Minutes from the Wednesday Service Provider Conference Call
March 26, 2003

The call in number is: (847) 413-2931

Pass code: 1390177#

WHISTLEBLOWER

Q.

Can we get e-mail access to the Whistleblower Hotline?

A.

We prefer phone calls to our 1-888-203-8100 number; however, you may send any code 9 referrals to the serviceprovider email and flag it as a whistleblower message.

Q.

How are whistleblower calls handled?

A.

When we receive a Code 9 call, we log all information received during the call. We would prefer for you to identify yourself so if further details are required during the investigation we are able to contact you, but we will accept anonymous calls. The case is then assigned to one of the investigators.

Q.

Who determines if the allegation has merit?

A.

The team of investigators review the information received and determines if the allegation has merit.

Q.

Why are service providers that have been identified through the whistleblower hotline as violating program rules still able to conduct business and participate in the e-rate program?

A.

If we can document reported violations; we will deny all FRNs associated with the service provider in question. If there is a pattern of intentional violations, we refer the case to the Office of the Inspector General. But we have no basis today to debar program participants. We would need future direction from the FCC.

Q.

What action can a service provider take when it thinks that competitors are making unfounded whistleblower calls against it merely to taint the service provider?

A.

This is a rare case the whistleblower hotline receives one call out of a hundred that might be unfounded. SLD can also generally spot this type of situation. The best thing to do is for the applicant and service provider to cooperate fully with any request from us for information.

FUNDING COMMITMENTS

Q.

What is the status of the March 10 goal on FY 2002 commitments?

A.

We don’t have a report on that. The goal had exceptions for applications that raised policy issues or where we were waiting for information. We are sending out letters today to applicants and service providers where applications will require continuing investigation.

Q.

When will FY 2002 be completely funded?

A.

We don’t have a date at this time.

Q. 

What can we expect from the next wave in $ amount?

A. 

We will not know until the funding threshold gets resolved.

Q. 

What is the $ disbursement for the current year?

A.

We've authorized disbursement in the amount of $244.7 million.

REVIEW OF APPLICATIONS

Q.

Why doesn’t the SLD communicate with the applicant and service provider during the review process in order to allow the service provider or applicant to assist in clearing potential problems?

A.

We do reach out in the vast majority of cases when we need additional information. When we are investigating allegations of abuse, we often can’t communicate without compromising the investigation.

Q.

Can a procedure be developed to keep applicants and service providers more informed about the process?

A.

We are sending letters out today to improve how we communicate on applications where continuing investigation is required. That may be a report we could use in future Funding Years.

Q.

What are the top reasons that hold applications up in selective review?

A.

- Getting information back from applicants in a timely manner.
- Receiving incomplete answers.
- The volume of information for us to analyze, although we have increased the staff dedicated to those reviews.

Q.

Why has there been an increase in paper review of applications that burdens those service providers who have complied with the program rules?

A.

The 2000 GAO report criticized us for not having adequate information to make sound decisions on applications. In addition, findings from the beneficiary audits are raising concerns. We have to ensure that we have a sound basis to commit funds or deny them.

ITEM 21 ATTACHMENTS

Q.

What are the top 5 reasons that hold applications up in regular review?

A.

The top five reasons were all identified as the item 21 attachment. This is an area that SLD will be working internally and with the applicant and service provider community for improvement. Each Form 471 Block 5 Discount Funding Request must include a description of the products and services for which discounts are being sought. This description is known as an "Item 21 Attachment." Clear and complete Item 21 Attachments allow an efficient review of funding requests so that prompt funding decisions can be made. Incomplete or unclear Item 21 Attachments slow the decision process, to the detriment of applicants and service providers. Several different formats are possible for the Item 21 Attachment. The Attachment is generally a line item listing of the products and/or services requested, with associated costs, and preferably includes a narrative description of the purpose of the funding request, and any special conditions that apply. We encourage the service provider to assist the applicant in preparing the item 21 attachment. Click here to view some examples of the item 21 attachment.

INVOICING

Q.

What are the top 5 reasons why invoices cannot get paid faster?

A.

These are the top five reasons we’ve identified:

Q.

Why do some invoices take 90 days to review?

A.

Q.

What is the status of invoice extension deadlines?

A.

Q.

Why do service providers have to provide two invoice samples, plus a description of items on the SLD invoice, plus a description of the functionality of the items on the SLD? I thought that the description and functionality were addressed on the applicants' forms 470 and/or 471.

A.

Form 470 and/or Form 471 attachments do not always adequately describe the functionality of the equipment eventually delivered but the invoice provided by the service provider should clearly indicate the program eligibility to enhance invoice review efficiency. In cases where discrepancies occur adequate and complete documentation to support eligibility for payment is required.

(Example SLC invoice 369243)

OTHER ISSUES

Q.

How can we lobby for additional staffing for the SLD?

A.

SLD believes that it is on track to meet its April 15, 2003, goal, which is to have a 90 day turn around period on appeals, but there is a lot of work to do.

Q.

What is the status of outstanding appeals?

A.

SLD believes that it is on track to meet its April 15, 2003, goal, which is to have a 90 day turn around period on appeals, but there is a lot of work to do.

Q. 

What does Commissioner Abernathy's recent call for a public forum on improving the administration of the e-rate program mean to service providers and is there anything that service providers can do to respond?

A. 

This is within the purview of Commissioner Abernathy’s office. There is a FCC public notice released for those of you who are interested in obtaining more information.