How Do I Navigate PIA Review?

How Do I Navigate PIA Review? Back to the New Basics Schools and Libraries Division Washington, DC • Orlando • Boston • New Orleans • Cleveland • San Francisco • Phoenix September/October 2007

Overview • PIA Review - What Is It? • Types of PIA Review • Frequently Asked PIA Questions • Responding to PIA Questions

PIA Review What is PIA? Program Integrity Assurance

PIA Review What is the purpose of PIA Review? • To educate applicants about E-rate jargon (e.g., FCDL, tariffed, SPAC, etc.,) • To ensure that Universal Service Fund support is committed only for eligible products and services as well as eligible uses by eligible entities. • To annoy applicants by asking for the same documents multiple times.

PIA Review Answer is B. • 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.

Types of PIA Reviews • Regular PIA Review All Form 471 applications are reviewed for: • Entity Eligibility • Discount Accuracy • Eligible Products & Services • Compliance with Program Rules

Types of PIA Reviews • Heightened Scrutiny PIA Reviews • Generally includes all applications associated with the BEN. • This is a targeted review of one or more of the following areas: • competitive bidding and evaluation process, • budget, • technology plan, • necessary resources (e.g., professional development, software, hardware, maintenance); and • products/services pricing and use

Types of PIA Reviews Types of Heightened Scrutiny Reviews • Selective Review • Pattern Analysis • Special Compliance • Cost Effectiveness 10% of Form 471 applications receive heightened scrutiny reviews

Types of PIA Reviews Levels of PIA Review Initial Review, Final Review, QA 1, QA 2 • Applications always start in Initial Review • Initial Reviewer from regular and/or heightened scrutiny team contacts the applicant with questions • If a more senior reviewer finds an issue with the review of the application, it will be returned to the initial reviewer and then have to move back up again. • Real time application status – 471 Application Status Tool

PIA Questions What do you do when PIA contacts you? • Resign immediately and don’t leave forwarding information. • Hide under your desk. • Respond to the questions.

PIA Questions Answer is C. • Respond to the questions. • If you are unsure what the PIA Reviewer is asking, use the contact information provided to ask the PIA Reviewer to clarify the question. • Ask to speak with a Manager if you are still unsure what the reviewer is requesting. 14% of all FY2006 FRNs were denied because the applicant never responded or submitted insufficient information.

PIA Questions What is PIA really asking me? • Third Party Documentation PIA Question: “If you do not agree with our eligibility assessment … then you may provide third party supporting documentation.”

PIA Questions Translation: • PIA needs additional details about the service to determine eligibility • Vendor product description • Vendor invoice or bill • Contract, service agreement, statement of work • PIA needs the information from an official source (e.g., State Department of Education) • Validating entity eligibility • Validating discount percent, student count

PIA Questions • Contract Certification PIA Question: “Please provide supporting documentation to demonstrate that a signed contract was in place at the time of the submission of the FCC Form 471 certification. Also, please certify that your contract meets your state or local procurement regulations or rules.” Translation:The contract did not have an applicant signature and/or a date. Because the signature and/or date is missing, PIA needs to confirm that the contract meets state/local procurement rules. PIA will ask you to complete the contract certification.

PIA Questions • Contract Certification Example I certify that I am authorized to make the representations set forth below on behalf of <enter entity name>, the entity represented on this letter, and am the most knowledgeable person with regard to the information set forth herein. I certify that for Funding Request Number(s) (FRNs) ____________, the Contract Award Date (CAD) is <mm/dd/yyyy> as reflected on the supporting documentation for this contract. I am correcting the CAD provided on the FCC Form 471 submitted for the above listed FRNs. I acknowledge that false statements can be punished by fine or forfeiture under the Communications Act, 47 U.S.C. §§ 502, 503(b), or fine or imprisonment under Title 18 of the United States Code, 18 U.S.C. § 1001 and civil violations of the False Claims Act. I acknowledge that FCC rules provide that persons who have been convicted of criminal violations or held civilly liable for certain acts arising from their participation in the schools and libraries support mechanism are subject to suspension and debarment from the program. I declare under penalty of perjury that the foregoing is true and correct. Executed on _____ day of ____________, 2007 at ____________ [city], ________[state].

PIA Questions • Incomplete Online & Paper Item 21 PIA Question: “the documentation provided is not sufficient to determine the eligibility…” Translation: • The product description was generic • Server functionality is not specified (e.g., file, network, web) • PIA needs specific functionality such as DHCP, DNS, Email, Proxy, etc. • Missing or incomplete make/model information

PIA Questions Incomplete Online & Paper Item 21 cont’d • Miscellaneous charges • PIA needs to know what the miscellaneous charges are • Miscellaneous charges are often used to describe inside wiring jacks, faceplates • Training requests • PIA needs the who/what/when details of the training being requested

PIA Questions Incomplete Online & Paper Item 21 cont’d Common Omissions & Errors • Ineligible components not identified • Applicant sent both an online and paper Item 21 • Items, cost, ineligibles are different

