2015 Fall E-Rate Update & Training - Final - misn...

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TRIG 2015 E‐Rate Update & Training 1

November 2015

Presented by:

Ann‐Marie MapesTRIG E‐Rate Activity Project Coordinator

Michael AndrewsTRIG E‐Rate Activity Consultant



The State of E‐Rate

EPC Portal Overview

EPC Form 470

Eligible Services

Fiber Rules & Bidding

Direct BEAR Payment Process

Audit Documentation

EPC Creating Contracts

EPC DRAFT Form 471

Q&A



• E‐Rate’s Focus, Funding, Process & Procedures

Been Changing…

Changing…

Continue to Change…


• The E‐Rate Modernization goal to “simplify the E‐Rate application process” requires significant changes initially on the part of USAC, E‐Rate applicants, consultants and service providers

• Individuals new to the E‐Rate process will have both an advantage and a disadvantage due to these changes

• Expect FCC E‐Rate rule enforcement to be stepped up on an ongoing basis

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It is highly suggested that E‐Rate applicants stay current by utilizing:

• TRIG E‐Rate Support Resources

• USAC Website Resources

• State of Michigan (SOM) Website Resources

• E‐Rate Central Website Resources



Request TRIG E‐Rate coordinator support:Use: [email protected]

Previously: [email protected]

This distribution email will ensure all of the following individuals are aware of your request:

Ann‐Marie Mapes (MDE)

Michael Andrews (TRIG E‐Rate Consultant)

John Piznak (E‐Rate Central PIA Support)


Subscribe to the TRIG Weekly Update

Subscribe to E‐Rate 2‐Way Listserv: erateinfoSend an email to [email protected]

Leave the subject blank

In the body of the message enter only:“subscribe erateinfo YourFirstName YourLastName" without the quotation marks


November 3, 2015 – Wayne RESA

November 18, 2015 ‐ Kent ISD

November 19, 2015 – Shepherd

Pre‐training requirement: Participants are required to watch the EPC Video Tutorials.


Technical Assistance Webinars for EPC Account Access: http://remc.adobeconnect.com/epc/

1‐888‐398‐2342 Access code: 355 0170

10/30 10‐11 a.m.

11/6 10‐11 a.m.

11/13 10‐11 a.m.

11/20 10‐11 a.m.

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• EPC form 471 training webinars will be held once the form 471 has been released in EPC

• Anticipate form 471 and window opening to be simultaneous; anticipated early January 2016

• Anticipate 4‐6 EPC form 471 webinars



E‐Rate Glossary of Terms (revised Oct 2015)

The E‐Rate program is full of acronyms and terms that can be difficult to understand and remember. Here is the link to USAC’s E‐Rate “Glossary of Terms”:

http://usac.org/_res/documents/sl/pdf/handouts/SL‐Glossary‐of‐Terms.pdf



http://usac.org/sl/tools/news‐briefs/Default.aspx


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http://www.usac.org/sl/tools/e‐rate‐productivity‐center/default.aspx

TRIG 2015 E‐Rate Update & Training 202015 E‐rate Program Applicant Trainings I How to Use the Portal 20

EPC page on the USAC website

Log In Brings up EPC Portal

TRIG 2015 E‐Rate Update & Training 212015 E‐rate Program Applicant Trainings I How to Use the Portal 21

Glossary

FAQs

User Guides

Video Tutorials

Terms & Conditions


http://usac.org/sl/


CASH

HANDLESAC H


MDE E‐Rate: www.mi.gov/erate

CEPI Electronic Entity Master: www.mi.gov/eem

LoM E‐Rate: www.mi.gov/erateforlibraries

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Main Website: www.e‐ratecentral.com

E‐Rate Funding History:http://e‐ratecentral.com/us/stateInformation.asp?state=MI

Application Tips: http://e‐ratecentral.com/applicationTips/default.asp


Modernization Order Focus & Update


To close the Wi‐Fi gapProvide adequate cost effective broadband access via fiber to schools and library buildingsTo make E‐rate dollars go fartherTo improve administration of the programTo deliver faster, simpler more efficient applicationsTo provide a better stakeholder experience


• Level playing field for all

• Funding for C1 and C2 for everyone

• Improved administrative process

• Improved stakeholder experience

• Data Transparency

• Lower costs

• Better fund administration


Instituted a budget for schools and libraries C1 and C2 ‐ no more P1 and P2Added more data collection points Item 21 data required at application submission Electronic submission of all applicationsTarget deadline for application reviewStood up an E‐Rate Portal (EPC)


48,000 applications were processed

EVERYONE who submitted a timely application was eligible for C2 money

Enough money to fund all applications –demand did not outstrip available funds

PIA decisions were faster than the past

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Over 97% of all invoices were paid within 30 days

EPC Portal has over 17,000 users working

Over $800M of Broadband funded (100+ Mbps)


E‐Rate Discounts Have Changed

E‐Rate discounts are calculated based on a school’s approved poverty level statistic e.g. National School Lunch Program (NSLP)

E‐Rate discounts are provided on category of service:Category 1 – services to buildings, provides discounts ranging from 20‐90%

Category 2 – services within buildings, provides discounts ranging from 20‐85%

TRIG 2015 E‐Rate Update & Training 33 TRIG 2015 E‐Rate Update & Training 34


Move to one location for all program activities.

Complete and certify program forms

Obtain the status of applications

Submit requests

Receive timely reminders and notifications

Respond to PIA questions

Ask USAC questions

Improve the customer experience.

Streamline the application process.

Using the Portal

Why Move to a Portal?


All of your forms, submitted documentation, and requests will be in one location online and easily accessible.

Users can access the portal from any device (e.g., desktop computer, laptop computer, tablet, smartphone) and any browser.

Using the Portal

Advantages of the Portal

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School districts and library systems can update and store address information and other data on their individual schools and libraries. This information can then be uploaded into online forms so that you do not have to re‐enter it every year.

Consortia and statewide applicants will have a complete list of their members, and service providers and consultants will have a complete list of their clients.

Using the Portal



Applicants will no longer need a Personal Identification Number (PIN) to certify forms.

