-rate discounts.
  • Technology plan review.
  • Estimate of the technology level of all schools or libraries in your organization after the receipt of E-rate discounts.

Slide 86

Preparing for Audits

Slide 87

Purpose of E-rate Audits
  • To protect the program from waste, fraud, and abuse.
  • To ensure the program accomplishes its mission of “affordable telecommunications and information services for all eligible schools and libraries”.
  • To help the program meet its mission in the most effective and efficient manner possible.

Slide 88

What Auditors Look for
  • Inadequate competitive procurement process.
  • Ineligible services being funded.
  • Lack of resources to support effective use of E-rate-funded equipment.
  • Unauthorized equipment substitutions with increased costs and decreased functionality.
  • Incorrect discount calculations.
  • Implemented evaluations as indicated in your technology plan.
  • Location of E-rate-funded equipment.

Slide 89

Potential Consequences of Selective Reviews and Investigations
  • Denial of funding commitment.
  • Rejection of invoices.
  • Commitment adjustment.
  • Audits.
  • Reimburse E-rate.
  • Civil lawsuit.
  • Subpoena.
  • State or local prosecution.
  • Recovery under the Federal Debt Collection Act.
  • FCC enforcement action.
  • Civil false claims action.
  • Criminal action.

Slide 90

Audit Findings
  • Asset or inventory tracking documents missing or not complete.
  • Competitive bidding violations.
  • Invoice documentation, SP invoice/bills.
  • Disbursement.
  • Tech plan and evaluation.
  • National School Lunch Program data documentation not available.

Slide 91

Be Prepared for the Auditors
  • Rules require records to be kept for five years.
  • Keep e-mail, notes, memos, FCC Form instructions, eligibility list, etc.
  • Audit is based on the rules in place at the time your application was processed.
  • Be responsive to auditors:
  • Make it as easy as possible for them,
  • but don’t be afraid to question their requests and/or decisions.
  • Turn to experts, reputable vendors, and third-party consultants.

Slide 92

Document “Testing”
  • Free and reduced-price lunch surveys.
  • Technology plan.
  • Budget documents.
  • Original RFP and bidders’ list.
  • All bids, selection criteria, and reasons for bid selection.
  • Original contracts.
  • Purchase orders.
  • Original invoices.
  • Shipment receipt information.
  • Inventory records.
  • Canceled checks and payment dates.
  • Item 21 attachments.

Slide 93

Contract Review
  • Test all contracts.
  • Are you in compliance with state and local regulations?
  • Did you really conduct a competitive bid?
  • Can you demonstrate how you chose the winner?
  • Is the contract consistent with Form 470?
  • Do contract dates correspond to Form 471?

Slide 94

Signing Contracts
  • Applicant must have contract, PO, or other binding agreement.
  • Applicant may want to make contract contingent on receiving funding.
  • Don’t sign before allowable contract date (No agreement to purchase, no P.O., etc.)
  • Funds will cover services delivered only during the funding year (e.g., July 2004 - Sept. 2005 for YR 7).

Slide 95

Signing Contracts (Continued)
  • Be careful that contract language doesn’t cause problems down the road.
  • The term “functional equivalent” allows for easier product/service substitutions later.
  • Specify responsibilities of applicant and vendors:
  • Form 486 submission.
  • Payments and invoicing of its portion.
  • Eligible services/locations.
  • Make sure original contract language specifies the terms of renewal.

Slide 96

Free Services
  • The value of all price reductions, promotional offers, and "free" products or services must be deducted from the prediscount cost of services indicated in funding requests.
  • Costs, trade-in allowances, and discounts must be fairly and appropriately derived.
  • A proportionate cost allocation is required between eligible and ineligible components.

Slide 97

Invoices and Payments
  • Vendor must invoice applicant before invoicing SLD.
  • Applicants must pay their nondiscount share.
  • Invoices must clearly show what services are being delivered (and where).
  • Applicant verifies that discounts are applied properly.
  • Applicant credits or adjustments must also be applied to SLD.

Slide 98

Changing a Service Provider
  • The change is subject to deadline.
  • The process is easier than it once was.
  • Applicant can get out of old contract.
  • Applicant has informed original vendor.
  • State and local procurement regulations allow the change.
  • The change will be reviewed by auditors.

Slide 99

Service Substitution
  • New product(s) must have the same functionality:
  • Same medium (e.g., voice, data, video), same category.
  • Service substitution must be permitted under procurement rules.
  • Substitutes must not cost more than the original product/service, or the applicant must pay any increase.

