Contacts with SLD

I think we all need to be very cautious in our contacts with SLD. During the E-Rate application process, you can be contacted by any number of SLD personnel from Problem Resolution or Program Integrity Assurance. While I would encourage you to be cordial with these individuals, after all, they are just doing their jobs, I think it's important that their jobs are not necessarily to help you through the E-Rate process. Instead, it may often seem that it's their job to see that your application is not successful. That's unfortunate but in this process they're looking for problems or gotchas. So, I see our job as making sure that we give them as few potential gotchas as possible.

My first piece of advice is to conduct all transactions with PR and PIA officials in writing. You can do it by fax or email - whatever's your preference. But you want to have written copies of all transactions. That way if your application is rejected and you need to appeal, you have a written copy of your interactions for the appeal. You can be sure that SLD personnel are taking notes of their conversations with you for the record. If your powers of recall are anything like mine, you don't want your appeal to depend on your fuzzy recollection of "I think I told him that I'd sent the certification form in January."

Second, only give them exactly what they ask for at the time - nothing more, nothing less. That's another way that written interactions can help. You're less likely to get chatty by email and start talking about something that might come back to bite you later. Remember anything you say can and will be used against you.

If you should happen to be chosen for a site visit, please let me know. Site visits often lead to audits so we want to be prepared.

Chance to Resubmit BEAR Forms

The following advice comes from Linda Schatz. I'm not sure if it applies to any Montana libraries. But, just in case someone received a BEAR notification with zero dollars funded, I'll pass it along.

I would advise the following:

1. Have your applicants look carefully at their BEAR notification letters. They should check carefully to make sure they received the entire amount that they requested on the BEAR they submitted.
2. If they were zero funded for any and/or all lines of the BEAR form(s) they submitted, they should immediately re-submit the BEAR form. They should carefully review the Form 472 Instructions to make certain they have correctly completed the form. (One of the common problem seems to be that folks are filling out both column 12 and 13.)
3. They should refile the BEAR forms just as soon as possible but no later than January 29.

We'll see what additional problems arise and will add them to the next call with the SLD. I suspect that not having letters reissued in those situations where folks have already been $0.00 funded is going to be a problem but, in the meantime, let's make sure folks get those BEARs refiled in those cases where they can figure out what the problems were. The good news is they won't also have to submit requests for extensions as long as they get them in by January 29.

And, since they're extending the BEAR deadline for these resubmissions, it probably wouldn't hurt to submit a BEAR form for last year if you missed October 28 deadline.

Possible changes ahead in DSL charges

The word came this week from the E-Rate person at Mid-Rivers that they would no longer unbundle charges for internet access lines from internet service charges. Apparently, this is in response to an FCC decision from 2005 DSL lines are no longer regulated. Many libraries have taken advantage of the fact that DSL/T1 lines were considered regulated telecomm services to apply for these under Telecommunications Services in E-Rate.

I wouldn't be surprised if other telecomms take this stance. So, be prepared to face CIPA yet again.

Libraries faced with this unbundled internet access have a couple of options:

1. Drop internet from your e-rate requests and apply for just basic telephone service - local, long distance, cellular. The added advantage of this approach is that you don't have to worry about technology plans. As SLD seems to be cracking down on tech plans, I find this an attractive option.
   
2. Apply for discounts for internet under Internet Access. You may need to file a new Form 470. Luckily you still have time to do so for this funding year.
   

• Libraries with Mid-Rivers as a telecomm/internet service provider will have to have a request under Internet Access to receive discounts for their DSL lines in this upcoming funding year. You'll apply for local and long distance under Telecomm and High speed internet access under Internet Access. The quote from Mid-Rivers will include both DSL and monthly internet.
  
• Other libraries would be well-advised to list "high speed internet access" in their Form 470 under both Telecomm and Internet Access just in case their providers decide to go this route. This is, of course, in direct contradiction to what I've told some of you already. But if you want to keep internet discounts (or at least keep this option open), you may need to be prepared to go along with whatever your provider decides. It's not like there's a lot of competition out there in most of our communities.

But, keep in mind, that accepting discounts in the Internet Access category requires you to comply with CIPA, including installing CIPA-compliant filters on all computers with internet access. And having a public meeting over a CIPA/NCIPA-compliant Internet Use Policy.

There is another plus to having to file a new Form 470 for those of you who are keeping internet access as an option, it gives you a chance to take a look at your tech plan and assign it a creation date prior to your Form 470.

Letters of Agency

You may need to have a letter of agency on file in case of PIA review.

Some public libraries do not actually pay the bills for their libraries. The bills are paid by the city or county instead. The city or county is thus the billed entity NOT the library. Note the comment next to block 1 on Form 471: "(The 'Billed Entity' is the entity paying the bills for the services listed on this form.)" So, in many cases, the city or county should probably be filing the E-Rate forms instead of the library.

