Fall 2011 Library E-Rate Training
description
Transcript of Fall 2011 Library E-Rate Training
Fall 2011 Library E-Rate
Training
E-Rate FY2012
• Understanding the Basics• OPLIN News• CIPA Update
– Break• Correcting Ministerial & Clerical Errors• Eligible Services
– Break or Lunch on Your Own• Form 470 Step - by - Step
Today’s Agenda
• General information about E-Rate• Technology planning• Requesting services (FCC Form 470)• Competitive bidding process• Ordering services (FCC Form 471)• Application review & funding commitments• Begin receiving services (FCC Form 486)• Invoicing USAC (FCC Form 472 and FCC Form 474)• Deadlines
Overview
Understanding the Basics
• Federal Communications Commission (FCC), an independent U.S. government agency, established and oversees the E-Rate program
• Universal Service Administrative Company (USAC), a not-for-profit, administers the E-Rate program along with three other programs
• Schools and Libraries Division (SLD) is the part of USAC with responsibility for E-Rate
E-Rate Organization
General E-Rate Information
• Congress directed the FCC to establish the E-Rate program in 1996
• The FCC sets rules and policies through orders
– Policies are defined in the text of orders
• USAC/SLD develops procedures for specific actions, such as how to process applications
E-Rate Rules
General E-Rate Information
• Commitments for E-Rate are made by funding year (FY), which runs from July 1 through the following June 30
• USAC refers to the funding year as the year in which most services will begin
– E.g., FY2010 is July 1, 2010 – June 30, 2011
E-Rate Timeline
General E-Rate Information
• The FCC has set the E-Rate fund at $2.25 billion for each funding year. However, beginning in FY 2010, the cap is now adjusted for inflation each year – Cap is now $2.29 billion
• Once each year, FCC can roll over unused funds from previous funding years into the current funding year– Money for ALL FY2010 Applications at all discount
bands– $850 million for FY2011 Applications
E-Rate Budget
General E-Rate Information
Who is eligible for E-Rate funding?
• Schools and school districts– Non-traditional facilities (conditionally by state)
• Libraries and library systems
• Consortia – groups of eligible entities that band together to aggregate demand and negotiate lower prices
E-Rate Eligibility
General E-Rate Information
How large are the discounts on eligible products and services?• Discounts= 20% to 90% of eligible costs
Discount level for a school or library depends on: 1) Percentage of students who are eligible for National School Lunch Program (NSLP) in:
→ (for a school) the school→ (for a library) the school district in which the library is
located 2) Urban or rural location of the school or library
→ Determine Your Classification
E-Rate Discounts
General E-Rate Information
– School District’s October Data reported to ODE can be found in the MR-81 document located at www.ode.state.oh.us.
• From the ODE website, search for MR-81
Total Student (ADM) Count
Combined Free/Reduced Lunch Count
Numbers to use:
Discount Matrix
General E-Rate Information
INCOME % of students eligible for NSLP
URBAN LOCATION Discount
RURAL LOCATION Discount
If the % eligible is... ...and you’re in an URBAN area, your discount will be...
...and you’re in a RURAL area, your discount will be...
Less than 1% 20% 25%
1% to 19% 40% 50%
20% to 34% 50% 60%
35% to 49% 60% 70%
50% to 74% 80% 80%
75% to 100% 90% 90%
• Priority 1 (P1): funded first
– Telecommunications Services
– Internet Access
– Telecommunications
• Priority 2 (P2): funding starts with neediest applicants
– Internal Connections
– Basic Maintenance of Internal Connections
E-Rate Categories of Service
General E-Rate Information
How do I file a program form?• In general, you have three options:
1. File online, certify on paper2. File online, certify online3. File on paper, certify on paper
• Two versions of each online form: standard and interview
*Note* USAC encourages you to file online, because online filing speeds processing and reduces errors
E-Rate Forms
General E-Rate Information
Each time you file a program form, USAC sends you a letter• Letters are color-coded by funding year
2011 Blue 2012 Canary2013 Pink
*Note* When storing documents, USAC encourages you to separate your program forms & letters by funding year to better organize them.