PIA Questions Incomplete Online & Paper Item 21 cont’d Common Omissions & Errors • Telecom service • Type of service is missing (local, long distance or cellular service) • Line count missing • Speed of line (e.g., T-1, Frame Relay, ISDN)

PIA Questions Incomplete Online & Paper Item 21 cont’d Common Omissions & Errors • Internet access • Bandwidth or speed missing (T-1, T-3, broadband, etc.) • Web Hosting (third party documentation needed) • Internal connections • Type of equipment stored on rack/cabinet missing • PBX component list missing • Make and model are missing

PIA Questions • Cost Allocation PIA Question: “For FRN XXX, the documentation provided in the Item 21 Attachments indicates that the following ineligible XXX were included in your request... Please provide documentation identifying the charges associated with the ineligible XXX identified above.” Translation: • “Save” the eligible portion of the FRN by removing the ineligible items and costs • Providing the cost allocation may prevent the entire FRN from being denied.

PIA Questions • Cost Allocationcont’d • Cost allocations must be based on tangible criteria and reach a realistic result. • PIA needs the cost associated with the ineligible service, entity, or location to: • Modify the FRN to remove ineligibles; or • Split the FRN, creating a new FRN for the ineligibles Note:When 30% or more of the services are ineligible and the applicant does not agree to split the FRN, the FRN will be denied.

PIA Questions • Splitting FRNs PIA Question: “You may request to remove the ineligible item(s) from this FRN and place this item(s) in a new FRN. Would you like to split the FRN? _____Yes or _____ No.” Translation: • “We agree to disagree” • Maintaining the ineligible items & cost

PIA Questions Splitting FRNs (New Block 5 information) • PIA needs the (ineligible & eligible) costs, service provider, contract and entities receiving service information for the “old” and “new” FRNs • Use the Applicant Contact Template to complete the Block information for the new FRN Splitting mixed-bucket request • Applicants have an opportunity to receive P1 (telecom, Internet access) funding without waiting until P2 threshold is determined

PIA Questions Sample Block 5 Template

PIA Questions • Establishing Form 470 PIA Question: “…you indicated that Form 470 XXX is the establishing Form 470 for the services requested. Is this Form 470 the establishing Form 470…?” Translation: The Form 470 provided does not support the category of service on the Form 471. PIA needs the Form 470 that was posted for at least 28 days for the services requested on the Form 471.

PIA Questions • Establishing Form 470 cont’d PIA Question: “… please provide the 15-digit Form 470 that established the bidding for the contract extension.” Translation:PIA needs the Form 470 which demonstrates the applicant requested a contract extension or the current funding year Form 470.

PIA Questions • Alternative Discount Calculation PIA Question:“On your Form 471 application #, you stated that you used an alternative discount mechanism to calculate the number of students eligible for NSLP, for the following entity (ies): XX. Please provide a complete description of the methodology used to calculate the number of students eligible for NSLP.”

PIA Questions • Alternative Discount Calculation Translation: • PIA needs to verify what method the applicant used to derive the discount. • Surveys are the most common method. • NSLP forms are not acceptable as surveys. • SSI, Section 8, Food Stamps are acceptable alternative mechanisms • Income Survey template is available on USAC’s website

PIA Questions • Additional explanation PIA Question: “If you do not agree with the cost allocation that we have produced, you must provide an alternative cost allocation identifying the cost(s) for the ineligible item(s).” Translation: PIA provided a cost allocation to remove ineligibles. The applicant can provide an alternate cost allocation if he or she disagrees with PIA. Make sure the alternate cost allocation is supported by third party documentation.

Applicants Responses 15 Day Rule • Applicants have 15 calendardays to respond to PIA questions • PIA will send a reminder on or near the 7th day • The state E-rate coordinator will be cc’ed on the reminder • Applicants may request extensions

Applicants Responses Why are you asking me that again? Modifications and Denials • PIA will confirm the original response when the FRN is modified or denied. • PIA will tell you the denial reason. This is an opportunity to correct a mistake and/or omission.

Applicants Responses Asking Again Success • Few FRNs were denied in FY 2007 for 30% Rule. 30% Rule Stats FY 2006 977 FRNs denied FY 2007 46 FRNs denied (as of 8/2007)

Applicants Responses Why are you asking for the same document again? • Different reviews • Regular review v. Selective review • Previous document may be missing key information • Contract missing date or signature • Unexplainable cost increase

Applicants Responses Why are you asking for the same document again? • Applicant’s funding request changed from FY to FY • Applicant added entities • Applicant requested additional services • PIA Resources

Applicants Responses Tips to eliminate repeat questions • Indicate multi-year or state master contract on Form 471 and contract number • Provide the application number and FRN associated with the documents previously submitted • Respond timely to PIA request

Applicants Responses Tips to eliminate repeat questions cont’d • Answer all the questions • When you ask to increase discount percentage and/or FRN amounts, provide third party documentation

Applicants Responses Tips to eliminate repeat questions cont’d • Provide PIA with the telephone bill summary page. If miscellaneous charges are listed in the summary, state what they are in your Item 21 Attachment. • “Final Answer”

Questions?

How Do I Navigate PIA Review?