Account administrators can create as many account users as they wish, and decide which activities the users can perform (i.e., set their permissions or user rights).

Using the Portal



The EPC design is changing frequently

The security and functionality of the system are in flux

Most State E‐Rate Coordinators do not have access to most of the administrative functions within EPC

The ability to support and access much of EPC is just now being made available

No EPC library users ids were provided to test with

Feel free to question and correct this presentation if and when your actual experience exceeds our theoretical test system exposure…

EPC Portal Overview

Disclaimer

To access the EPC Portal, go to www.usac.org/sl and clickon“E‐Rate Productivity Center (EPC)” logo. You will then see the “Login” button.

Click on “I Agree” to accept the terms. Enter your email address as username.

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If first time using EPC, click on “Forgot Password”.

Enter Username and click on “Request Password Reset”.

You will receive an email with a link to reset password, but it’s only valid of 15 minutes.

Username is your email address

My Landing Page View

Click on “USAC” logo at any time to return to Landing Page.

Click on header to sort listalphabetically .

Click on name of organization to see Organization Detail page. Note: Billed Entity will appear at the top of the list.

Menu options such as “Apply Now” are also included on the Landing Page.

User Profile

By clicking on the pull‐down next to your user name, you can view your profile and change your settings. You can also edit your password , and the news you receive under the News Feed.

District Organization Detail Page

After clicking on your organization, you’re taken to the Details Page under “Records”, where you can create, add, or remove users, or click on the ellipsis for additional items.

As you move around in the system, the breadcrumb and main menu bar will show you where you are, as well as the sidemenu.

By clicking on the “Related Actions” menu, you have the option to manage users and your organization, or create an application.

“Related Actions”Menu

Please note, while under your organization's “Records” menu, if you click on “Records” from the main menu bar, you will be taken from your organization’s records to the “Records” listing at the national level. Just remember, you can return to your landing page at any time by clicking on the USAC logo.

National Level “Records”Menu

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Here is the view when selecting a school building from the list of organizations.

By clicking on “Manage Organization”, you can edit information pertaining to this specific building, such as Student or NSLP Counts.

Note: You also have the optionto provide information if thereis an annex associated with thisschool.

School Detail Page

Modify An Organization –School Detail View

View after clicking on “ManageOrganization”

From here, you can correct building addresses.

Modify An Organization ‐School Detail View cont.

You can edit the Student and NSLP counts, and then click on “Submit”.

These 4 number fields and the CEP status form the basis for the NSLP percentage

Creating NewUsers

From the landing page, click on “Manage Users” and then select organization from the list.

Click on “Create New User”

Creating NewUser

Enter User Details

Modify address if necessary. TheBilled Entity’s address is listed bydefault.

Select permissions for the newuser, which are defined on thesite.

You can assign rights per form, orchoose “Apply All”.

When done, click on “Continue”

Confirm NewUser

Confirm information and click on “Submit” and then “Yes” in the pop‐up to proceed.

The new user will receive several emails prompting them to sign in to EPC, create apassword, and accept the terms and conditions.Note: The user must accept the terms and conditions before you can modify their role.

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First Email Received by NewUser

Click on portal link, select “Forgot Password” and follow directions. The new user will receive an email with a link to create new password, and an email called “New Task: Complete Terms and Conditions.

Accepting Terms and Conditions

New user will receive the “New Task” email. Click on the link, and then initial “Accept”. Enter User Name and Password to see “Terms and Conditions”.

Scroll to the bottom of the page, and click on “Accept”

Displaying Users and Rights

Go to “Manage Users” and“Add and Remove ExistingUsers” to view user details.

Note: To remove a consultant, click on the “X” next to the user name. All other users can be deactivated, with the option to later reactive.

Removing (Deactivating) Other Users in YourOrganization

• Select “Records” located on the main menu bar.

• Click on “Users”

Enter user’s name. After locating in list, click on user name link.

Removing (Deactivating) Other Users in YourOrganization

The user profile opens. Click on “Related Actions” and then “DeactivateUser”.

Removing (Deactivating) OtherUsers in YourOrganization

Enter notes (a required field), click on “Submit”, and then “Yes” in the pop‐up to proceed.

Note: User can be reactivated by following previous “Records” menu steps . Afterclicking on “Related Actions”, you will see a link to the right to “Reactive User”.

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Click on “Manage Users” andthen select organization fromthe list.

Click on “Manage User Permissions”

Managing User Permissions

We see an explanation of the permissions available.

Use the drop‐downmenu to assign the correct permissions, and click on “Submit”.

Managing User Permissions

Modify Account Administrator

From your landing page, choose your Billed Entity organization, and then “Related Actions”.


Click on “Modify Account Administrator”


EPC allows only one user to be designated as the account administrator. To change the current administrator, uncheck the box to the left of the current user’s name, and select the new administrator. Click on “Continue”, confirm information, and then select “Submit”.

Adding a Consulting Firm

From the landing page, select your organization, and then “Related Actions”. Click on“ManageOrganizations”.

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Adding a Consulting Firm

Select “Add a Consulting Firm”. Enter search information, such as name or CRN, and click on “Search”. Choose firm, and click on “Submit”.

Note: Once the firm has been added, you can go to “Add or Remove Existing Users” to add the individual consultant.



School District

Starting the Form 470

From the landing page, click on “Apply Now”. Thenew Form 470 will open. Enter a nickname for theapplication, and click on “Save& Continue”

Note the new buttons at the bottom of the screen: “Discard Form” and “Save & Share”

Completing the Form 470

Once you save the application, the “Task” is indicated on the main menu bar

Verify the information listed. If necessary, update your profile.

Click on “Save & Continue”

EPC Form Numbers

If you start an application, and cannot complete it, go to “Tasks” located on the main menu bar, and click on form to complete.

Tasks

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Contact Information

Choose option for contact information. If “Yes”, your info will display.

If someone else will be the main contact, choose “No” and provide their information.


Choosing Category of Service

Choose the “Category of Service”

Remember, on the Form 470, you can list services from both Category 1 and Category 2


Adding An RFP

If you have RFP’s for any of the services that will be included on this Form 470, click on “Yes”.