E-Rate Letters
General E-Rate Information
Filing Process
FCC Forms 472 (BEAR) & 474 (SPI)
FCC Form 486
Application Review & FCDL
FCC Form 471 & RAL
Competitive Bidding
FCC Form 470 & RNL
Technology Planning
A technology plan must contain the following elements:1) Goals and strategies for using technology to improve
education or library services2) Needs assessment 3) Staff training 4) Evaluation plan
*Note* Starting with FY2011, if you are only requesting P1 services, a technology plan is not required
Tech Plan Elements
Technology Planning
• Tech plan should not cover more than 3 years• Should cover the funding year (July 1 – June 30)• Sufficient detail to support & validate services requested• Must follow FCC rules AND applicable state or local
technology plan requirements• Created prior to FCC Form 470/RFP (month & year)• Contains four elements (goals/strategy, professional
development, needs assessment, and evaluation process)
• Must be approved on or before the date when you begin receiving services
Tech Plans
Understanding the Basics
Requesting Service (FCC Form 470)
• Open a competitive bidding process (acts as an RFP)• Identify and describe desired categories of service and
function of the services• Describe scope of your needs• Notify potential bidders of the types and quantities of services
that you need• Must be posted a minimum of 28 days• Must file yearly for month-to-month service or prior to signing
a new contract• For multi-year contracts, you do not need to file during the
term of the contract
FCC Form 470 Purpose
Requesting Service
• Applicants must ensure that they post for the correct category or categories of service (Non-allowable correction. Must repost FCC Form 470)
• Sufficient detail in FCC Form 470– Cannot provide generic descriptions (e.g., “All eligible telecom services”
or “Digital Transmission Services”)– Cannot provide laundry lists of products and services
• Addendums or changes to the RFP may require applicants to re-start the 28 day period when there is a significant change to the original scope of the procurement
• If a service is not listed on a Form 470, you cannot list on a Form 471
• *Note* RFPs are not required by E-Rate but may be used to describe specific needs and circumstances
Tips for Success
FCC Form 470 & RFPs
• Billed Entity Number (BEN): an identification number assigned by USAC to each school/district or public library responsible for paying the bills• An Entity Number is assigned to each individual
school/building
• Personal Identification Number (PIN): a code assigned by USAC to applicants for use in certifying program forms online– USAC issues a PIN to every new authorized person filing a
paper certification for FCC Form 470, 471, or 486
Acronyms & Terms
Requesting Service
• FCC Form 470 Receipt Notification Letter (RNL): a letter issued by USAC to the applicant that summarizes the information provided in the FCC Form 470
• Allowable Vendor Contract Date (ACD): the date 28 days after the FCC Form 470 is posted to the USAC website
Acronyms & Terms
Requesting Service
• You must ensure that the competitive bidding process is open and fair
– You must keep all incoming bids/correspondence with bidders and prepare to evaluate bids equally
• All potential bidders have access to the information from your FCC Form 470 and RFP, and they can respond to your requests
• Price as the primary factor: In evaluating bids, the price of the eligible products and services must be the most heavily-weighted factor in your evaluation of bids
Competitive Bidding Requirements
Competitive Bidding
Bid Evaluation Matrix (sample)
Competitive Bidding
Factor Points Available Vendor 1 Vendor 2 Vendor 3Price of the ELIGIBLE goods
and services 30 15 30 25Prior experience w/ vendor 20 20 0 20Prices for ineligible services,
products & fees 25 20 15 25Flexible Invoicing: 472 or 474 15 0 15 15
Environmental objectives 5 5 3 2Local or in state vendor 5 5 5 5
Total 100 65 68 92
1. The applicant has a relationship with a service provider that would unfairly influence the outcome of a competition or furnish the service provider with “inside” information
2. Someone other than the applicant or an authorized representative of the applicant prepares, signs OR submits the FCC Form 470 and certification
Examples of Rule Violations
Competitive Bidding
3. A service provider representative is listed as the FCC Form 470 contact person and that service provider is allowed to participate in the competitive bidding process
4. The FCC Form 470 does not describe the desired products and services with sufficient specificity to enable interested parties to submit bid responses
Examples of Rule Violations
Competitive Bidding
• After you close the competitive bidding process for your services (on or after the ACD):1) You can evaluate the bids received
2) You can choose your service provider(s)
3) You can sign a contract
4) You can submit an FCC Form 471
• No bids or one bid (email yourself noting the fact)• Retain all vendor selection documentation
– Winning and losing bids, correspondences, memos, bid evaluation documents, etc.
