E-rate: A Review for 2011 Session starts at 10am

1. E-rate: A Review for 2011– Session starts at 10am – Steve Sanders 608-266-3856stephen.sanders@dpi.wi.gov 1-9: Intro, review of FCC Sept Order, discounts 16-26: 470 review 50-57: W/F/ A, contracts 1-9: Intro, review of FCC Sept Order, discounts 16-26: 470 review 50-57: W/F/ A, contracts

2. 2 Agenda Overview of the program Eligibility, changes for 2011 and discounts Technology plans Application forms, follow-up processes Contracts TEACH and BCN update

3. 3 Overview Created by 1996 Telecom Act $2.25 billion annually from interstate phone revenue Can use rollover funds WI averages $25 million annually FCC has regulatory and legal oversight SLD does program administration SLD division of USAC Eligible applicants K-12 public and private schools, CESAs, Head Starts Public libraries, library systems Program has many acronyms

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5. 5 What Are The Eligible Services? Priority 1 Telecommunication services (telco’s only) Local/long distance, wireline and wireless, broadband Telecommunications (any entity) Dark and lit fiber Internet access Basic access Priority 2 Internal connections (2 in 5 year rule) Basic maintenance of IC (each year) Very few WI applicants get P2 2010 funding may drop to 80%? Note that any entity can provide Net access, including Telcos Check SPIN for cell services SPAC (US Cellular issue) Priority 2, only 2x in 5 years 2007: Extra $600 million addedNote that any entity can provide Net access, including Telcos Check SPIN for cell services SPAC (US Cellular issue) Priority 2, only 2x in 5 years 2007: Extra $600 million added

6. Eligible Services List (ESL) If it’s not in the ESL, assume it’s not eligible Must be used in an eligible location for eligible purposes See SLD site “Determine Eligible Services” Ineligible components/services must be removed Full funding may be provided as Ancillary Use Funding requests must be cost effective

7. 7 2011 E-rate Changes* Dark/lit fiber eligible from any entity** No technology plan required for P1 services Changes to Forms 470/471 Strengthens competitive bidding process Cannot accept anything of value from service providers** EDU 2011 program (off-premise wireless connectivity) Restricts unbundled warranties** Restricts Operational SPIN changes** Not addressed: Discount matrix, P2 funding, service provider board issue FCC’s Ysleta Order has this example: “[A] proposal to sell routers at prices two or three times greater than the prices available from commercial vendors would not be cost effective, absent extenuating circumstances.” FCC does not currently have “bright line” standards for evaluating cost effectiveness USAC will not approve funding requests that have unreasonable costs compared to the marketplace The selected bid must be cost-effective compared to prices available commercially Applicants are provided an opportunity to explain why a funding request has higher-than-expected costs USAC questions to applicants are targeted to the issues seen >>>>>>>>>>>>> Firewall: Like text messaging, not including the eligibility for firewall service is confusing. For this service however, it is even more confusing because a firewall is eligible when it is part of an applicant’s Internet access service, but it is not eligible when billed as a separate, standalone service. Thus the Commission is basing eligibly not on the technology, but on how it is billed. To be blunt, this does not make sense. FCC’s Ysleta Order has this example: “[A] proposal to sell routers at prices two or three times greater than the prices available from commercial vendors would not be cost effective, absent extenuating circumstances.” FCC does not currently have “bright line” standards for evaluating cost effectiveness USAC will not approve funding requests that have unreasonable costs compared to the marketplace The selected bid must be cost-effective compared to prices available commercially Applicants are provided an opportunity to explain why a funding request has higher-than-expected costs USAC questions to applicants are targeted to the issues seen >>>>>>>>>>>>> Firewall: Like text messaging, not including the eligibility for firewall service is confusing. For this service however, it is even more confusing because a firewall is eligible when it is part of an applicant’s Internet access service, but it is not eligible when billed as a separate, standalone service. Thus the Commission is basing eligibly not on the technology, but on how it is billed. To be blunt, this does not make sense.

8. 8 How Much Discount Can I Get? Discounts range from 20% to 90% Based on free/reduced lunch eligible Enrollment and lunch data entered on ISES Data now being reviewed DPI does not verify schools using their own data DPI posts Excel file in late December DPI sends file to SLD If you use DPI data and are contacted by PIA, contact DPI Actual Calculating Discount Methods done on Form 471 Add bullet on timing of ISES reportingAdd bullet on timing of ISES reporting

9. 9 Discount Matrix

10. Info & Technology Planning Certified plans required for Districts getting any (P1 or P2) E-Rate discount for current services (2010-2011) must have an approved plan that expires no earlier than June 30, 2011. Participation in NCLB II D activities - approved plan will be necessary to apply for a EETT FY11 competitive and/or formula grants in March ’11 (assuming Congressional funding) E-Rate Central advises all their schools that have 60% or higher discount rate to have an approved plan in case the P2 funding dips that low. (That would imply that they will encourage them to apply for P2 in the upcoming round) 10

