Technology IS Infinity! YOUR GUIDE TO TAMING THE EPC MONSTER AND OTHER BEASTS Presented by AL ROSSI LAURA SASAKI with FRED BRAKEMAN BRITTANY MOSQUEDA TODAY’S TOPICS USAC 1. E-RATE - OVERVIEW AND UPDATES 2. EPC – THE EVER-CHANGING PORTAL 3. E-RATE COMPLIANCE 4. CATEGORY 2 & BUDGETS 5. ADVOCACY 6. QUESTIONS SLD FCC Technology IS Infinity! OVERVIEW & UPDATES Keeping you in the know E-RATE ELIGIBLE SERVICES CATEGORY 1 CATEGORY 2 Connectivity to the building Connectivity within the building • Voice Services - Subject to phasedown of 20% per year starting in 2015-2016, fully effective in 2019-2020 • Wi-Fi (managed, owned, or leased), Licensing for APs, and Controller Systems • Internet Access • Switches, routers, cabling (copper and fiber), racks, and UPSs • Digital Transmission Services • Basic Maintenance of Eligible Systems • Software supporting each of the components on this list used to distribute high-speed broadband * Complete Eligible Services can be found at http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db1005/DA-17973A1.pdf E-RATE DISCOUNT MATRIX E-RATE PROGRAM UPDATES STATE OF THE FUND • FCC Commissioner Pai confirmed for second term on Commission and as Chairman on October 2, 2017 • $3.99 billion annual cap, indexed for inflation • $1 billion target for Category 2 • • Adjusted to $153.47/per student or $9,412.80 minimum Currently in evaluation phase for future modernizations to the Program E-RATE PROCESS Description of Services Requested FCC Form 470 & Receipt Notification Letter (RNL) First appeal to USAC Competitive Bidding 28 Day Minimum E-rate Funding Request FCC Form 471 & Receipt Acknowledgement Letter (RAL) If denied If denied Application Review & Funding Commitment Decision Letter (FCDL) Start of Services Notification FCC Form 486 Reimbursement FCC Form 472 (BEAR) or Form 474 (SPI) California Teleconnect Fund (CTF) Then appeal to FCC. CALIFORNIA TELECONNECT FUND (CTF) ABOUT CTF CTF provides up to 25% off voice services and 50% for broadband on select communications services to schools. • One-time application - schools must be approved to receive discounts http://www.cpuc.ca.gov/General.aspx?id=4095 • Discounts • Only after E-rate discount is applied on bills • Must be requested on any new services • Must be requested when moving to upgraded services with new BTNs CALIFORNIA TELECONNECT FUND (CTF) DISCOUNT CHANGES CTF discounts will be equal to the E-rate subsidy, up to 50% • Broadband • If E-rate discount is lower than 50%, the lower discount will apply e.g., an applicant with an E-rate discount of 40% will now receive a CTF discount of 40% • Voice services • If E-rate discount is lower than 0%, applicants will receive 25% CTF discount • Districts at 10% E-rate on remaining voice (18-19), will receive a 10% CTF discount for that year Technology IS Infinity! EPC The ever-changing portal E-RATE EPC BEST PRACTICES & THINGS TO KNOW Central point of all E-rate filings and communications • USAC is working on changing the front end interface, including navigation changes Keep list of users updated • Ensure that your consultant or primary user is a “full rights” user • Locking • NSLP (free and reduced numbers) • • • These may be locked for editing in early 2018 • Any site changes also locked When working with a consultant, be sure to coordinate any changes with them E-RATE EPC ISSUES • • • Bundled Internet Services (Form 470) • USAC is indicating that applicants applying for bundled Internet access and transport – unless specifically looking for a non-fiber solution – must also select lit fiber and standalone ISP service on their Form 470. If not, the application will be denied. (e-mpa) • Note: The transport option does not refer to fiber – use lit fiber option Forms disappearing during filing window • Refiling of applications • RAL corrections to cancel applications Not receiving notice of changes - if item is submitted by a vendor or another consultant, notification will go to the person who created or submitted information, instead of EPC administrators E-RATE EPC ISSUES • Not having the same capabilities for all FYs. (e.g., SPIN changes for 2017) • No ability to cancel RALs, file BEARs (in the legacy system), IDERs • Form 486s in automatic review • FRN Status Tool not properly displaying FY2016 Authorized Disbursements Note: USAC is aware of the ongoing issues and is making efforts to correct them. Time frames for resolutions are ongoing. Technology IS Infinity! PROGRAM COMPLIANCE Making sure you know the rules E-RATE COMPLIANCE BEST PRACTICES & THINGS TO KNOW • Follow competitive bidding rules • Follow up on requests of information in a timely manner • Update information in EPC • Communicate with all District stakeholders • Reconcile discounts – follow through on disbursements with service providers • Enter into contracts/ordering new services ONLY within E-rate window • Account for ALL sites – including: • • New construction/re-opening of closed sites • Non-Instructional facilities (e.g. bus barns, district offices, IT offices) Keep up-to-date with program changes and how they affect you E-RATE COMPLIANCE ISSUES • USAC’s Fiber Inquisition Questions • Even applicants who purposely asked for special construction to be broken out, USAC is applying the standard in the 2nd Modernization Order against lit services. If special construction is included, asking how many strands of fiber is being brought in and forcing a cost allocation. • Most carriers have standard number of strands that they pull in to every site, and even if not utilized and are not lit, cost is still associated with them. • • USAC sending out notifications that they will cost allocate strands that are not going to be lit to applicant location. Fiber COMADs (Commitment Adjustment, October 2017) • Entire fiber projects– approved, funded, installed, paid for, etc. E-RATE COMPLIANCE ISSUES • C2 Form 486s in review • Voice phasedown • C2 budgets too low • PIA Reviewers not fully understanding EPC or the E-rate process, resulting in appeals for unnecessary omissions in PIA process • • Modifications made during RAL not effective on FCDLs • Bulk upload worksheet – additional tabs not being reviewed Cardinal charges – virtually any change to RFP constitutes a cardinal change, restarting 28- day clock Technology IS Infinity! CATEGORY 2 BUDGETS How to calculate and use your budget E-RATE C2 BUDGETS E-RATE C2 BUDGETS E-RATE C2 BUDGETS ELIGIBLE SERVICES LIST (ESL) • • • • • • • • • • • • • • Managed WiFi Access points used in a local area network (LAN) or wireless local area network (WLAN) environment (such as wireless access points) Licensing for access points Antennas, cabling, connectors, and related components used for internal broadband connections Caching Server Firewall services and components Switches Routers Racks Uninterruptible Power Supply (UPS)/Battery Backup Wireless controller systems Software supporting each of the components on this list used to distribute high-speed broadband throughout school buildings and libraries Basic Maintenance of the above systems/hardware Managed Internal Broadband Services * Complete Eligible Services can be found at http://transition.fcc.gov/Daily_Releases/Daily_Business/2017/db1005/DA-17-973A1.pdf Technology IS Infinity! ADVOCACY How can your voice be heard? E-RATE BE HEARD OPTIONS FOR ADVOCACY • On September 22, FCC published document seeking comments on C2 budgets • Comments were due October 23, and reply comments due back November 7 • Infinity responded to the request emphasizing the need for more flexibility on allocated monies, higher funding per student and a less obstructive process for review and approval. • E-MPA submitted with data from various applicants across US • May see piecemeal changes to the program or comprehensive Report and Order issued • Let your advocate(s) know that you want to be heard • Gather measurable data in addition to anecdotal narratives E-RATE BE HEARD AVENUES OF ADVOCACY American Institute of Architects (AIA & Golden Empire Chapter) http://aiage.org/ Association of California School Administrators (ACSA) http://www.acsa.org/ Building Industry Consulting Service International (BICSI) https://www.bicsi.org/ California Association of School Business Officials (CASBO) https://www.casbo.org/ California Chamber of Commerce https://www.calchamber.com/Pages/default.aspx California Coalition of Adequate School Housing (CASH) https://www.cashnet.org/ California Community College Facility Coalition (CACCFC) https://www.caccfc.org/ California Educational Technology Professionals Association (CETPA) https://cetpa.net/ Construction Specifications Institute (CSI) https://www.csiresources.org/home E-rate Management Professionals Association (E-MPA) http://www.e-mpa.org/ Schools, Health and Libraries Broadband Coalition (SHLB) http://www.shlb.org/ Small School Districts Association (SSDA) http://ssda.org/ State Educational Technology Directors Association (SETDA) http://www.setda.org/ Technology IS Infinity! QUESTIONS AND ANSWERS Go ahead. Ask away. Give us your best shot. Technology IS Infinity! GET IN TOUCH 4909 Calloway Dr #102 Bakersfield, CA 93312 Technology We always want to hear from YOU you! IS Infinity! 661.716.1840 email@example.com Technology IS Infinity! THANK YOU FOR COMING Have a wonderful afternoon!