Choosing a Service Provider
Competitive Bidding
Understanding the Basics
Ordering Services (FCC Form 471)
• Provide information on the service providers and eligible services you have chosen
• Identify the eligible schools and libraries that will receive services
• Calculate and report how much support you seek for the year
• Include your discount calculation information• Certify your compliance with program rules• Must be filed on a yearly basis
FCC Form 471 Purpose
Ordering Services
• Contract must be signed and dated by the applicant prior to the FCC Form 471 certification postmark date
• Applicant must not sign a contract before the Allowable Contract Date (ACD)
• Service providers may sign before the ACD
Overview
Contracts
• Item 21 attachment describes the eligible products or services requested for each FRN
• It is a FCC Form 471 window filing requirement. It should be submitted on or before the window close.
• Can be submitted via Online tool, mail, fax or email to USAC – Remember to click SUBMIT when using Online tool
Tip for Success• Clearly label the Item 21 attachment (Applicant name,
BEN#, FRN, Page #, Application #)
Item 21 Attachment
Ordering Services
• Receipt Acknowledgment Letter (RAL): a letter issued by USAC to the applicant and the service provider that summarizes the information provided in the FCC Form 471
– Many of the entries on the form can be corrected after submission by using the RAL
– Ministerial and clerical errors can be corrected until USAC issues the Funding Commitment Decision Letter
Ordering Services
• Non-instructional Facility (NIF): a school building with no classrooms or a library building with no public areas
– NIFs are eligible for Priority 1 services– NIFs are eligible for Priority 2 services only if
necessary to provide effective transport of information to classrooms or public areas of libraries
Acronyms & Terms
Ordering Services
Understanding the Basics
Application Review & Funding Commitments
• Check the eligibility of the schools and libraries and their discount levels
• Verify that the services you requested are eligible for discounts
• Give you an opportunity to make allowable corrections to your form
• In some cases, ask for additional verification of your compliance with program rules
During Program Integrity Assurance (PIA) USAC reviews FCC Form(s) 471 to :
Application Review/Commitments
• Following application review, USAC issues a Funding Commitment Decision Letter (FCDL) to both the applicant and the service provider(s)
• Applicants and Service Providers should carefully review their FCDL for details on approved or denied requests and your next steps
Receiving Your Funding Commitment
Application Review/Commitments
Understanding the Basics
Begin Receiving Services (FCC Form 486)
• Notify USAC that your eligible services have started or been delivered and invoices for those services can be processed and paid
• Provide the name of the TPA that approved your technology plan
• Report your status of compliance with the Children’s Internet Protection Act (CIPA)
• Can only be filed after the Funding Commitment Decision Letter is issued
FCC Form 486 Purpose
Begin Receiving Services
Understanding the Basics
Invoicing USAC (FCC Forms 472 & 474)
• Billed Entity Applicant Reimbursement (BEAR) FCC Form 472 is filed by the applicant and approved by the service provider after the applicant has paid for the services in full
• Service Provider Invoice (SPI) FCC Form 474 is filed by the service provider after the applicant has been billed for the non-discount portion of the cost of eligible services
*Note* Applicants can choose their method of invoicing; service providers cannot force applicants to use a particular method.
2 Methods of Invoicing
Invoicing USAC
• Applicants and Service Providers receive an FCDL from USAC for the services being invoiced
• Applicants must file an FCC Form 486 and receive an FCC 486 Notification Letter
• Service Providers must file an FCC Form 473 - Service Provider Annual Certification (SPAC) each funding year to certify that it will comply with FCC rules concerning invoicing and documentation – FCC Form 473 can be filed after USAC has announced
the opening of the application filing window
Requirements Before Invoicing USAC
Invoicing USAC
Understanding the Basics
Deadlines
• FCC Form 470 - Posted at least 28 days before the filing of the FCC Form 471, keeping in mind the FCC Form 471 application filing window opening and closing dates
• FCC Form 471 - Received or postmarked no later than 11:59 p.m. EST on the day of the close of the FCC Form 471 application filing window (exact date will be announced)
• FCC Form 486 - Received or postmarked no later than 120 days after the date of the USAC Funding Commitment Decision Letter or the service start date, whichever is later
• FCC Form 472/ FCC Form 474 - Received or postmarked no later than 120 days after the date of the FCC Form 486 Notification Letter or the last date that the applicant can receive service from the provider in the funding year at issue, whichever is later
• Appeals - Received or postmarked no later than 60 days after the date of USAC's decision letter
Application Deadlines
Deadlines
OPLIN News
All library organizations receiving Internet connectivity from OPLIN are required to submit:
•a Letter of Agency (LOA) •And a Form 479
OPLIN News
• LOA and Form 479s can be found at http://oplin.org/erate
• Once generated, the forms must be signed, dated, and either faxed to 614-728-5256, or scanned to [email protected]
• Please complete ASAP so OPLIN can begin work on our E-Rate applications
OPLIN News
CIPA Update
Children Internet Protection Act requirements:– Proof of public notice of public meeting or hearing– Proof of public meeting or hearing– Copy of Internet Safety Policy– Technology protection measure (filtering)
Documentation Tip:– Must maintain documentation from prior years if it
supports current funding year– Filter documentation examples: maintenance logs, filtering
logs, proof of purchase or vendor filter description
CIPA Compliance
• FOR SCHOOLS – By July 1, 2012, amend your existing Internet safety policy (if you have not already done so) to provide for the education of minors about appropriate online behavior, including interacting with other individuals on social networking sites and in chat rooms, and cyberbullying awareness and response.
