Archive for November 2013

SLD News 11/15/13 – Focus: Technology Plan

 November 15, 2013

TIP OF THE WEEK: If you have not yet filed your FCC Form 486 for FY2013, you should do so promptly. Remember, however, that before you can file this form, you must have received an FCDL with a positive funding commitment, your services must have started, and you must be able to accurately make all of the certifications on the form.

Commitments for Funding Years 2013, 2012, and 2011

Funding Year 2013. USAC will release Funding Year (FY) 2013 Wave 27 Funding Commitment Decision Letters (FCDLs) November 20. This wave includes commitments for approved Priority 1 (Telecommunications Services and Internet Access) requests at all discount levels. As of November 15, FY2013 commitments total over $1.33 billion and encompass 29,393 of FY2013 applications.

Funding Year 2012. USAC will release FY2012 Wave 69 FCDLs November 21. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of November 15, FY2012 commitments total over $2.81 billion.

Funding Year 2011. USAC will release FY2011 Wave 104 FCDLs November 19. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 88 percent and denials at 87 percent and below. As of November 15, FY2012 commitments total just under $2.64 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

APPLICATION PROCESS: Technology Planning

A technology plan is a written document that describes the technologies and associated resources, both existing and planned, that will assist a school to provide educational services or a library to provide library services.

Beginning with FY2011, technology plans are required only for Priority 2 services – i.e., Internal Connections and/or Basic Maintenance of Internal Connections.

  • Under certain limited conditions, equipment may be eligible as Priority 1. However, if USAC must move a funding request for such equipment from Priority 1 to Priority 2 Internal Connections during application review because it doesn’t meet all of those conditions, a technology plan is required. Please refer to the website guidance document On-premise Priority 1 Equipment for more information.

The basic requirements of a technology plan are listed below. Note that service providers should not write or assist in the writing of a technology plan.

  • It must be created (written) before the FCC Form 470 is filed.
  • It must cover all 12 months of the funding year for which you are applying or cover at least part of the upcoming funding year and be revised before it expires.
  • It must contain all required elements (see below).
  • It must be approved by a USAC-certified Technology Plan Approver (TPA) before the FCC Form 486 is filed or services start, whichever is earlier.
  • We recommend that it not cover more than three years.

Let’s look at each of these in turn.

The technology plan must be created before the FCC Form 470 is filed.

Your technology plan must form the basis for the products and services you are seeking on your FCC Form 470 and the products and services you subsequently order on your FCC Form 471. The products and services you request on your FCC Form 470 must therefore be consistent with your technology plan. Your technology plan should be specific enough to allow you to achieve your goals and strategies for providing educational or library services, but flexible enough that you can consider different available technologies to attain those goals.

The technology plan written before the FCC Form 470 filing is not necessarily the final version of your technology plan, nor the version that will eventually be approved by your TPA. It should, however, be far enough along in its development that it can reasonably support your requests for discounted products and/or services. In addition, we recommend that you document the date that you created your technology plan since this information may be requested during review of your FCC Form 486. The creation date is defined as the date your technology plan first contained all of the required elements in sufficient detail to support the products or services requested on your FCC Form 470.

NOTE: Currently approved plans that cover at least part of the upcoming funding year and support the services that will be requested on the FCC Form 471 meet this requirement. Also, an applicant that purchases services from a state master contract and cites the associated state-filed FCC Form 470 on the funding request is not required to have a written technology plan before the state filed its FCC Form 470.

The technology plan must cover all 12 months of the funding year.

Internal Connections and Basic Maintenance of Internal Connections products and services that are received during the funding year must be covered by the technology plan. Because services are usually received during the entire funding year, the technology plan must cover the entire funding year.

If your current technology plan expires before the end of the funding year for which you are applying, you can still obtain services under that existing technology plan if it covers part of the upcoming funding year, but you must revise the plan before it expires.

The technology plan must contain all of the required elements.

The required elements are:

  • Goals and strategies for using telecommunications and information technology
  • A professional development strategy
  • An assessment of telecommunications services, hardware, software, and other services needed
  • An ongoing evaluation process
  • Budget resources [Beginning with FY2011, this element is not required.]