I think we can anticipate how eager most of our city/county officials would be to take on E-Rate paperwork. One option is for the librarian to do the paperwork for the city/county billed entity, but have an authorized representative of the city/county sign and certify the application. I wouldn't be too surprised, however, if city/county officials were reluctant to take on the onerous certifications. Look for a post on certifications in the future.

Another option for them is to sign a letter of agency whereby the librarian has explicit authorization to file for E-Rate on the city/county's behalf. Here is information from the SLD website on what such a letter of agency should contain with some modifications by me:

Whatever the form of the document establishing the above authorization, it must contain all of the following:

• The name of the person filing the application (i.e., the librarian)
  
• The name of the person authorizing the filing of the application (the entity who will receive discounted services, such as a city/county official)
• The specific timeframe the LOA or authorizing document covers (for example, the E-rate Funding Year 2003)
• The signature, signature date, and title of an official who is an employee of the entity who is authorizing the filing of the application (the entity who will receive discounted services, such as the city/county)
• The type of services covered by the LOA or authorizing document. The description of services can be as general as "all E-rate eligible services" or it can be more restrictive (e.g., "basic telephone service only").

The letter of agency needs to be signed and dated prior to the filing of the Form 470. And the timeframe cannot be open-ended.

WebJunction for Technology Planning

In my previous post about tech planning, I neglected to mention WebJunction as a resource.

I think TechAtlas will also prove a useful tool with it's new upgraded features. Reportedly, it will help you create a technology plan that meets SLD criteria.

There's an online training session on TechAtlas 2.3 scheduled for Wednesday, Nov. 22. Sign up here.

I'll post information about what I learn from this session.

Technology Planning

It's time for most of you to be looking at updating your technology plans again. They need to be updated every 3 years so you might want to check on the date of your last approval letter.

The deadline for having them approved is before services start (for most applicants July 1, 2007) AND the Form 486 is submitted. So, if you get your Funding Commitment Decision Letter (FCDL) on May 1, 2007 and want to file Form 486 early so your discounts can start right away on July 1, you need to already have submitted your technology plan and had it approved before you start on Form 486.

Also, your technology plan should have been "prepared" before you file Form 470 for this upcoming funding year. So, I would suggest you pull out your old technology plan, make obvious changes that need to be made and date when you made the changes on the revised technology plan. This date needs to be before you file Form 470. The idea is that you go through the technology planning process to determine what your needs are for the next three years and look at your budget to see what you can afford and then order services on that basis.

If you're planning on adding additional DSL lines or increasing your bandwidth, make sure that's indicated in your tech plan.

Some reminders-

1. No tech plan required for basic telephone services
   Local, cellular/PCS & long distance (wired or wireless)
   
   
2. All tech plans need to include the following 5 criteria:

• The plan must establish clear goals and a realistic strategy for using telecommunications and information technology to improve education or library services;
• The plan must have a professional development strategy to ensure that staff know how to use these new technologies to improve education or library services;
• The plan must include an assessment of the telecommunication services, hardware, software, and other services that will be needed to improve education or library services;
• The plan must provide a sufficient budget to acquire and support the non-discounted elements of the plan: the hardware, software, professional development and other services that will be needed to implement the strategy; and
• The plan must include an evaluation process that enables the school or library to monitor progress toward the specified goals and make mid-course corrections in response to new developments and opportunities and they arise.

SLD also has Questions to Consider in Technology Planning. You might want to go through some of these with your staff and board. And make note of your available budget to support the technology - undiscounted telecommunication costs, staff development, hardware/software upgrades, etc. If you plan to use federation funds, make note of how much is available.

We have been using Technology Planning on the Lite Side to meet these criteria. Plans written using this formula will no longer be accepted as they fail to meet SLD's more stringent review.

But, in the meantime, you need to have a new tech plan prepared now.

2007 filing dates

The Form 471 application filing window for Funding Year 2007 (July 1, 2007 to June 30, 2008) opened at noon EST (10 am MST) on Tuesday, November 14, 2006 and will close at 11:59 pm EST (9:59 pm MST) on Wednesday, February 7, 2007. The filing window will be open for 86 days.

Remember that your Form 470 has to be posted online for 28 days before you can file Form 471. You'll receive an allowable contract date by mail or you can check online using the Form 470 Search Posted function.

1. Select the year.
2. Enter your entity number
3. Click next
4. Click on the circle next to your library name
5. You'll see the Allowable Contract Date listed in the top box.
   

Whatever you do, don't sign any contracts or file or date a Form 471 prior to this date.

If you have an RFP, that RFP must be available for 28 days as well.