• FOR LIBRARIES – No new requirements– You will not be required to provide Internet Safety
Training
New “Internet Safety Training” requirements under CIPA
New Requirements
• OPLIN will be making a free content filter available to all libraries next year.– see
http://www.oplin.org/oplin-plans-offer-free-internet-filtering-service
If you are not currently CIPA compliant because you do not have the resources to support an Internet content filter :
CIPA Compliance
• You may go to http://oplin.org/erate and resubmit forms as often as needed until Friday, February 24, 2012, the deadline for form submission.
• As we put the final touches on our E-Rate applications, we will determine a library's CIPA-compliance based on the last Form 479 received from the library prior to 5:00 pm February 24.
Some libraries may be reviewing their CIPA compliance as a result of the new OPLIN-provided filter.
CIPA Compliance
• The FCC plans to seek public comment in a separate proceeding on the following issue:– Do CIPA requirements apply to the use of portable
devices owned by students and library patrons – such as laptops and cellular telephones – when those devices are used in a school or library to obtain Internet access that has been funded by E-Rate?
• The FCC may raise other issues as well.
Public comment
Clarifications
Correcting M&C Errors
Ministerial & Clerical Errors
• M&C errors– What are M&C errors– What is new & what is the same
• Corrections– Allowable – Non-allowable – Conditional
• Submitting Corrections to USAC• Notifications from USAC (FCDL Comments)
Overview
Ministerial & Clerical Errors
• “The applicant can amend its forms to correct clerical and ministerial errors on their FCC Forms 470, FCC Form 471 applications, or associated documentation until an FCDL is issued. Such errors include only the kinds of errors that a typist might make when entering data from one list to another, such as mistyping a number, using the wrong name or phone number, failing to enter an item from the source list onto the application, or making an arithmetic error.”(FCC 11-60)
Definition
Ministerial & Clerical Errors
• 15 Day Rule eliminated (CORRECTIONS ONLY)– RNL & RAL corrections can be submitted until the FCDL is
issued
• PIA will ask if this is a ministerial or clerical error– Tell us what error occurred – Provide a reasonable explanation– Documentation may be requested
What Is New?
Ministerial & Clerical Errors
• Minimum Processing Standards (MPS) for the FCC Forms 470 & 471 and Certifications
• FCC Forms 470 & 471 and Certifications corrections • FCC Form 471 Certification must be submitted on or
before the Window close• 15 Day Rule still applies for responses to reviewers’
inquiries• Additional documentation may be required to
support your requested change
What Is The Same?
Ministerial & Clerical Errors
• Spelling errors• Simple addition, subtraction, multiplication or
division errors• Transposed letters and/or numbers• Misplaced decimal points• Other punctuation marks (hyphens, periods,
commas, etc.) included, or not included or misplaced• Failing to enter an item from the source list (e.g.,
NSLP data, uploading Block 4 data, FRN, etc.)