Your technology plan should address each of these elements at a level of detail appropriate to the size of your entity. For example, the technology plan for a one-room rural library with a single router would be much shorter and simpler than the technology plan for a large urban library with 20 branches and the internal connections equipment required to provide service to all of the branches.

The technology plan must be approved by a USAC-certified Technology Plan Approver (TPA).

USAC certifies certain entities to approve technology plans. In general, state departments of education and state libraries can approve plans. Other agencies can approve technology plans for non-public and other entities, such as diocesan schools or special libraries.

You can access a list of agencies that are certified to approve technology plans using the Technology Plan Approver Locator tool in the Search Tools section of the USAC website. You should not submit your plan to an approver who is not certified by USAC to approve plans for your state or entity type. If you cannot find an appropriate approver for your state or entity type, use the email link on the TPA locator web page or Submit a Question (choose “Technology Planning” from the Topic Inquiry menu and then “I can’t find my Tech Plan Approver on your website”) to ask USAC for help in locating an approver.

The technology plan must be approved before services start. However, because some applicants are eligible to file an FCC Form 486 early if they meet certain requirements, the technology plan must be approved before the FCC Form 486 filing if that form is filed before services have started.

The technology plan should not cover more than three years.

New technologies and services develop and change rapidly. Funding can be reduced or increased. Staff changes can lead to modifications of organizational goals. For these and other reasons, technology plans can become out-of-date in a relatively short period of time. Consequently, we recommend that your technology plan not cover more than three years. However, we recognize that in certain situations a technology plan may be in effect for longer than three years, such as:

  • State five-year plans required by the Library Services and Technology Act (LSTA) meet E-rate requirements for state library agencies applying for discounts.
  • School five-year plans required by the U.S. Department of Education’s Enhancing Education Through Technology (EETT) program meet E-rate requirements.

For more information on all aspects of technology planning, start with Step 1: Technology Planning on the USAC website.

 

SLD News 11/8/13 – Focus: Eligible Services

November 8, 2013  

TIP OF THE WEEK: Remember that you can file an FCC Form 470 for FY2014 from the Apply Online web page or on paper. You do not need to wait for the application filing window to open before filing this form and opening your competitive bidding process.

Commitments for Funding Years 2013 and 2012

Funding Year 2013. USAC will release Funding Year (FY) 2013 Wave 26 Funding Commitment Decision Letters (FCDLs) November 14. This wave includes commitments for approved Priority 1 (Telecommunications Services and Internet Access) requests at all discount levels. As of November 8, FY2013 commitments total over $1.28 billion and encompass 28,623 of FY2013 applications.

Funding Year 2012. USAC will release FY2012 Wave 68 FCDLs November 15. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of November 8, FY2012 commitments total over $2.80 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

APPLICATION PROCESS: Eligible Services

Each year, before the FCC Form 471 application filing window opens, the Federal Communications Commission (FCC) releases an Eligible Services List (ESL) for the upcoming funding year. This list contains a description of the products and services that will be eligible for discounts, together with additional helpful information such as a list of ineligible products for each category of service and a glossary of terms. We suggest that you review this list before you prepare your technology plan – if one is required – and before you file an FCC Form 470 to open your competitive bidding process.

The FY2014 ESL has been released. A detailed description of the changes is included in the FCC’s Order DA 13-2037. The Order provides clarifications for lit and dark fiber, web hosting, and several other miscellaneous clarifications.

Lit and Dark Fiber

Lit and dark fiber provided by an entity, including a non-telecommunications carrier, is eligible. Leased lit fiber as part of a Priority One service may include as eligible: monthly charges, special construction charges, maintenance charges, and modulating electronics. For leased dark fiber, from the eligible entity up to the property line, maintenance costs and special construction costs to connect the fiber are eligible. Beyond the eligible entity’s property line, monthly charges and maintenance provided as a component of leased dark fiber to maintain reliable operation is eligible. If the dark fiber serves other customers, the costs of maintenance should be shared among all recipients. Re-routing of fiber is considered construction not maintenance. Also for dark fiber, an Indefeasible Rights of Use (IRU) purchase arrangement will be considered a lease for E-rate purposes and may be subject to amortization if the IRU contains significant upfront charges.

