On September 30 the SLD conducted the first of four E-rate stakeholder workshops. The main objective was for them to explain the application process and compliance issues that are equally important for all E-rate stakeholders to understand. Down below are the subjects that were stressed during the training.
FCC
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The FCC has not given any more specifics on how they are going to handle schools and libraries affected by the hurricane
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There is still no indication when the FCC will approve the eligible services list and the Form 471 window will open approximately 60 days later.
Technology Plans
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SLD Reminders
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On the SLD website they list 5 criteria that technology plans must cover. Even if the state approves a technology plan, an applicant may get denied if that plan doesn't cover all five SLD criteria. The approved technology plans must state goals and objectives, professional development, needs assessment, budget and evaluation
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Service providers can provide their customers with ‘technology neutral assistance or advice'
Form 470
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The SLD is reminding E-rate applicants to post their Form 470's now and not wait until the Form 471 window opens. Form 471's posted the last few days will receive more scrutiny to ensure that the competitive bidding was conducted properly
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On the 2006 Form 470 even if an applicant has to conduct an RFP to comply with their state and local procurement regulations, applicants still need to provide details of the requested services on the corresponding Form 470
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Applicants should make sure the correct category of service is checked on the Form 470 or PIA may move the service to the correct category or the funding will be denied.
Contracts
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In order for an applicant to consider multi-year contracts or voluntary extensions, that information needs to be provided on the Form 470 or RFP
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Both parties need to sign and date contracts. If a multi-year contract was signed before 10/13/2004 and only had applicant signature, applicant should get the signature of service provider now to get in compliance with this regulation
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State Master Contracts
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Single Winner – Applicants do not need to justify selection of the winning bidder
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Multiple Winners – Applicants must be able to document why they selected the winning provider off the master contract
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Multiple Award Schedule – Applicants must be able to document why they selected the winning provider off the multiple award schedule
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Only Terms and Conditions – These contracts do not meet FCC contract requirements
Item 21 Attachments (Description of Services)
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Applicants are encouraged to work with service provides to craft their Item 21 attachments and share them with their service provider. If service providers have their customers Item 21 attachments it could speed up the processing of invoices. The SLD needs to make sure the products and services delivered match up to what was actually requested.
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Service providers are encouraged to break out eligible and ineligible services in order for applicants to comply with the 30% rule. If more than 30% of an FRN is for an ineligible service the whole FRN will get denied.
Documentation
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Retain ALL documentation for a five year period
Form 486
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The SLD encourages E-rate applicants and their service providers to discuss together when the service start date should be: installation date versus shipping date. The SLD is working on guidance they will post to their website
Invoicing
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Applicants can request an "invoice check" on every FRN if they wish, but when the SLD sends them a service certification they need to respond quickly to ensure the service provider gets paid in a timely manner
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Applicants need to ensure they pay the non-discounted portion of the service within 90 days of service or the FCC will consider you in non-compliance
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Service providers need to forward the Bear checks to their customer within 20 days of receipt
Eligibility
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The SLD stressed the best way to think of the Eligibility Services List is hat everything is "conditional" and should be based on where, by whom and how the service or product is being used
New Tools
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The SLD is encouraging E-rate applicants to use the Online Item 21 Attachment tool to file their description of services. This is the second year and the SLD would like more applicants to use the system.
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Block Four Bulk Upload – Applicants will be able to upload their Form 471 Block 4 information into a Form 471 as opposed to creating it in the online system. It will need to be in CSV Format and the SLD envisions this would be useful for large school districts
PIN
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A couple of weeks before the Form 471 window opens the SLD will send new PINS to all 2005 Form 470, 471 and 486 form signers and all Form 470 2006 signers in order to assist with online certifying
Program Integrity Assurance and Selective Reviews
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Applicants can request extensions, however, it is critical that information is completely accurate because the SLD may not seek clarification and will make a determination on the information you provided
Two in Five Rule
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Applicants can only request internal connections for specific sites twice every five years. If they receive a commitment and do not go ahead with the project they should file a Form 500 to cancel that FRN. If they do so this rule will not be in effect for those sites
Consortia
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Consortia leaders need to get letter of agencies (LOAs) from their members and the letter can not just say for "all E-rate eligible services", but specifically need to say the type of service
Education Services Agencies (BOCES)
The SLD will post guidance and will require ESA's to be careful to avoid conflicts of interests as some ESA's are applicants and service providers at the same time
Top Denials
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30% rule – If an FRN is submitted where 30% or more of the FRN is for an ineligible service or product the whole FRN will be denied
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Contracts not signed – Contracts need to be signed and dated by both parties before the Form 471 window closes
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Consortium – The consortium leaders needs to retain proper authorization for their consortium members before the Form 471 is filed
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Insufficient Documentation – When applications are reviewed and the SLD asks for further information or documentation it is critical to be responsive to those requests
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No corresponding Form 470 – Month to Month and Tariff Services need to have Form 470's posted every year and if applicants wish to consider multi year or contracts with voluntary extensions, the Form 470 or RFP must reflect that.
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Competitive bidding – The applicants bidding process was not fair, open or competitive
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28 day rule – Once a Form 470 is posted to the SLD website applicants need to wait 28 days before contracts are signed. Applicants are giving an allowable contract date on their Form 470
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Invalid Telecom Provider – Applicants will request telecom service from a service provider who is not an eligible telecom provider. Applicants can confirm if their service provider is an ETP by doing a SPIN search on the SLD website
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Certifications – Form 470's not certified or certified late