You will then see the “Browse” option to attach the RFP file.

You can add multiple documents if necessary for both Category 1 & 2.


Choose RFP

If applicable, select the RFPs that apply to all new Category 1 services.

If you answered “No” previously to RFP’s, this screen will not display.

Click on “Save& Continue”

Adding Service Request

Click to add service request.

Click on the pull‐down,and choose the serviceyou are requesting.

Click on “Add”

Adding New Service Request

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Enter the quantity. “Units” will be determined by the function chosen. Enter number of entities served.

Click on the pull‐downs to choose “Minimum” & Maximum”capacity.

Note new questions regarding Installation and Maintenance.

Choose RFP if applicable.

Click on “Add”

Adding NewService Request

Verify information.

If you want to add additional Category 1 services, click on “Add New Service Request”

Note: If you indicated you were also including Category 2 service at the beginning of the application, you will scroll down the screen to add the Cat 2 requests.

Adding NewService Request

*Remaining portion of screen on next slide

You may add additional information in the narrative

If seeking fiber installation with special constructions charges, you may request payment plan.

If your are not adding Category 2 requests, click on “Save & Continue”

Narrative &Installment

Plans

If you choose both Category 1 and 2 when initially starting the Form 470, you will see the “Category 2” section.

Click on “Add New Service Request”

Requesting Category 2Services

Choose “Service Type” and click on pull‐down to select value.

Click on “Add”

Note: if choosing “MIBS”,the options are “Leased”or “Existing” equipment

Adding Category 2 Services

Choose “Manufacturer”. Note, the system adds the language “or equivalent”.

Enter “Quantity”, and indicate if you are seeking Installation.

Click on “Add”


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Click to add additional services.

You can also choose to “Edit” or “Remove” request.

Add a narrative if applicable.

Click on “Save& Continue”


Choose “Yes” if you’d like to add a technical contact.

You can search and add an EPC user or manually enter contact details.


Adding Technical Contact

Indicate if there are State or Local procurement requirements.

Click on “Review FCC Form 470”

Procurement Requirements

When you advance to this screen, a PDF of your Form 470 is generated.

Click on “Refresh” to view document

Review Form 470

Click to view PDF. If correct, click box to certify. If not, click on “Back” to make corrections.

If you have the authority to certify application, click on “Continue to Certification” and choose “Yes” in the pop‐up.

Choose “Send for Certification” if someone else will certify

Certifying Form 470 View of PDF

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Certifying Form

Check each box, and click on “Certify”

Receipt Notification

The Receipt Notification will appear in the “News” feed



• Category One

• Category Two

• Category Two Budgets

ESL updates:

Fiber

ISDN

Data plans

Eligible Services

Overview

Firewalls

Virtualization and cloud based functionality

TRIG 2015 E‐Rate Update & Training 96 96

Eligible Services

Category One

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Category One primarily supports broadband connectivity to schools and libraries.

Category One also supports voice service which is subject to a phase down of support as of FY2015.

This includes broadband connections to eligible locations that:

Connect multiple points

Connect eligible locations to the Internet

Services that provide basic conduit access to the Internet

Category One

What is Category One?


Fiber (Lit and Dark)

Self‐Provisioned Fiber

Wireless Service (e.g. microwave)

Satellite Services

DS‐1, DS‐2, DS‐3

Category One

Eligible Data Transmission Services and Internet Access

– Ethernet

– T‐1, T‐3, Fractional T‐1

– Cable Modem

– DSL

– ISDN

– MPLS

• Some examples include:


Starting with FY2015, voice services are subject to a 20% reduction continuing until FY2019 when all voice services are phased out.

For FY2016, the reduction to voice services is 40%.

Category One

Voice Service

Discount %FY2015

‐20%

FY2016

‐40%

FY2017

‐60%

FY2018

‐80%

FY2019

‐100%

90 70 50 30 10 0

80 60 40 20 0 0

70 50 30 10 0 0

60 40 20 0 0 0

50 30 10 0 0 0

40 20 0 0 0 0

30 10 0 0 0 0

25 5 0 0 0 0

20 0 0 0 0 0


Local, long distance, 800 service

POTS

Interconnected VoIP

Circuit capacity dedicated to providing voice service*

Centrex

ISDN

Category One

Eligible Voice Services Subject to Phasedown

• Radio Loop

• Satellite telephone service

• Shared telephone service

• Wireless telephone service including cellular voice

– Excludes data and text messaging


Circuits are subject to the voice phasedown if any portion of the circuit is dedicated to voice.

Circuits wholly dedicated to voice such as PRIs and SIP trunks are fully subject to the phase down.

A T‐1 used for voice is subject to the phasedown if any of the channels are dedicated to voice.

If there is a voice application running over a data circuit with no portion of the circuit dedicated to voice (e.g. QoS), the circuit is not subject to the phase down.

VoIP service bundled with Internet access requires cost allocation to separate the voice from the Internet charges.

Category One

Circuits and the Voice Phasedown


Eligible Services

Category Two

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Category Two includes equipment and services needed to bring broadband into and throughout schools and libraries.

Subject to five‐year budgets for schools and libraries.

Category Two includes internal connections, basic maintenance of internal connections and managed internal broadband service.

Category Two

What is Category Two?


Access points

Cabling

Caching

Firewalls

Switches

Routers

Racks

Category Two

Eligible Internal Connections

• UPS

• Wireless LAN Controllers

• Improvements, upgrades and software necessary to support eligible broadband internal connections components


As part of the E‐rate Modernization Order, broadband distribution services and equipment that can be virtualized in the cloud are eligible.

This includes virtual or cloud based functionalities so long as they support eligible internal connection functions.

For example, software virtualizing routing or switching in the cloud is eligible.

Equipment and functionalities must still be competitively bid and the most cost‐effective solution must be chosen.

Category Two

Eligible Internal Connections: Virtualized and Cloud‐Based Functionalities


Services provided by a third party:

Operation

Management

And/or monitoring of eligible broadband internal connection components

The third party may manage the school or library’s equipment or provide the equipment as part of a lease.

