Databus Issue: 2008 1 01/28/2008
E-Rate Update
Fred Brakeman PresidentGetting Ready For the Dreaded Erate Review
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Well, you made it through another year and successfully filed your Erate Forms 470 and 471 on time and now you are onto other more pressing matters like doing the job they actually pay you to do! Unfortunately you are not done. Erate still has to review your application(s). Here are some tips on how to have a successful review.
TIP #1 – Verify that you sent in via mail or electronically with your PIN the Form 470 and 471 signature pages. Make sure you keep the express mail return receipt if you sent the certification pages by mail. A high percentage of applications are denied each year because the certification pages were lost. If you can prove you sent the certification pages, the applications can still be approved. If you can not find evidence that you have sent the certification pages in, send them now or supply them to the reviewer once the review process starts!
TIP #2 – After you sent in your Form 470 and Form 471 you received in the mail a Receipt Notification Letter. Before you file these letters away, please read them and verify all the information in the letters is correct. If you have corrections, make them on the Notification Letter, sign and date the letter, and send back to Schools and Libraries Division.
TIP #3 – When the Program Integrity Review (PIA) person contacts you and provides a list of items they need additional clarification on, respond immediately! You have 15 days to respond. If you can not respond within the 15 day period, send an email to your reviewer and request a 1 week extension. Extensions can be granted if you have a valid reason. If the PIA reviewer asks for information and you need your Service Provider’s assistance, please contact your Service provider immediately so they can research the matter and provide the information to you within the 15 day window.
TIP #4 – Treat the PIA reviewer as your friend, not an adversary! If you don’t understand the question, ask for a clarification. They are mandated to help you through this process. The PIA reviewer can not answer the questions for you but they can provide additional clarification in order for you to provide a proper and complete response.
TIP #5 - Request the PIA reviewer to communicate with you via email and respond to the reviewer via email (or fax). It is extremely important that you have a written record of all communications in the event you are denied and you can prove the written documents don’t support the reasons for denial. It is a good practice to ask the reviewer to verify that he/she received your email and do a read receipt when you send the email. This procedure will be very helpful in the event an appeal needs to be written at a later date.
TIP #6 – One of the items the reviewer will need to verify is your Free & Reduced (F&R) Lunch discount percentages for each school site. They will be checking the information you gave them in your Form 471 against “third party documentation” supplied by the California Department of Education (CDE). The information that is posted on the CDE’s website came from the information your district supplied to the CDE in November of each year. It is a good practice to use the same F&R numbers that your district supplied to the CDE. If you used different F&R numbers, please be prepared to supply this information to the reviewer.
TIP #7 - If you signed new contracts, be prepared to supply copies of these contracts during the review process. Make sure they are signed and dated by all parties and that they were dated before you filed your Form 471. Failure to do so will cause the denial of funding.
TIP #8 – PIA will be looking for competitive bidding violations. Be prepared to show that you maintained a “fair and open” competitive bidding process. They will ask for supporting documentation to verify that RFPs were made available to bidders for 28 days after the Form 470 was filed, all bidders received the same information and were all treated fairly. If multiple bids were received, which bidder was chosen and what evaluation criteria was used to pick the winning bid. Most likely, they will also ask for board minutes where the board approved the bids.
TIP #9 – If you applied for Priority 2 Internal Connections projects, be prepared to verify that all the components of your voice, video, or data systems are eligible by provided detailed material lists. PIA may determine that some of your components are ineligible and/or some of the components of your system are not 100% eligible. This is a good time to involve your Service Provider and request support documentation from the Service Provider to work through these issues. Before the reviewer can approve this funding request, these issues must be mutually agreed upon.
TIP #10 – Make sure you have the correct Service Provider Identification Number (SPIN) on your application. Many Service providers such as Verizon or AT&T have multiple SPINs. Verify that each service you have with a company such as AT&T or Verizon is the correct SPIN. You may also need to “split” the SPINs citing several SPINs such as telco lines, and long distance. These issues can be fixed during the review process.