Web hosting

The Order clarifies that features that facilitate the ability to communicate, such as blogging and discussion boards, are eligible for E-rate funds if part of a web hosting package, but are not eligible as standalone services. Because the FCC did not designate these features as standalone services, applicants may not seek them from multiple providers (e.g., they may not seek funding for web hosting service from one vendor and communications features from another).

Miscellaneous Clarifications

The Order provides a few miscellaneous clarifications to the ESL. There are non-substantive corrections in the introduction to the ESL. The definition of Internet Access in the Glossary was modified to match the definition in the Special Eligibility Section. The Glossary adds the definition of “shared telephone service” which had been inadvertently deleted in a prior year. Finally, deleted from the list is the explanation concerning cost allocation for file servers which is covered by the main explanation for cost allocation.

Categories of service

There are five main categories of eligible services in two funding priorities:

Priority 1

  • Telecommunications Services
  • Telecommunications
  • Internet Access

Priority 2

  • Internal Connections
  • Basic Maintenance of Internal Connections

Beginning in FY2014, all of the Priority 1 services appear in the same section.

*Note: The proposed draft FCC Form 470 will reflect the consolidation of the Priority 1 section in the ESL and will feature only a single selectable category of service listed as “Priority One” on the new form.

– Telecommunications Services

Commonly available telecommunications services eligible for discounts include local and long distance wired telephone service, Interconnected Voice over Internet Protocol (VoIP), cellular phone service, and Centrex service. Digital Subscriber Line (DSL), Primary Rate Interface (PRI), T-1, T-3, and satellite services are also eligible.

Telecommunications Services must be provided by a telecommunications carrier, that is, a company that offers telecommunications services on a common carriage basis. You can Search for SPIN Information on the USAC website to find information about the telecommunications carrier status of a provider.

– Telecommunications

Telecommunications include leased lit and dark fiber which is described in the FY2014 ESL update.

– Internet Access

Applicants can apply for discounts on basic conduit access to the Internet, but not on content, equipment purchases, or other services beyond basic conduit access. However, selected services that are an integral component part of an Internet Access service may be eligible. There are also other services designated as eligible by the FCC as Internet Access, for example: interconnected VoIP, email service, and web hosting.

– Internal Connections

Internal Connections includes products such as routers, switches, hubs, and wiring. Eligible components of Internal Connections are located at the applicant site and must be necessary to transport information to classrooms or publicly accessible rooms of a library. Internal Connections do not include services that extend across a public right-of-way beyond the school or library facility.

Starting with FY2005, under the Two-in-Five Rule, eligible entities can only receive discounts for Internal Connections in two of every five funding years.

– Basic Maintenance of Internal Connections

Basic maintenance services – repair and upkeep of eligible hardware, wire and cable maintenance, basic technical support, and configuration changes – ensure the necessary and continued operation of internal connections components at eligible locations. The components themselves must be eligible for discounts for their associated basic maintenance services to be eligible.

Basic maintenance services must be for actual work performed and parts repaired or replaced. Unbundled warranties or fixed price contracts – other than for software upgrades and patches including bug fixes and security patches, and online and telephone-based technical assistance and tools – are not eligible for reimbursement unless the ineligible portions can be cost-allocated.

Some other eligibility issues to consider

Partial eligibility. If a product or service has both eligible and ineligible uses or components, applicants may still receive discounts on the eligible portion(s) of the product or service. We refer to these products or services as partially eligible. For example:

  • A file server may be used both as an email server (an eligible use) and an archive server (an ineligible use).
  • A phone service may be delivered to a school run by a church (an eligible location) and to the church office (an ineligible location).

To request discounts on the eligible portion of these products and services, you must do a cost allocation. There is not a single approved method to allocate eligible and ineligible costs. The method you choose must use tangible criteria to reach a realistic result.

Conditional eligibility. Products and services may be eligible under certain conditions but not others. We refer to these products or services as conditionally eligible. For example:

  • Basic maintenance is only eligible if it is for eligible products and services.
  • A file server in conditionally eligible based on the tasks being performed. For example, if a server is being used for email, DHCP, or DNS service, the server is eligible. However, if a server is being used for running applications or archiving, the server is ineligible.