Category Two

Managed Internal Broadband Services (e.g. Managed Wi‐Fi)


Support for basic maintenance of eligible internal connections such as:

Repair and upkeep of hardware

Wire and cable maintenance

Basic tech support

Configuration changes

Support for BMIC is limited to actual work performed under the contract.

Category Two

Basic Maintenance of Internal Connections


Basic maintenance does not include:

Services that maintain ineligible equipment

Upfront estimates that cover the full cost of every piece of eligible equipment

Services that enhance the utility of equipment

Network management services, including 24‐hr network monitoring

On‐site technical support

Unbundled warranties

Operations and management of eligible equipment not supported as BMIC but eligible as Managed Internal Broadband Services

Category Two


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Eligible Charges

Taxes, surcharges and other similar reasonable charges

Lease fees to rent or lease eligible components

Shipping charges

Training

Installation and configuration

Installation may be provided by a third party

Miscellaneous

Miscellaneous Charges


Eligible Services

ESL updates


The Second E‐rate Modernization Order equalized lit and dark fiber.

Dark fiber special construction is now eligible both within and beyond the property line.

Modulating electronics to light dark fiber is eligible.

Due to the equalization of fiber, eligible costs for lit vs dark fiber have been removed.

ESL Updates

Eligible Category One Costs –Dark and Lit Fiber


Special construction consists of

Design and engineering

Project management

Construction of network facilities.

Special construction is limited to the one‐time costs of physically deploying new or upgraded network facilities and services required to complete that deployment.

Does not include non‐construction one‐time costs such as Network Equipment or upfront IRU payments for dark fiber.

ESL Updates

Eligible Category One Costs –Special Construction


Eligible costs for new or existing lit fiber, dark fiber and self‐provisioned broadband networks include:

Monthly charges

Special construction

Installation and activation

Network equipment (Includes modulating electronics and other equipment to make the broadband service functional)

Maintenance and operation charges.

ESL Updates

Eligible Category One Costs –Dark and Lit Fiber


Integrated Services Digital Network (ISDN) is added to the list of eligible Voice Services.

ISDN must be selected in the Voice Services category if it is being used for voice.

Data plans and air cards for mobile devices include additional explanations of eligibility.

ESL Updates

Other Category One Modifications

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Data plans and air cards for mobile devices are eligible only:

If you can demonstrate that individual data plans are the most cost‐effective option for providing internal broadband access for mobile devices or

Installing a Wireless Local Area Network (WLAN) is not physically possible.

Seeking support for data plans or air cards for mobile devices for use in a school or library with an existing broadband connection and WLAN implicates the E‐rate Program’s prohibition on requests for duplicative services.

ESL Updates

Eligibility Limitations of Data Plans


This can be accomplished by seeking and comparing bids for both WLANs and individual data plans.

• The comparison may not include likelihood of receiving Category Two support.

• Program rules require applicants to use the pre‐discount cost of the service and not the post‐discount cost when evaluating price as the primary factor.

ESL Updates

Cost Comparisons for Data Plans


Firewall protection provided by a vendor other than the Internet access provider OR priced separately is considered Internal Connections.

ESL Updates

Eligible Category Two Services ‐Firewall


Bug fixes, security patches and online and telephone‐based technical assistance still do not have to demonstrate work being performed to receive BMIC support.

Network monitoring and management functions remain eligible only as Managed Internal Broadband Services.

ESL Updates

Other Category Two Minor Clarifications


Eligible Services

Category Two Budgets


Each school or library receiving Category Two support between FY2015 and 2019 will have a five‐year budget for Category Two products and services (those that distribute broadband within schools and libraries).

Category Two products and services include Internal Connections, Managed Internal Broadband Services, and Basic Maintenance of Internal Connections.

Products and services ordered in excess of an entity’s Category Two budget will not receive E‐rate discounts.

There is no budget for Category One services (those that connect broadband to schools and libraries).


What are Category Two budgets?

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Each individual school and each library outlet or branch has a pre‐discount budget. School districts or library systems may not average their costs across multiple school or library budgets.

Non‐instructional facilities (NIFs) – including school NIFs with classrooms and administrative buildings – do not have pre‐discount budgets.

If a NIF is essential for the effective transport of information to or within a school or library, the applicant must allocate the NIF costs to the entities benefiting from the service while the costs for ineligible services to a NIF should be allocated out.


Which entities have Category Two budgets?


The pre‐discount budget for a school is calculated by multiplying the total number of students at the school by $150, with a minimum of $9,200 if the school has fewer than 62 students.

The pre‐discount budget for a library is calculated by multiplying the total area in square feet – including all areas enclosed by the outer walls of the library and occupied by the library – by $2.30, with a minimum of $9,200 if the library is less than 4,000 square feet.

Libraries located in cities and urbanized areas with a population of 250,000 or more are eligible for a budget of $5 per square foot.


How much is my budget?


Remember that the budget is PRE‐DISCOUNT.

For example, for a school with 1,000 students:

At the 85% discount rate (the maximum discount rate for Category Two), the school will have a pre‐discount budget of $150,000, but may receive E‐rate discounts of up to $127,500.

At the 50% discount rate, the school will have a pre‐discount budget of $150,000, but may receive E‐rate discounts of up to $75,000.


How much is my budget (cont’d)?


The pre‐discount budget calculation is for a five‐year period, starting with the first funding year in which you receive Category Two support.

However, you can apportion your pre‐discount budget in a manner that best meets your needs. You could spend all of it in FY2016, spend 1/5 each year, or any other combination up to your total.


What period of time does my budget cover?


Your pre‐discount budget in FY2016 is decreased based on all commitments where your entity is listed as a recipient starting with FY2015 commitments.

It could go up in FY2016 if your student count or square footage increases, or down if your student count decreases.


Can my budget change from year to year?


For existing schools: If your student count decreases in subsequent funding years, you do not need to repay the fund for money disbursed in excess of the five‐year budget in years when your student count was higher.

For new schools: If you overestimate your student count and exceed the five year pre‐discount budget based on your actual student count, you must return any funds in excess of the allowable budget to USAC.


