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What Documents Should I Keep?

Back to the New Basics

Schools and Libraries Division

Washington, DC • Orlando • Boston • New Orleans • Cleveland • San Francisco • Phoenix

September/October 2007

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Overview

Document Retention Rules

The Top Five “Missing” Documents

USAC Tips & Tools

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Retention Rules

How long should you keep your documents?

A. Until I run out of office space.

B. Five years.

C. Period of five years after the last day of service delivered for a particular FY.

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Retention RulesAnswer is C.

Period of five years after the last day of service delivered for a particular FY

Effective in FY 2004

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Retention RulesExamples:

Application Fund Year

Application Commitment Year

Keep Documents At Least Until

2003 Committed in FY03 Follow your state’s document retention rules

2001 Committed in FY06 Keep at least until 2011

2005 Committed in FY05 Service delivery extension in 2006

Keep at least until 2011 unless other extensions are requested

2004 Committed in FY04 RFCDL issued in 2007

Keep at least until 2012 unless other extensions are request

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Retention Rules

Who should retain documents?

A. Applicants

B. Service Providers

C. Consultants

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Retention Rules

Answer is A & B. “…our rules to require both applicants and

service providers to retain all records related to the application for, receipt and delivery of discounted services …”

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Retention Rules

USAC will ask to review documents:

Compliance review (PIA, CIPA, Invoicing, COMAD, etc.)

Audits

Site visits

Appeals

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Retention RulesReasons to keep good records:

To ensure applicants & service providers comply with program rules

Protect applicants & service providers in the event of disputes

Prepare appeals Audits (E-rate and applicant internal audits) Archive for successors Prevent waste, fraud and abuse

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Retention Rules

Consequences of “poor” recordkeeping

Non-compliant audit findings FRN modified or denied Invoice rejected Funds COMAD/RIDF Heightened Scrutiny application review Red Light status

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Missing Documents

Top 5 Missing Documents1. Discount verification (NSLP, survey, etc.)

2. Asset listing not maintained or updated

3. Signed and dated contracts

4. Consultant agreement or LOA

5. Bid evaluation/ Award schedule

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Missing Documents

Facts & Figures At the time of the initial visit:

63% IPIA Audit Beneficiaries and 40% of Site Visit applicants were missing documents in 2007

As of June 2007, 97% of Site Visit applicants are aware of FCC documentation requirements

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Tips & Tools

USAC Tip: Maintain an “E-Rate Binder”

– Binder or filing system housing copies of documents or document location

– Can be organized by FY, BEN, or Application

– Paper or electronic filing system

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Tips & Tools

USAC Tool: USAC E-Rate Binder Table of Contents

– Records retention guide– Contains a list of key documents commonly

requested during programmatic reviews, Site Visits and audits

– Headings are organized by forms, letters, programmatic reviews, change requests, and invoicing

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Tips & Tools

USAC E-Rate Binder Table of Contents

– Downloadable Table of Contents Guide – Downloadable Table of Contents (Word

document preformatted for Avery© Ready Index 10)

– Located in USAC web site Reference Area– Hyperlinks to USAC web site Reference Area,

samples & checklists

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Tips & Tools

USAC Forms

USAC Letters

Technology Plan & Approval Letter

Competitive Bidding, Vendor Evaluation & Contracts

PIA Review

USAC Table of Contents Sections

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Tips & Tools

CIPA (Children’s Internet Protection Act)

Service Delivery & Inventory Management

Invoicing & Payments

Change Requests & Appeals

Miscellaneous

USAC Table of Contents Sections

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Tips & Tools

USAC Tools: Sample Documents

– “Good” or “Acceptable” documents – Resource for applicants to develop their own

documents– Located on USAC website Reference Area– Technology Plan Sample is available

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Tips & ToolsUSAC Tools: Sample Documents Service Sub Request

Income Survey for Discount Calculation

Bid Evaluation Matrix Technology Training Sign In Sheet Professional Development Training CalendarLetter of Agency (Consortium)

More to Come!