M&C Errors Examples
Ministerial & Clerical Errors
• Update or change contact person and/or consultant information
• Billed entity information• Add the authorized person signature • Change or update eligible entities receiving service
(Note: changes are accepted if it is not a significant change from the original scope)
• Certification not submitted by Window close
FCC Form 470 Allowable Corrections
Ministerial & Clerical Errors
• Incorrect citation such as:– FCC Form 470 number– Discount percent – Urban/rural status– Contract number– Billing Account Number/Multiple Billing Account
Numbers– Block 4 worksheet entries
FCC Form 471 Allowable Corrections
Ministerial & Clerical Errors
• Update or change contact person and/or consultant information
• Correct errors to dollars figures on an FRN• Add or remove entities accidentally omitted or
included in block 4• Provide accidentally omitted FRNs• Amount budgeted for ineligible services (Block 6)
FCC Form 471 Allowable Corrections Cont’d
Ministerial & Clerical Errors
• SPIN corrections are ALLOWABLE when requesting a Corrective SPIN change– Data entry errors, company merger or acquisition
• Contract Award Date/ Expiration Date• Consortium Letters of Agency (LOA)
– Applicants may provide supplemental documentation dated on or before FCC Form 471 certification postmark date when:
– LOA service timeframe is missing or not specified– Lack of detail regarding the services provided– Missing consortium members
Conditional Corrections
Ministerial & Clerical Errors
• FCC Form 470: Adding Service Category – Must post new FCC Form 470
• FCC Form 471: Operational SPIN change
– Request SPIN change after FCDL issued– Not allowed pre-commitment
Non-Allowable Corrections
Ministerial & Clerical Errors
• FCC Form 470 corrections submitted via Receipt Notification Letter (RNL)
• FCC Form 471 corrections submitted via Receipt Acknowledgement Letter (RAL) and/or during FCC Form 471 review
• Follow submission instructions on letter– Send a copy of Block 4 Worksheet if entity
changes are made
Submitting Corrections
Ministerial & Clerical Errors
• Discrepancies may be detected during PIA review. PIA will contact you when PIA is unsure an error happened.– PIA will:
• ask if an error occurred• ask if you wish to make a correction• ask for an explanation • request supporting documentation, if
applicable
Program Integrity Assurance (PIA) Review
Ministerial & Clerical Errors
• Supporting documentation examples:– Contract, Service Agreement– Vendor quote, bill, invoice, etc.– Documented communication like emails between the
applicant & the service provider– Source list– RFP, Newspaper listing– NSLP documentation or student enrollment data– Board Minutes, Resolutions– Budget
Program Integrity Assurance (PIA) Review
Ministerial & Clerical Errors
• PIA Review– Your reviewer will inform you if the correction was
completed or not (preferred mode of contact)• FCDL
– Global Comment • informs applicant that a RAL correction was received• Informs the applicant about corrections affecting
multiple FRNs (e.g., discounts, entity removals) • appears at the top of the FCDL FRN report
– FRN Comment: states the specific changes
Correction Notification
Ministerial & Clerical Errors
The E-Rate Program
FY2012 Eligible ServicesFall 2011 Applicant Trainings
• Priority One (P1)– Telecommunication Services, Telecommunications,
Internet Access (IA)• Priority Two (P2)
– Internal Connections (IC) and Basic Maintenance of Internal Connections (BMIC)
• Miscellaneous• Dark Fiber• Equipment Transfers, Disposals and Trade-ins
Overview
Eligible Services
• Support for telecom services such as:– Local and long distance service– Interconnected Voice over Internet Protocol (VoIP)– Cellular voice service
• Including text messaging, voicemail• (For email/Internet on your phone, remember to check
the IA box on your 470!) – Centrex Service
Telecommunications Services
Priority One
• Digital Transmission Services– Digital Subscriber Line (DSL)– Primary Rate Interface (PRI)– T-1, T-3– Satellite Service
Telecommunications Services
Priority One
Not Eligible as Telecom Services• Broadcast “Blast” messaging• Monitoring services for 911, E911 or alarm telephone lines• Services to ineligible locations• End-user devices
– Cell phone, tablet computers
• Support for IA includes Internet Service Provider (ISP) fees as well as the conduit to the Internet
• Other eligible Internet Access services include:– E-mail service– Wireless Internet access– Interconnected VoIP– Web hosting
Internet Access (IA)
Priority One
• Costs for Internet content– Subscription services such as monthly charges for on-
line magazine subscriptions• Internet2 membership dues• Web site creation fees• Web based curriculum software• Software, services or systems used to create or edit
Internet content
Not eligible as Internet Access
Priority One
• Support for equipment and cabling on-site that transport info to classrooms or public rooms of a library
• Subject to the Two-in-Five Rule– Entities can only receive funding every two out of five
years
Internal Connections
Priority Two
Internal Connections
Priority Two
• Support for basic maintenance of eligible internal connections (BMIC)
• Such as:– Repair and upkeep of hardware– Wire and cable maintenance– Basic tech support– Configuration Changes
Basic Maintenance of Internal Connections
Priority Two
• Agreements or contracts must state the eligible components covered, make, model and location
• Service must be delivered within the July 1st to June 30th timeframe
• Two-in-Five Rule does not apply to BMIC
Basic Maintenance of Internal Connections
Priority Two
• Standard manufacturer warranties of no more than three years remain eligible.– If there is a cost associated with the warranty, then
the warranty is not eligible• Support for BMIC is limited to actual work performed
under the contract
BMIC Updated Guidance
Priority Two
• Applicants may make estimates based on:– Hours per year of maintenance– History of needed repairs and upkeep– Age of eligible internal connections
• Applicants using the factors listed above must submit a bona fide request
• It is not reasonable to estimate an amount that would cover the full cost of every piece of eligible equipment.