Can my budget change from year to year (cont’d.)?

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On the FCC Form 471, you indicate how funding should be allocated among entities sharing services.

Your allocation can be:

Straight‐line (all entities share the cost equally)

Proportional (based on student count/square footage of each entity)

Specific (you specify each entity’s share)


How do I allocate costs for shared services?


Any funding commitments that included your entity as a recipient of service in FY2015 count against your pre‐discount budget for that entity.

If funding is remaining on a funding request, you can file an FCC Form 500 to return the funding to USAC.

If entities are sharing the service, we will need specific information so that we know how to apply the returned funds to specific entities.

If you need to return funds you will need to fill out a Payment Identification Worksheet.


How are services counted against my budget?



Review of fiber options available as a result of theSecond E‐Rate Modernization Order

Expanding Access to Broadband for FY 2016 and beyond

Agenda


Emphasis on providing additional flexibility for schools and libraries seeking high‐speed broadband connections.

Lack of access to broadband, especially in rural areas, and high cost of those services are major obstacles in meeting program goals.

Order designed to help close the rural connectivity gap and increase affordability of high‐speed broadband connections.

Everything presented will be in effect from FY 2016 forward.

Overview

Expanding Access to Broadband

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New Options for E‐rate funded special construction for new fiber*.

Cost of deploying new fiber (as opposed to ongoing cost of leasing or maintaining/operating fiber.)

Provides up‐front capital that will reduce monthly recurring cost to applicants.

Previously only available for lit services, now also available for dark fiber and self‐provisioned fiber.

* Potential exists for special construction of a non‐fiber network

What’s New?



Regardless of the services sought (including new fiber options), E‐rate rules continue to require that applicants:

Conduct fair and open competitive bidding process.

Selecting the most cost‐effective bid.

What Stays the Same?



Old Requirement

• Applicants had to amortize large, up‐front construction costs in excess of $500,000 over three years.

Amortization of Up Front Special Construction Costs


New Requirement

• E‐rate will now pay the full discounted share of up‐front special construction charges in the first year.


Previous Requirement:

• Applicants had to pay their share of non‐recurring cost of special construction within 90 days of the start of service.

Installment Payments for Special Construction Costs


E‐rate will now allow:

• Applicants are allowed to pay their share of those up‐front costs in installment payments over up to four years.


Applicants interested in an installment payment plan option must indicate their interest on FCC form 470

Service providers are under no obligation to offer such installment payment options to applicants.

Installment Payment Plan of Up Front Special Construction Costs



Applicants can receive funding for Category One special construction costs incurred up to six months prior to start of funding year.

Occurs after selection of service provider via FCC Form 470

Actual service start date is on or after July 1 the funding year.

Can get one year extension due to unavoidable delays.

Special Construction Projects


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Beginning FY 2016, funding for lit and dark fiber has been equalized.

Dark fiber leases allow the purchase of capacity separate from the service of lighting the fiber.

Equalizing Dark and Lit Fiber



Old Dark Fiber Rule

• E‐rate would only pay special construction costs up to the applicant’s property line.

• Modulating electronics not eligible in Category One.

Equalizing Dark and Lit Fiber


New Dark Fiber Rule

• E‐rate will now pay special construction costs beyond the applicant’s property line.

• Modulating electronics to light dark fiber will be eligible for category one support.


Applicants that seek bids for dark fiber must also seek bids for lit fiber service.

Before selecting a dark fiber solution, applicants must fairly compare dark fiber with other available options to ensure the most cost effective option is chosen.

Requirement to Compare Dark and Lit Fiber



To the extent an applicant intends to seek support for equipment and maintenance costs associated with lighting newly leased or purchased dark fiber, the request for support for those services must be included in the same application with the dark fiber lease.

Applicants will not receive support for excess capacity and may only receive special construction support for dark fiber lit in the same funding year.

Requirement to Compare Dark and Lit Fiber (continued)



Applicants may seek E‐rate support for self‐construction of their own high‐speed broadband networks, or portions of such networks, when self‐construction is the most cost‐effective solution.

Applications for self‐provisioned networks should reflect the total cost of ownership, including special construction, equipment, and maintenance and operation.

Self‐Construction of High‐Speed Broadband Networks



Requirements:

Applicants soliciting bids for a self‐provisioned network must also seek bids for lit service on the same FCC Form 470, unless the applicant already posted for broadband services for this same funding year and received no bids.

Applicants must compare the cost of lit fiber service to the total cost of ownership over the life of the facility for self‐provision option.

Applicants seeking dark fiber or self‐provisioning must upload an RFP in new the FCC Form 470 system.

Self‐Provisioned Fiber Networks


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• Be as specific as possible to enable a meaningful comparison of lit, dark, and self‐provisioned options.

• Include estimated bandwidth sought. Terms such as “as needed” or “district‐wide” are not sufficient descriptions of the quantity or capacity of the products and services requested. Applicants may identify a range, such as 100‐200 Mpbs.

• Include expected growth rate in bandwidth demand over the relevant time period and seek pricing for the increased level of bandwidth over time.

Guidance on RFPs



• Include any state or local procurement requirements.

• RFPs must be available for at least 28 days.

• Fiber RFPs take time to write.

• Potential bidders need more time to respond to these bids.

• Start early!

Guidance on RFPs



Old Rule

• Applicants must conduct fair and open competitive bidding process.

• Applicants had to select the most cost‐effective service provider.

• Price of eligible products and services must be the most heavily weighted bid eval factor

Competitive Bidding Considerations


New Rule

• Applicants must conduct fair and open competitive bidding process.

• Applicants had to select the most cost‐effective service provider.

• Price of eligible products and services must be the most heavily weighted bid eval factor


Comparing different fiber options:

Determine a reasonable, defensible period of time for the comparison, based on their anticipated use of the assets. Applicants that choose to self‐provision or purchase the equipment required to operate a dark fiber IRU may expect to recover their costs in 5, 7, 10, or even 20 years.

Identify a comprehensive and specific total cost for each option.




Comparing different fiber options:

Applicants must be prepared to explain their assumptions, such as expected useful life.