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Tips & Tools

USAC Tools: Checklists

– Documents applicants can use when preparing a request or responding to USAC inquiries

– Prevents omitting information needed for preparing a request or responding to USAC inquiries

– Located on USAC’s website in Reference Area

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Tips & ToolsUSAC Tools:

Checklists

Appeals

Service Substitution

SPIN Change

MORE TO COME!

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Tips & ToolsUSAC Tips: Check your dates & signatures

– Make sure you have an applicant signed and dated contract

– Make sure the contract complies with state and local procurement rules

Keep paper copies of “e-certifications”– Websites often are updated or changed, so print out a

copy of your certification with the date Keep web addresses & e-reference material

– Websites often are updated, keep updated information on state master contracts

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Documents to Keep

USAC Forms– Filing & Certifying online

print a copy of the formretain online cert id

– Filing & Certifying paperCopy the original Maintain a copy or proof of postmark dates

– Consortium members Form 479 (Verification of CIPA compliance)

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Documents to Keep

USAC Letters– Generally are printed on colored paper– The Administrator’s official decision– Applicant & Service Provider should always

review for accuracy of:• Contact information• FRN count• Funding request amount• Funding decision

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Documents to Keep

Technology Planning & Approval Letter

– Written technology plan with the creation date

– Approved technology plan with effective dates

– Copy of the approval letter • Paper copy or• Dated screen print of the certification

– Technology plan updates

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Documents to Keep Competitive Bidding, Vendor Evaluation, &

Contracts– Maintain reference information about state

and local procurement regulations

– Bidding Notices (RFP, RFI, advertisement, etc.)

– Evaluation criteria & matrix

– Winning and losing bid responses

– Vendor and internal correspondence

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Documents to Keep PIA Review

– Letter of Agency (Consortium or Consultant)

– Signed and date contracts• Extensions, Addendums, Amendments• Board approval & board minutes• Notice of award letters

– Discount Calculation

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Documents to KeepPIA Review– Product and service documentation

• Item 21 AttachmentTip: Online submissions print detail Item 21 and

confirmation page

•Service agreements •Eligible & Ineligible Items (hardware &

software)•Network diagrams •Product description

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Documents to Keep

PIA Review – Budget & Funding Information

• Budget information should contain discount and

non-discount funds

• Grant letters, board resolutions, draft and

approved budgets

• Superintendent or School Official letter

(reasonable expectations to secure financial

resources by the time services are delivered)

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Documents to Keep PIA Review

– Entity Eligibility• Charter• Matching Records• State law or provision

– PIA review• Responses to PIA questions • Supporting documentation

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Documents to Keep

CIPA (Children’s Internet Protection Act)– Filtering documentation (purchase, installation

and use)– Internet safety policy & board approval– Actions taken to comply with CIPA in the first

funding year• Public Notice• Hearing• Minutes from the hearing or meeting

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Documents to Keep Service Delivery & Inventory Management

– What date did you receive service?

– Who received service?

– Where are the items located?

– Were the items replaced, maintained, or transferred? (if so, remember to record the new serial numbers)

Tip: Color code equipment labels by fund year and include application number and FRN on label.

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Documents to Keep

Invoicing & Payments– Invoices and customer bills– Payments

• Maintain payment records for discount and non-discount amounts for each FRN

– Reimbursements from vendors– Memorandums or correspondences– Service Certifications– Quarterly Disbursement Report

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Documents to Keep

Change Requests & Appeals– Change Requests

• Requests submitted to USAC to modify the Form 471 post-commitment (SPIN change, Service Substitution)

• Notify USAC you are transferring equipment to due school or library closing

• Service delivery and/or payment timeframes have changed

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Documents to Keep

Change Requests & Appeals– Appeals

• The appeal request submitted to the FCC and/or USAC

• Delivery receipt (Proof of postmark, fax or email confirmation)

• Supporting documentation

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Questions?