BMIC Updated Guidance
Priority Two
• Flat rate contracts may be eligible however, applicants may only invoice for services actually delivered/work performed.
• Exceptions that will not require demonstration that work was performed are: – Software upgrades and patches– Bug fixes and security patches– Online and telephone based technical support
BMIC Updated Guidance
Priority Two
• Miscellaneous charges can apply to all four Service categories and are funded in the category of the service they are supporting.
• Training is eligible when included as part of the contract and performed coincidently with the installation of the new service/product or in a reasonable time there after. – Training for end-users or professional development is
not eligible
Miscellaneous charges
Miscellaneous
• Taxes, surcharges and other similar reasonable charges are eligible for discount. This includes but is not limited to :– Universal Service Fund– Excise Tax– 911– Local Number Portability– Telephone relay service
Miscellaneous charges
Miscellaneous
• Other charges that are not eligible include but are not limited to:– Universal Service Administration Fee – Interest or finance charges– Late payment– Termination fees
Miscellaneous Charges
Miscellaneous
• Telecommunication Services and Telecommunications are two separate categories on the Eligible Services List (ESL)– Telecommunications Services can only be provided by
an eligible telecommunications carrier – Telecommunications can be provided by non-
telecommunications carriers via fiber in whole or in part
Telecommunications Services vs Telecommunications
Dark Fiber
• Leased Dark Fiber added as Telecommunications in the FY2011 Eligible Services List
• Allows for the lease of dark fiber as a priority one service, from any entity
• On the FCC Form 470, file for both Telecom and Internet Access
• On the FCC Form 471, select the Telecom box if the dark fiber is provided by a telecom carrier– In all other cases, select the Internet Access box
Leased Dark Fiber as Priority One
Dark Fiber
• Dark fiber must be lit immediately • Does NOT allow for unneeded capacity or warehouse
dark fiber for future use• Maintenance costs of dark fiber and installation costs to
hook up the dark fiber are eligible– This includes charges for installation within the
property line• Modulating electronics for leased dark fiber are not
eligible
Leased Dark Fiber as Priority One
Dark Fiber
Leased Dark Fiber as Priority One
Dark Fiber
• Installation costs to hook up the dark fiber is eligible from the eligible entity to the property line
• Special Construction charges to build out connections from applicants’ facilities to an off-premise fiber network are NOT eligible
Dark Fiber as Priority One
Dark Fiber
Dark Fiber as Priority Two
Dark Fiber
• Installation and Fiber costs between two eligible buildings, not crossing a public right of way are considered Internal Connections
• In general, equipment may not be transferred for money or any other thing of value
• A no-cost transfer may occur three years or more after the purchase of the equipment to other eligible entities
• No equipment transfer may occur prior to three years from the purchase, unless the eligible entity is permanently or temporarily closing
Equipment transfer rules
Equipment Transfers
• Notify USAC• Both the closing entity and the recipient must retain
records of the transaction– Include the reason for the transfer
• Records must be kept for five years after the date of the transfer
• Records for equipment >3 years follow the traditional document retention requirements
Equipment transfers less than 3 years
Equipment Transfers
• As of January 3, 2011, applicants can dispose of obsolete equipment, but no sooner than five years after the date the equipment is installed
• Resale for payment or other consideration is allowable no sooner than five years after the equipment is installed
• Resale or disposal is prohibited before the five years have passed.
Disposal of Equipment Rules
Disposal of Equipment
• Trade-ins of equipment may be permitted if the E-Rate funded equipment to be traded in has been installed for five years– This limitation does not apply for equipment not
funded through E-Rate
Trade-ins and Exchanges
Trade-ins and Exchanges
Questions?
Support from eTech Ohio
eTech Ohio E-Rate Support and Information
Lorrie Germann: 614-485-6050Mike Edwards: 614-485-6462
E-mail: [email protected] To subscribe to the E-Rate list, send an email with no
message to [email protected].