11. Info & Technology Planning DPI encourages continued technology planning even though you may not need a certified plan Tie into district goals. Strategic plan or school goals or school improvement plan DPI will continue to approve technology plans… and will be working on a digital reporting mechanism in collaboration with districts… a Google Docs Template???? Want to give DPI technology planning input? http://tinyurl.com/techplanwi 11

12. 12 CIPA/NCIPA Compliance (Children's Internet Protection Act)

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15. 15 Forms and Deadlines

16. Form 470 Block 1: Applicants address and ID info Block 2: Summary of the services being requested Telecom Internet Internal connections Block 3: Technology resources Block 4: Entities that will receive the services Block 5: Certifications and signature 16

17. 17 Form 470 470 begins bidding process, must be filed for 2011 If you have no contract for the requested services Often tariffed or monthly telco or Internet service If you have contract but it expires before July 1, 2011 File 470 once for length of multi-year contracts or contracts with voluntary extensions 470 and any RFP must indicate this Check 7a and b and both options under b In out years on the 471, site the original 470 Be sure to file for correct category of service

18. 18 Form 470 Can file the 470 now for 2011 New form likely early Jan File one 470 for all services, or file separate forms for each service 470 must be posted on SLD website for at least 28 days before you select a provider or sign a contract See “Form 470” in News Briefs Insert 470 screens after this.Insert 470 screens after this.

19. 19 Form 470 and Competitive Bidding Must have a fair and open bidding process Bid document (RFP) optional, is a local decision Treat all vendors the same Vendors cannot be involved in your 470 Applicant’s consultant cannot be associated with vendor Must choose most cost-effective bid Cost must be primary factor Non-eligible products/services not part of cost effectiveness Fully document your bid review process and any decision(s) Record dates of any decisions, actions taken, etc. Highly public instances of waste, fraud and abuse reported in the media, US DOJ Highly public instances of waste, fraud and abuse reported in the media, US DOJ

20. Online Forms Training Site(http://sldtraining.usac.org) http://sldtraining.usac.org/ TrainingSiteWarning.asp? http://sldtraining.usac.org/ TrainingSiteWarning.asp?

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28. 28 E-rate Form 471 Provides specific information on services, service providers selected, and contracts and/or agreements, costs, etc. Provides discount calculation information Must be filed each funding year Applicant certifies compliance with all program rules Must be postmarked or filed online by ??? March XX ??? Form 470 certifications must also be filed online or postmarked before the close of the 471 filing window NEW Item 21 attachments may have to be filed by deadline!!!!! (still hoping for change in this).

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31. 31 Don’t Forget to print and save this!! It lets you get back into your application. You can start your Form 471 now to get basic information in, add specifics like lunch numbers and selected vendors when you know them, then submit before the Feb. 7th Deadline.Don’t Forget to print and save this!! It lets you get back into your application. You can start your Form 471 now to get basic information in, add specifics like lunch numbers and selected vendors when you know them, then submit before the Feb. 7th Deadline.

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43. 43 Tips on Filing Form 471 File separate Forms 471 for Priority 1 and Priority 2 services Remove ineligible costs and document or estimate eligible costs carefully (30% Rule) – (Now Bishop Perry makes less important) Filing online speeds processing and reduces errors Examine, correct, and save Receipt Acknowledgement Letter (RAL) Paper forms and instructions: http://usac.org/sl/tools/required-forms.aspx

44. 44 Receipt Acknowledgement Letter (RAL) Form 471 Receipt Acknowledgment Letter (RAL) Cover page of important reminders Provides confirmation of certain information entered from Form 471 Data entry errors may be corrected within three weeks by using the RAL (including Block 4 worksheets) Applicants can request funding reductions but not funding increases Can also correct some information on the block 4 worksheet… print it. Do within 3 weeks!!!!!!!!!!!!!!!!Can also correct some information on the block 4 worksheet… print it. Do within 3 weeks!!!!!!!!!!!!!!!!

45. 45 Funding Commitment Decision Letter (FCDL) FCDL reports status of individual funding requests: Funded Not funded As yet unfunded (internal connections) Canceled May receive more than one FCDL Use info on FCDL to prepare Form 486 ADD bullets on what they can change on the FCDL ADD bulls on they can make on RNL; RAL ADD bullets on what they can change on the FCDL ADD bulls on they can make on RNL; RAL

46. 46 E-rate Form 486 Notification that services have started and that SLD can pay invoices Certifies that Tech Plan (if required) has been approved and covers the entire funding year. Form 486 deadline is 120 days after service starts –OR– 120 days after date of Funding Commitment Decision Letter date, whichever is later October 29 deadline for FCDL before July 1

