E-Rate Procedures and Program Compliance

 

1. A structured and team-oriented approach will be utilized in the oversight, management, and administration of the Edinburg CISD Erate Program responsibilities. The Erate Program Personnel Team will consist of the following Technology Department staff members:

Assistant Superintendent for Technology Services (Erate Program Compliance Officer)

Technology Assistant

Erate Specialist

Senior Security Engineer

Technology Inventory Specialist

Network Specialist 1

Network Specialist 2

Network Specialist 3

Computer Specialist

Federal Program Specialist

 

 

1. The Edinburg CISD Erate Program Personnel, Purchasing Department, and Internal Auditor will ensure that all competitive bidding practices for the Erate Program goods and services are “fair and open” and consistent with all of the Federal Communication Commission’s rules and requirements (see, e.g., 47 C.F.R. 54.50 (a), 54.511,54.513, and 54.523; and all pertinent FCC orders)

2. The Edinburg CISD Erate Program Personnel will adhere to all local, state, and federal “fair and open” bidding processes.

3. The Edinburg CISD Purchasing Department will review and confirm that all Erate RFPs, bids, proposals, and evaluations adhered to local, state, and federal purchasing procedures.

4. Conflicts of interest regarding any bid, proposal, or submission for Erate funding or other Erate related conduct in accordance with the Edinburg CISD Erate Compliance Policy or Erate Program Rules will be reported and/or disclosed to the Erate Compliance Officer immediately.

5. All Federal Communication Commission gifting rules as referenced by the Universal Service Administrative Company-School and Libraries Division will be strictly adhered. Non-compliance, known or suspected, will be reported to the ECISD Erate Compliance Officer immediately.

6. Edinburg CISD Erate Program Personnel will notify the Erate Compliance Officer in writing of any known, alleged, or suspected ECISD Erate Program Personnel affiliated with any ECISD Erate service provider or prospective Erate service provider.

7. Edinburg CISD Erate Program Personnel will notify the Erate Compliance Officer of any known, alleged, or suspected improper requested payments by ECISD or any ECISD Erate service provider or vendor for goods and services not provided, or overcharges for goods and services provided.

8. The USAC whistleblower telephone number will be publicized and an ECISD hotline will be available for ECISD Erate Program Personnel to report anonymously any known or suspected violations of Erate Program Rules.

 

 

1. The Erate Program Compliance Officer will attend yearly Erate information update held by the Universal Service Administrative Company-School and Libraries Division.

2. Erate Program Personnel will participate in periodic Erate trainings.

3. Proper procedures and updates in the management of Erate equipment and/or documentation will be reviewed periodically with Erate Program Personnel.

4. The Edinburg CISD Erate Program Personnel will subscribe to the School and Libraries Division News Briefs.

5. The Erate application process and procedures will be reviewed periodically with designated staff in the Edinburg CISD Purchasing, Finance, and Fixed Asset Departments.

 

 

1. The bills of material from the designated Erate vendor will be cross-referenced with Erate RFP Bid Specifications and/or any Certified Service Substitutions prior to generating an Edinburg CISD purchase order.

2. All Erate eligible equipment will be delivered to the Edinburg CISD Fixed Assets Department, inventoried, and an Edinburg CISD Asset Tag, which includes Edinburg CISD Fund Source and Purchase Order Numbers, will be affixed to Erate eligible equipment. At no time will Erate equipment will be delivered to any District location prior to tagging of equipment.

3. The Edinburg CISD Fixed Assets Department will maintain receivable inventory documentation for all new Erate eligible equipment inventory as required.

4. Serial Numbers for all Erate eligible equipment will be documented and maintained by the Edinburg CISD Fixed Assets Department.

5. Erate vendor delivery sheets will be cross-referenced with Edinburg CISD Purchase Order when equipment is received at the Edinburg CISD Fixed Assets Department.

6. A separate Erate Asset Identification Tag for Erate eligible equipment indicating the Erate Funding Year, Funding Request Number, Edinburg CISD Purchase Order Number, Edinburg CISD Fixed Asset Number, and the Edinburg CISD Campus Code Location will also be placed on Erate eligible equipment for efficient identification at Edinburg CISD Erate eligible entities.

7. A transparent color-coded label matching the designated Erate funding year color system may also be utilized as an Erate Asset Identification Tag for efficient identification.

8. Erate Program Personnel will coordinate dissemination and delivery of all Erate eligible equipment. At no time will vendors, subcontractors, or installation integrators pick up Erate eligible equipment from the Edinburg CISD Fixed Assets Warehouse. Erate eligible equipment will be delivered by Edinburg CISD Personnel to each designated Edinburg CISD Erate eligible entity for installation.

9. The Edinburg CISD Fixed Assets Department will only accept a signature confirming a delivery from a designated Technology Staff/Project Manager for Erate eligible equipment to an Edinburg CISD Erate eligible entity. Signatures from campus personnel will not be acceptable for Erate eligible equipment deliveries.

10. An Erate digital inventory database will be maintained by the Technology Department for Erate eligible equipment.

11. A Transfer Request Form will be utilized to track any necessary movement and/or maintenance (RMA) of Erate eligible equipment.

12. All Return Merchandise Authorization (RMA) documentation generated by Erate Program Personnel will be forwarded immediately to Erate Specialist and the Erate eligible equipment inventory will be updated accordingly.

13. Any equipment eligible for Cisco Return Merchandise Authorization (RMA) must be replaced to the same location from which it was originally removed.

14. A dedicated Erate storage room with surveillance camera will be maintained for any Erate eligible equipment removed from a campus.

 

 

1. A statement of work (SOW) will be submitted by an Erate eligible vendor to the Edinburg CISD Technology Department for review and approval prior to the start of any Erate implementation project.

2. A work approval form (WAF) will be completed by Erate vendors indicating the completion of an Erate eligible project.

3. Edinburg CISD Erate Program Personnel will review, confirm, and sign the work approval form (WAF) indicating that the Erate eligible work was completed according to statement of work (SOW) requirements.

4. Erate eligible vendors will submit digital copies of required installation ‘as built’ documentation to be archived in the Edinburg CISD Erate digital documentation library.

5. A digital copy of all Erate eligible documentation (Form 470s, RFPs, Form 471s, FRNs, BEAR forms, bids, purchase orders, delivery sheets, work approval forms, bills of material, statements of work, invoices, etc.) will be maintained as required by the Universal Service Administrative Company School and Libraries Division and Federal Communication Commission Erate Rules and Guidelines.

 

 

1. Periodic physical audits of Erate eligible equipment will be conducted by the Edinburg CISD Internal Auditor, Erate Compliance Officer, and/or designee using FRN, Purchase Order, ECISD #, etc. All information in the Edinburg CISD Erate eligible inventory database may be subject to audit.

2. An Edinburg Erate eligible equipment audit binder will be maintained to document and monitor progress.