Divide total cost of IRU or self‐provisioned fiber by number of years to determine annual cost.

Compare to annual lit fiber charge.

Applicants cannot resell service.

Applicants must secure access to necessary resources.




USAC will focus on verifying the cost effectiveness analysis explained above in the bid evaluation phase.

When applicants add up the total anticipated costs over a reasonable, defensible time period, the most cost effective option will be clear in most cases.

Cost Effectiveness


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For shared or multi‐purpose fiber build projects, costs necessary to get the fiber to the school or library are eligible.

E‐rate will not fund capacity beyond what the applicant needs in that funding year. Applicants may not seek E‐rate funding for fiber that the applicant is not using.

Example: Applicant needs 12 strands of fiber. Construction is for 96 strands. If no plans for other customers, only remove cost for 84 additional strands, but all other special construction costs would be fully eligible.

Cost Allocation



Providing an incentive for state support of last‐mile broadband facilities.

E‐rate match of up to 10% of the cost of construction will be provided to match state funding for special construction charges for high‐speed broadband connections.

E‐rate match also provided for Tribal schools and libraries when matched by state, Tribal government, or federal agency.

Additional Matching Funds for Fiber Builds




Current Process

Future Process

Timeline

FCC Form 498 Information

Common Invoicing Mistakes

Deadlines

Agenda

Agenda


Applicant fills in Block 1, Block 2 – request information

Applicant fills in Block 3 – certifications

Applicant obtains service provider certification on Block 4

Applicant submits BEAR

Paper mailed to Kansas

Online – automatic after service provider certification

FCC Form 472 ‐ Currently

Current Process

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USAC processes invoice

USAC approves funds

USAC sends BEAR Notification Letters 2 weeks prior to funds being paid

USAC electronically sends funds to service provider

Service provider passes funds to applicants

Must send funds within 20 business days

FCC Form 472 ‐ Currently

Current Process


Online Only ‐ via EPC Portal

Paper BEAR will be discontinued July 1, 2016

Certifications to change

No longer require service provider certification

May require some information during invoice review

Applicants paid directly via electronic transfer

FCC Form 472 – Changes – beginning July 1, 2016

Future Process


Applicant logs into EPC portal to access invoice

Applicant fills in information: SPIN

Applicant fills in request: FCC Form 471 number, FRN, Dates, Amounts

Applicant reviews and certifies information

Applicant submits BEAR – only online

No service provider Certification Required

FCC Form 472 – Changes – beginning July 1, 2016

Future Process


Payments scheduled twice a week when invoice approved – no longer two week delay for service provider notification

BEAR payments only via electronic transfer to applicant

Billed Entities will be paid directly to bank account

Bank account information will be required

Direct Payment – beginning July 1, 2016

Future Process


Future Process

Applicant fills out BEAR, sends to provider

Provider signs BEAR‐returns to applicant

Applicant sends BEAR to USAC

USAC approves funds

USAC notifies providers

USAC sends funds to provider

Provider forwards funds to applicant

Current Process Direct Applicant Payment Process – beginning July 1, 2016

Applicant fills out BEAR online

USAC approves funds

USAC sends funds to applicant’s bank account


Banking Information collection available from applicants after new FCC Form 498 released

Direct Payments begin July 1, 2016

Direct Payment

Timeline

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Contact information section

Applicant identification section

Banking information section

Direct Payment – What You Need on FCC Form 498



Identifies contacts for financial information

Company Officer

An officer is a person who occupies a position authorized by the school, district or country, and consortium applicants, and would typically be a Superintendent, Assistant Superintendent, Principal or Assistant Principal, County or District Administrator, or state education department leads

Authorized to certify that the data set forth in the FCC Form 498 is true, accurate, and complete

Direct Payment – What You Need:Contact Information section



Identifies contacts for financial information

General Contact

This individual will be able to retrieve the FCC Form 498 information on file with USAC as well as be given access to USAC’s on‐line filing system

This person will also be able to input new FCC Form 498 ID data for Company Officer certification

Direct Payment – What You Need:Contact Information section



Company Officer

Cannot be a Consultant

Bank Account

Cannot be owned by a Consultant

Direct Payment – What You Need: Contact Information section



Federal Employer Identification Number (EIN/TaxID)

Dun and Bradstreet “Data Universal Numbering System” number (DUNS or D‐U‐N‐S)

DUNS, is a proprietary system developed and regulated by Dun & Bradstreet (D&B) that assigns a unique numeric identifier, referred to as a "DUNS number" to a single business entity

Direct Payment – What You Need: Applicant Identification Section



Dun and Bradstreet Number (DUNS)

DUNS Number assignment is FREE for all businesses required to register with the US Federal government for contracts or grants

Before applying, check to see if your organization already has a DUNS number



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Dun and Bradstreet Number (DUNS)

You can search for your organization, by name, through D&B’s online D‐U‐N‐S database: https://iupdate.dnb.com/iUpdate/companylookup.html or call (866) 705‐5711 to speak to a representative

If your organization does not have one, you can apply online through Dun & Bradstreet’s website: http://www.dnb.com/get‐a‐duns‐number.html (This is neither an FCC nor a USAC website)




You will need all of the information listed below to obtain a DUNS number:

Name of organization

Organization address

Name of the chief executive officer (CEO) or organization owner

Legal structure of the organization (e.g., corporation, partnership, proprietorship)

Year the organization started

Primary type of business

Total number of employees (full and part‐time)

Direct Payment – What You Need: Obtaining a DUNS Number



FCC Registration Number (FRN) or (CORES ID)

Note – this is a number that you also enter on each FCC Form 471 that you file

It should not be confused with the “Funding Request Numbers” (FRNs) that applicants fill out on their FCC Form 471 applications




Name of Financial Institution

Financial Institution Account Number

Checking account number

ACH Financial Institution Transit Number ( 9 digits)

Routing Number

Direct Payment – What You Need: Bank Information Section



Billed Entities

BEN (Billed Entity Number)