47. 47 E-rate Form 472/474 (Invoices) Invoices — Form 472 or Form 474 BEAR (Billed Entity Applicant Reimbursement) Form 472 filed by applicant and certified by service provider after receipt and payment for services Form due October 28, 120 days after last service date, June 30 Or 120 days after date of Form 486 Notification Letter -OR- SPI (Service Provider Invoice) Form 474 filed by service provider after providing services and billing applicant for its non-discount share

48. 48 Program Integrity Assurance (PIA) Application Review PIA reviews all applications to ensure compliance with rules Respond within 15 days to requests Work with service provider if needed Respond completely to PIA questions, but no more If needed, ask for more time or for clarification; contact DPI 10% of FRNs move to “Selective Review” Check 471 status at 471 Application Status Tool

49. 49 Issues of Waste, Fraud, Abuse W/F/A still problem in program, mostly caused by 90% discount, P2, complex program rules Vendors have been debarred, people are in prison W/F/A drives many FCC decisions More certifications More PIA requests for information More audits leading to more COMADs FCC can recoup funds going back 5 years See SLD Fall 2009 slides on audits Recent FCC IG questions to WI schools not targeting schools

50. 50 Contract Issues FCC/SLD E-rate contract rules trump local policies Telecom and Internet may/may not be contracted services As noted, on the 470, always check #7, options a and b Don’t sign contract before RFP due date or before 28 days But, you must sign/date contract before filing Form 471 Verbal agreements are not acceptable Quotes are not acceptable Have contract timed to E-rate cycle -- Contracts can cover more than one year or contain voluntary extensions, but these options must be indicated in the establishing Form 470 -- Tariffed and month-to-month services do not require a contract, but they are considered contracted services if a contract is signed -- Contracts can cover more than one year or contain voluntary extensions, but these options must be indicated in the establishing Form 470 -- Tariffed and month-to-month services do not require a contract, but they are considered contracted services if a contract is signed

51. 51 State Telco Contracts DOA cell contract School files 471 for cell service using your own or DOA 470 School must file 470 if using handhelds for Internet access Contract expires 6-30-12 DOA STS and Centrex Long distance via AT&T: Contract expires June 30, 2011, DOA to rebid Local and Centrex via AT&T, CenturyLink, Frontier Covered for 2011 E-rate Cell contract: http://vendornet.state.wi.us/vendornet/asp/ContractDetail.asp?SystemContractNumber=2050 STS, Centrex, VoIP contract: http://vendornet.state.wi.us/vendornet/asp/ContractDetail.asp?SystemContractNumber=1891 Hosted IP Services fully executed July 24, 2008. Contact Mark Rappe, (608) 264-9406 or mark.rappe@wisconsin.gov. Cell contract: http://vendornet.state.wi.us/vendornet/asp/ContractDetail.asp?SystemContractNumber=2050 STS, Centrex, VoIP contract: http://vendornet.state.wi.us/vendornet/asp/ContractDetail.asp?SystemContractNumber=1891 Hosted IP Services fully executed July 24, 2008. Contact Mark Rappe, (608) 264-9406 or mark.rappe@wisconsin.gov.

52. BadgerNet Grant and TEACH Federal grant to bring fiber to 467 schools and libraries on BCN Grant to provide districts with 100Mbps and libraries with 20Mbps But issues still preventing grant from being implemented If you need more bandwidth, contact TEACH If TEACH cannot meet your needs, you may need to file a 470/471 to get bandwidth outside of BCN DPI recommends waiting on this until more info is available 52

53. 53 Appeals Funding denials can be appealed Generally, appeal first to the SLD Then appeal to FCC if SLD denies appeal Must be postmarked within 60 days of denial on FCDL FCC has been granting many appeals But can be a year or more Contact DPI for appeal advice and template No appeal form See Appeals Procedure on SLD Website

54. 54 When You Need Help SLD website: www.usac.org/sl/ Fall 2010 SLD training slides Reference area News Briefs E-rate Central, WI site Enter your BEN and get info on your application SLD Client Service Bureau: 888-203-8100 Email: question@slcfund.org Fax: 888-276-8736 ADD SLIDE on : -- News Briefs -- E-rate Central WI site -- FFL -- SLD reference site -- SLD train forms site -- SLD data (DRT) site SEE last two sides on SLD new basics slidesADD SLIDE on : -- News Briefs -- E-rate Central WI site -- FFL -- SLD reference site -- SLD train forms site -- SLD data (DRT) site SEE last two sides on SLD new basics slides

55. 55 DPI Help DPI’s E-rate website: dpi.wi.gov/pld/erate.html DPI’s WIERATE email list: dpi.wi.gov/pld/wieratelist.html DPI Staff:

56. E-rate for 2011 ? Questions ? Steve Sanders 608-266-3856stephen.sanders@dpi.wi.gov