The product or service can be eligible for discounts if the appropriate conditions are met.

Ancillary use. If a product or service contains an ineligible feature that is not significant and is strictly ancillary to the principal uses of the product or service and the ineligible feature is not offered or priced separately, the full product or service may be eligible for E-rate discounts and may not require a cost allocation if certain other requirements are met.

On-premise Priority 1 equipment. Equipment owned by the service provider but located at the applicant site and leased by the applicant can be eligible for discounts as a Priority 1 service if it meets specific conditions. We refer to this equipment, if eligible, as on-premise Priority 1 equipment.

Wide area networks. A wide area network (WAN) is a voice, data, or video network that provides connections from one or more computers or networks within an eligible school or library to one or more computers or networks that are external to such eligible school or library. Under certain conditions, leased WAN services can be eligible for discounts.

Educational purposes. Services must not only be eligible, but must also be delivered to eligible locations and used primarily for educational purposes. The presumption is that activities that occur on school or library property fall under the definition of educational purposes but certain special conditions may apply.

For more information on eligible services, refer to the guidance documents linked to the Eligible Services Overview on the USAC website.

 

SLD News 11/1/13 – Focus: Service Substitutions

 November 1, 2013  

TIP OF THE WEEK: The invoice deadline for FY2012 recurring services has been extended to October 28, 2014. You therefore do not need to file an invoice deadline extension request before you can submit an invoice for FY2012 services, but we strongly encourage you to complete your invoicing process for FY2012 as soon as possible.

Commitments for Funding Years 2013 and 2012

Funding Year 2013. USAC will release Funding Year (FY) 2013 Wave 25 Funding Commitment Decision Letters (FCDLs) November 6. This wave includes commitments for approved Priority 1 (Telecommunications Services and Internet Access) requests at all discount levels. As of November 1, FY2013 commitments total over $1.23 billion and encompass 27,869 of FY2013 applications.

Funding Year 2012. USAC will release FY2012 Wave 67 FCDLs November 7. This wave includes commitments for approved Priority 2 (Internal Connections and Basic Maintenance) requests at 90 percent and denials at 89 percent and below. As of November 1, FY2012 commitments total over $2.80 billion.

On the day the FCDLs are mailed, you can check to see if you have a commitment by using USAC’s Automated Search of Commitments tool.

More on Service Substitutions

A service substitution is a change in the products and/or services originally specified in the Item 21 attachment for the FCC Form 471. In last week’s SL News Brief, we covered basic information on service substitutions. Below are additional examples of service substitution requests and guidance on discontinued products and deadlines.

Additional examples of allowable and unallowable service substitutions

  • An applicant wants to change from PBX (voice) equipment to CODEC (video) equipment. USAC would not approve this service substitution request because voice and video components are of different functionalities.
  • An applicant wants to change from local and long distance telephone service in Telecommunications Services to email accounts in Internet Access. Such a request would be denied because the services are not functionally equivalent and the substitution would involve a change in category of service.
  • A service provider has discontinued manufacturing Router X and now manufactures only Router Y. Router Y is better and faster than Router X but provides essentially the same functionality. Assuming there are no other differences, USAC can approve a service substitution of Router Y for Router X on an applicant by applicant basis OR – if the manufacturer of the router submits the change to USAC directly – this can be processed as a “global” service substitution (see below).
  • An applicant wants to switch from an expensive router to a less expensive switch. USAC will approve this service substitution request because the functionality of the equipment remains the same. USAC will remove the dollars associated with the difference in the price of the two pieces of equipment from the commitment. The applicant does NOT need to file an FCC Form 500; USAC will calculate and implement the reduction to the funding request.
  • An applicant realizes that the installed equipment was not Server A, the requested server on the Item 21, but in fact Server B. An applicant submits this change as a “corrective” service substitution (see below). Assuming that these are the same functionality with no significant differences, USAC will be able to approve this request.

Discontinued products (global service substitutions)

Manufacturers and service providers may submit notification to USAC that a product or service is being discontinued, is changing model numbers, or is being replaced. USAC refers to these requests as “global” service substitutions.

