Databus Issue: 2006 1 02/13/2006
E-Rate Update
Fred Brakeman President
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Like many of our E-rate/CTF clients, now that the time frame is over to file E-rate funding requests for the fiscal year 2006- 2007, our office is going back and checking (and double checking) that all of our E-rate records are in order. We thought it might be helpful to pass on the checklist we follow to prepare for the Program Integrity Assurance (PIA) process and, more importantly, a possible future audit.
Have I prepared and sent to E-rate all Form 471, Item 21 attachments?
If not, do so immediately. If a “non-E-rate” person can’t decipher your Item 21 attachments, you may want to consider amending the information and put it into an “easier to read” format. You can’t increase the amount of funding but anything you can do to make it easy to read is advisable.
Is the Free & Reduced (F&R) information I used on my Form 471 different than the October, 2005 CBED documentation that was sent to the CDE?
If it’s the same, nothing more needs to be done regarding this matter since PIA reviewers verify your F&R by checking the CDE website. If it’s different, be prepared to document the alternate discount method you used to request your E-rate funding.
Does my technology plan address all the services requested in my Form 471?
By the time you file your Form 471, your technology plan should have been written before services can be supplied, your technology plan must be approved. If your current technology plan does not cover all the services requested in your E-rate application, an addendum must be written, signed and dated by administration staff, and filed at the District office. This addendum does not have to be approved by the local technology plan approver or the CDE.
Am I CIPA compliant?
To be CIPA compliant, you must (1) seek public comment at a school board meeting; (2) you must have a procedure in place to protect children from online predators and objectionable material (acceptable use policy); and (3) the school board must certify that they are CIPA compliant. If this has not been done, do so immediately! You must be CIPA compliant before receiving Erate services.
Can I document that I followed all state, local and school district purchasing regulations?
Be prepared to document that you followed all bid laws and local purchasing procedures. Be prepared to document that you communicated with all vendors who requested RFPs and that you chose the lowest responsible bidder. Keep logs of all e-mails, letters, and telephone conversations you had with all vendors during the bidding process, not just the low bidders. Keep copies of all bids, not just the low bidder(s).
When PIA calls, respond to their request for information within seven days.
It is suggested, when PIA calls, that you request that the PIA reviewer e-mail you their list of questions. Respond in writing to their questions and keep copies of all communications with PIA. If you can’t respond within the allotted seven day period, request an extension within the seven day period.
Double check the Eligible Services List to verify you did not request funding for an ineligible product or service.
If, after checking, you identify that you made a mistake, be prepared to notify PIA once the review process starts. It’s better to get mistakes taken care of during the PIA process than later on in an audit when monies may be required to be paid back! Download and keep a current copy of the Eligible Services List. Since it changes every year, this will come in handy in the event of an audit.
After the Form 471 is fi led, be sure to check the information included in the Receipt Acknowledgement Letter (RAL) is correct.
Immediately check the information included in the RAL and verify the information is correct. If not, make the appropriate corrections and send the information to SLD immediately.
Assemble and put all E-rate documentation in one place.
Whether it’s you later on or your predecessor in subsequent years, it’s easier to answer questions if all the information is in one place. It’s a pain, and a bit time consuming, but it will save you hours of frustration later on by taking some time now to document the whole process and place that information in one place.
Always know there may be a future audit and act accordingly!
If you have documented the entire process, kept good records, and kept yourself abreast of E-rate rules and changes, an audit is nothing to worry about. Remember an audit can happen any time up to and until five years after the service has ended.
Gosh, I hate to even start thinking about it, but I guess I should start pre-planning what I need to be doing for the fiscal year 2007-2008 E-rate season.
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Fred Brakeman is president of Infinity Communications & Consulting, Inc, a full-service consulting firm including E-Rate/CTF consulting, technology design services, and lowvoltage construction management and inspection services serving approximately 10 percent of all the school districts and county offices of education in California. Infinity Communications & Consulting is located in Bakersfield, California. He can be reached at fbrakeman@infinitycomm.com, (661) 716-1840 or via mail at P.O. Box 6069, Bakersfield, California 93386. Please visit www.infinitycomm.com.