Name

Enter as many as are reimbursed thru this bank account number

Direct Payment – What You Need: Bank Information Section



Invoice Submission

Services not yet delivered – (Commitments are NOT simple grants)

Services billed for eligible costs – not for total FRN

Services not eligible

Service provider not on FCC Form 471

Services billed to party not on FCC Form 471

Services not listed on application line item (Item 21)

Services delivered outside funding year

Services delivered to location not on FCC Form 471



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Service Certifications

Customer bill does not identify services

Items on customer bill not found on Item 21

Service provider not certified

Service substitutions not requested

Services delivered outside contract dates

Name on bill does not match FCC Form 471




Payment of beneficiary portion

Proof of payment not returned when requested

Check does not demonstrate clearing bank

Check already shows payment for another invoice

Documents not from bank website

Payment validation not verified by applicant




Automatic

Late FCDL, Appeals

SPIN Changes, Service Substitutions

March 1 key date

Extends until September 30 of the following yearManual

Must be filed on FCC Form 500 – Contract Date also

Will be requested to provide a reason

By September 30 for non‐recurring services

Service Delivery Extension

Deadline Extensions


Invoice Filing Deadline

Invoices must be submitted to USAC

(1) 120 days after the last day to receive service, or

(2) 120 days after the date of the FCC Form 486 Notification Letter, whichever is later – 54.514 (a)

Invoice Extension

Deadline Extensions


Invoice Deadline Extension

In advance of the deadline pursuant to paragraph (a), service providers or billed entities may request a one‐time extension of the invoicing deadline from USAC

USAC shall grant a 120 day extension of the invoice filing deadline, if it is timely requested – 54.514 (b)

Invoice Extension

Deadline Extensions


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Requests for Proposals

Copies of bids received (winning AND losing)

Documentation supporting the selection of the service provider

E.g., individual evaluation score sheets, summary score sheets, bid meeting notes, meeting sign‐in sheets, etc.

Correspondence with potential bidders, if any

Sufficient Documentation

Requests for Services


Auditors determine whether the Beneficiary’s school(s) is recognized on the State’s Department of Education (DOE) website

If the school is not identified on the DOE website, the Beneficiary may provide:

A letter from the DOE recognizing the school as meeting the State’s definition of elementary or secondary education

Other support, such as certification of accreditation, school charter, by‐laws, etc. demonstrating the school meets the State’s definition of elementary or secondary education


Eligibility for Schools, School Districts, or Consortia Containing Schools or School Districts


A network diagram demonstrating Non‐Instructional Facilities receiving Category 2 funds are essential for the transmission of data to educational buildings

Documentation demonstrating residential schools serve unique populations, as required by the FCC’s Sixth Report & Order

Schools on Tribal landsSchools that serve children with physical, cognitive, and behavioral disabilitiesSchools that serve children with medical needsJuvenile justice schools, where eligibleSchools with 35 percent or more students eligible for NSLP


Eligibility for Schools, School Districts, or Consortia Containing Schools or School Districts (cont.)


Documentation demonstrating the library is eligible in accordance with the Library Services & Technology Act (LSTA)

Documentation demonstrating the library’s budget is separate and independent of a school

If a budget is not available, documentation demonstrating the library’s sources of revenue are independent of a school


Eligibility for Libraries or Consortia Containing Libraries


Documentation demonstrating the Beneficiary is operating as a not‐for‐profit

IRS determination letter

Federal Form 990 return

Audited financial statement footnotes identifying the Beneficiary’s tax‐status


Eligibility for Schools, School Districts, and Libraries

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For schools, school districts, and consortia containing schools or school districts, student enrollment reports supporting the number of students listed in the FCC Form 471

For libraries and consortia containing libraries, square footage floor plans as submitted to the LSTA


Category 2 Budgets


Documentation supporting the enrollment data and NSLP eligibility listed in the FCC Form 471

Do not rely on the State to maintain the NSLP data

If the data maintained by the State contains data updated from a date other than the date used for completing the FCC Form 471, the auditor will rely on the State’s revised data if the Beneficiary did not maintain the original documentation, which could produce a lower discount rate


Discount Calculations


Fixed Asset Listing (FAL), including the model, installation date, and location of the equipment

Delivery receipts, if available

Floor plans for wiring and cable drops

If equipment is non‐operational, documentation demonstrating the Beneficiary has the necessary resources to make effective use of the equipment (e.g. repair and maintenance requests or agreements)

If equipment has been uninstalled or removed, documentation demonstrating why and current location


Category 2 Equipment


Contract, including the list of equipment to be maintained with BMIC funds

FAL, including the model and location of the equipment maintained

Documentation, such as maintenance logs, demonstrating the maintenance was performed




Documentation demonstrating an Internet filter was in place during the funding year audited

Copy of the filter log

Service provider bills for the purchase and/or renewal of the filter along with proof of payment

Copy of the Internet Safety Policy (ISP), or Acceptable Use Policy (AUP)


CIPA


Documentation demonstrating a public hearing was held to discuss the ISP or AUP with the public

E.g., Meeting minutes

Documentation demonstrating a public notice was posted prior to the public hearing to discuss the ISP or AUP

The public notice should specifically state the ISP or AUP will be discussed


CIPA (cont.)

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If the Beneficiary’s non‐discounted share has not been paid in‐full, copy of the budget demonstrating funds have been budgeted to pay the non‐discounted share

Documentation demonstrating training has been provided to personnel to properly use the services

Documentation demonstrating appropriate equipment and software have been secured to use the services


Sufficient Resources


Copies of service provider bills

Proof that the Beneficiary’s non‐discounted share has been paid

E.g., Cancelled checks, bank statements, accounts payable history

Reconciliation between the eligible services billed and the services invoiced on the BEAR

Documentation demonstrating the reimbursement or credit for the funded services has been received


Services Received


Ensure procedures are designed to protect and maintain documentation in the event of employee turnover

Do not rely solely on a third‐party to maintain documentation (e.g., the State to maintain NSLP data)


Avoid Common Findings –Lack of Documentation


Residential area does not serve a unique population, as defined by the FCC’s Sixth Report & Order

No allocation of use, such as numbers of floors served, square footage served, bandwidth utilized, etc.