Global service substitution requests must indicate that the new products or services are functionally equivalent to the products or services being replaced and have no increase in percentage of ineligible features. Global service substitutions are only applicable when the product or service originally specified on the FCC Form 471 is no longer available or is no longer being provided by the manufacturer or service provider making the request.

USAC maintains a list of substitute products and/or services to speed the processing of invoices that specify the replacement product or service. Such service substitutions will not result in a change to an applicant’s funding commitment.

Service providers should submit model changes as early as possible to avoid delays in the processing of invoices. USAC will respond in writing to the service substitution request and may ask for additional information before processing the request.

Because a service substitution request initiated by a service provider does not reference any specific funding request, USAC will not modify individual applicant funding commitments nor extend the service delivery deadline.

Deadlines for requesting service substitutions

In general, a service substitution request must be received or postmarked by the last day to receive service for the corresponding FRN. The last day to receive service is:

  • June 30 of the relevant Funding Year for recurring services or
  • September 30 following the close of the Funding Year for non-recurring services. Remember, however, that the deadline for delivery and installation of non-recurring services can be extended (see Service Delivery for more information).

Several other program deadlines may affect service substitution requests:

  • Service substitution requests can be submitted after USAC issues the Form 471 Receipt Acknowledgment Letter but before the last day to receive service on the associated funding request. If the service substitution request is received before the review of the application is complete, the request will be incorporated into the review process.
  • Applicants are still required to comply with the deadline for filing the FCC Form 486. You can use the FCC Form 486 tab on the Deadlines tool to calculate this deadline.

Additional guidance

Here are some specific suggestions to assist USAC in processing your service substitution request more efficiently:

  1. Make sure you include the name and contact information for the person who can discuss the service substitution request. USAC often has questions about requests or needs additional information.
  2. In general, you – the applicant – must make the certifications about your request. Copy the certification language for the certifications from the service substitution website guidance as part of your request. Service providers cannot sign the certifications on your behalf.
  3. Always include the following information: type of service or make and model of equipment, quantity, cost per unit, total cost of the service or equipment, and the total cost of the From (original) and To (substituted) portions.
    • List only the equipment for which you are requesting a substitution. You do not need to list all items that were approved as part of the Item 21 attachment.
  4. Do not submit a single From and To list for multiple FRNs. Provide individual From and To lists for each FRN.
  5. Provide itemized From and To dollar amounts for the changing equipment. Also, provide the total original and revised costs of these changes.
  6. If any ineligibles were found during PIA review, you do not need to list them in your service substitution request. Also, if there are any ineligible charges, be sure to subtract those charges from the total cost.
  7. If you are correcting information about products and/or services for which USAC has already processed and paid an invoice, mark your request “Corrective” so that we understand your intent.
  8. If service providers submit a global service substitution, approval of this request does not automatically grant an extension of time to deliver and install the product or service. Also, such requests cannot be applicant-specific but must apply across the board. The more detail you provide – such as manufacturer product codes (rather than codes used by resellers, vendors, or applicants), make, model, and cost per line item – the better.
  9. If possible, send detailed information either electronically or on paper. This is especially important when identifying the individual entries for original and substituted products and services. Faxes can be difficult to read.
  10. Review the Eligible Services List for the funding year that applies to the original funding request to verify eligibility.
  11. Include the same level of detail on the substituted products and/or services that you provided on the original Item 21 attachment.
  12. Provide a Letter of Agency if you are a consultant submitting the request on behalf of an applicant.
  13. If the substituted product or service has a lower cost than the original, do not file an FCC Form 500. USAC will adjust the dollars associated with the FRN as part of the service substitution review process.
  14. Submit one copy of your request using only one mode of transmission (email, fax, or mail). If you submit multiple copies (for example, fax a copy and then mail the original), the processing of your request will be delayed.
  15. If USAC’s review of your service substitution request results in the identification of ineligible products or services that were erroneously approved, your original funding commitment will be adjusted to remove the ineligible products and services and their related charges. Ineligible products or services cannot be substituted for eligible products.

Again, for detailed instructions, information, and additional examples, refer to the service substitution guidance on the USAC website.