Slide 100

Service Substitution (Continued)
  • The substitute must not include greater percentage of ineligible services.
  • The substitute must be in line with Form 470 and RFP, if any.
  • The substitute will be reviewed by auditors.

Slide 101

Possible Penalties/Recoveries
  • Potentially several millions of dollars may be recovered, based on Andersen and Office of Inspector General audit work
  • Potential consequences:
  • Recovery of any and all funds paid from either the beneficiary or the service provider.
  • Suspension and/or debarment from the program for either beneficiaries or service providers.

Slide 102

Transition to Investigation
  • Intentional fraud, waste, and abuse uncovered by audit will result in an investigation.
  • Possible investigative issues:
  • Procurement irregularities.
  • Billing for goods and services not provided (false claims).
  • Ineligible items being funded.
  • Misappropriation of assets.
  • Beneficiaries not paying the undiscounted costs.
  • Misrepresentations on forms/certifications (false statements).

Slide 103

Audit Reminders
  • Audits are easier if you make them part of your E-rate application process.
  • Document your access to resources to pay for nondiscounted costs to make effective use of E-rated services and equipment.
  • Keep E-rate documentation by funding year.
  • Review SLD audit references on the Web.

Slide 104

Year 2004 E-rate Program Updates

Program Changes, New Eligible and Ineligible Services, New Interpretations of Rules.

Slide 105

Program Changes
  • Unused funds rollover – more funds?
  • Appeals deadline – 60 days.
  • Technology plans – more specific, written by the date the Form 470 is submitted.
  • Legally binding contracts – quotes not acceptable.
  • 30% rule – ineligible and unsubstantiated.
  • Duplicative services – need to justify

Slide 106

New Eligible Services
  • Definition of educational purpose – on the premise
  • Voice mail – in any category.
  • Wireless – same as wireline.
  • Firewalls – servers or service.
  • Alarm lines – but not 911 or E911 (yet).
  • Web hosting – but not Web site development.
  • File servers – firewall servers.

Slide 107

New Ineligible Services
  • Dark fiber – vs. lit fiber.
  • VoIP – Voice-over IP as a service.
  • UPS/battery backup limits.
  • Maintenance - limited to “basic,” no managed network services.

Slide 108

Definition of Educational Purpose

“. . . in the case of schools, activities that are integral, immediate, and proximate to the education of students, or in the case of libraries, integral, immediate, and proximate to the provision of library services to library patrons, qualify as educational purposes under this program.” Presume that activities on school or library property meet this standard.

Slide 109

Duplicative Services
  • Deliver the same function to the same population in the same location during the same period of time.
  • “Duplicative” is considered excess capacity, and redundant needs should be justified (e.g., system reliability).
  • Justify on Form 471, item 21.

Slide 110

Technology Plan
  • Technology plan must be written by Form 470 submission.
  • Technology plan must be approved by Form 486 submission.
  • Did you correctly characterize your technology inventory?
  • Does your technology plan actually match what you are doing?
  • Are all the E-rate services/products addressed in the technology plan?

Slide 111

What Does All This Mean?
  • More eligible services, more E-rate funds.
  • Procurements by the rules.
  • More specific technology plans, written by Form 470.
  • Budget documentation.
  • Documentation to show effective use.
  • Alignment of Form 470, tech plans, budgets.
  • More reviews and audits.

Slide 112

Top Reasons for Denial
  • 30% ineligible services.
  • Excessive vendor involvement.
  • Documentation not provided to SLD within timeframe requested.
  • Ineligible service provider or ineligible entity.
  • No Form 470 reference.
  • No contract when Form 471 filed.
  • Payment of nondiscounted costs.
  • Violation 28-day rule.

Slide 113

Looking Forward

Possible new FCC initiatives:

  • Limits to internal connections requests.
  • Guidance on transferability of equipment.
  • Eligibility of 911 and E911 lines.
  • New Notice of Proposed Rule Making this fall.

Slide 114

Telecommunications Discount Strategies

Slide 115

Year 2004 Strategies
  • Improve your district’s count of students eligible for the free & reduce-price lunch program.
  • Understand rules regarding vendor involvement.
  • File one Form 471 for Priority One and one Form 471 for Priority Two requests.
  • Understand your phone bills and use summary billing.

Slide 116

Year 2004 Strategies - Continued

Slide 117

Web References

Slide 118

Thank you
Questions: Patrick McMenamin | pmcmenam@cde.ca.gov | 916-322-5894 
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