E‐rate funds supported Pre‐Kindergarten (Pre‐K) students in a state where Pre‐K students were not eligible


Avoid Common Findings ‐Eligibility


No public notice made to discuss the Internet Safety Policy (ISP) or Acceptable use Policy (AUP)

Public hearing to discuss ISP or AUP was not held

ISP or AUP does not adequately address the elements required by CIPA

E.g., policy restates rule but does not address how students are monitored and protected


Avoid Common Findings –CIPA Violations


Did not select the most cost‐effective service provider

Price criteria included ineligible services

No support why a bid was not considered

Cost of service was substantially more than other bids for comparable services and not cost‐effective

FCC 03‐313, 18 FCC Rcd 26406 (2003), at 53 and 54

Evaluations were not conducted in accordance with the RFP requirements


Avoid Common Findings –Competitive Bidding

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Beneficiary did not pay its non‐discounted share within 90 days of service

No evidence of bill disputes, late receipt of bills, etc.


Avoid Common Findings –Services Billed by Service Provider


SLP was invoiced for ineligible services

Invoice did not exclude ineligible services

Services invoiced do not agree to the service and/or quantity in the Item 21 Attachment

Services used for ineligible purposes

Invoice did not allocate and remove the ineligible portion of services


Avoid Common Findings –Services Invoiced to SLP


Equipment not installed or non‐operational

Beneficiary did not notify SLP of equipment that was transferred within three years of installation

Lack of documentation demonstrating that BMIC services were performed

Insufficient or inaccurate Fixed Asset Listing

See asset register example at http://www.usac.org/_res/documents/sl/pdf/samples/samples‐checklist‐inventory‐list.pdf


Avoid Common Findings –Category 2


Information regarding audits is located on USAC’s website at http://www.usac.org/sl/about/program‐integrity/bcap.aspx

Samples and examples of various documents are located on USAC’s website at http://www.usac.org/sl/tools/samples.aspx

Additional Resources

Additional Resources


Prototype - Subject to Change

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Prototype - Subject to Change


Draft Screen Shots of New Form 471THESE ARE LIKELY TO CHANGE AND ARE BEING PROVIDED TO SHARE THE LOOK AND FEEL OF THE NEW FORM 471 INSIDE

THE EPC PORTAL


Create your own application nickname here.

Basic Information = Old Block 1. Information is taken from EPC Profile


Contact Information


Select Category of Service (C1 or C2) – Can Only Choose One Option 471 Category 1 Example


Category 1 Category 2

Select Category of Service (C1 or C2) 471 Category 1 Example

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Old Block 4 – Discount Calculations and Recipients of ServiceEntities, Enrollment and NSLP information imported from EPC Portal.

If necessary, make changes and add entities in EPC portal.

All of this information is “hard coded” from EPC.


Detailed Student Count/NSLP information


Old Block 5 – Funding Request. First task is to assign a nickname to the FRN.

Nickname link (hard to read)


Nickname and Service Type Selection

Choices here are either:Data Transmission and/or Internet Access ORVoice Service


NEW – Associate a Contract. If contract information is uploaded in EPC Portal, select from there. If not, go to EPC Portal and input information

See Separate Slides on EPC Create Contract

Associate a Contract


Detailed Contract Information for FRN

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Narrative Explanation of FRN

Text Box for you to enter description about FRN.


Revised Questions to Ask About Purpose of C1 FRNs


Specific Information about each Line Item (similar to FY 2015 Form 471)


Firewall Protection Question / Questions about whether Connection is Directly to a Building or Supports Service to a Building


Old Block 5 – Price Information for each FRN Line Item Note that the Form asks for Total Costs & Ineligible Costs.

Eligible Monthly Cost is a computed value – similar to FY 2014 and prior years)


Completed FRN Calculations

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Manage Recipients – Identify Recipients of Service for Each Line Item


471 Category 2 Example Note that the Nickname given to the 471 is “Routers”


Select Category 2 Type of Application

Hard to read: Button says Category 2


Old Block 4 – Discount Calculations and Recipients of ServiceLike Category 1, Entities, NSLP and Enrollment is imported from EPC

Make data corrections, revisions and additions in EPC


Funding Request – Old Block 5Assign a FRN Nickname


FRN Nickname and Service Type for C2 FRN

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NEW – Associate a Contract. If contract information is uploaded in EPC Portal, select from there. If not, go to EPC Portal and input information


Narrative Description of C2 FRN


Old Block 5 – Item 21 Details per Line ItemType of Internal Connection / Type of Product / Quantity / Make Model / Leased? Y/N


Error Messaging When Fields are Left Blank


Old Block 5 – Price Information for each FRN Line Item


Block 5 – Link Line Item to Recipients of Service

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Manage Entities when Less Than All Entities Receive Service -Costs Shared Equally Among Entities


Cost Allocation for Single School (formerly known as “Manage Entities”)


Single FRN Line Item CompletedCould add more FRN line items by clicking Add New FRN Line Item


Completed FRNCan add new FRN (Add Funding Request) or Continue to Certification


Tasks Toolbar - Where to Re-Start Incomplete Form to finish


471 Certification

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Once all of the Certification boxes are checked, click Certify to Submit/Certify Form


Certification Confirmation Screen after Clicking Certify


471 RAL Appears in News Feed



You will receive a follow up email with a link to a survey regarding today’s training. Please provide us with feedback so that we can meet your needs.

If you want to take the survey now, go to http://tinyurl.com/q4rcyq9

The email will also contain a link to today’s presentation

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Request TRIG E‐Rate coordinator support:Use: [email protected]

Previously: [email protected]

This distribution email will ensure the following individuals are aware of your request:

Ann‐Marie Mapes (MDE)

Michael Andrews (TRIG E‐Rate Consultant)

John Piznak (E‐Rate Central PIA Support)


Please use [email protected]

Subscribe to the TRIG Weekly Update

Subscribe to the E‐Rate Listserv: erateinfoSend an email to [email protected]

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In the body of the message enter only:“subscribe erateinfo YourFirstName YourLastName" without the quotation marks


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