Are there costs that the NDBEDP will not cover?

Yes. Please see “Examples of Reimbursable Expenses” for a list of expenses that are reimbursable and those that are not.

Does the NDBEDP reimburse for the cost of cables, switches, clamps, and adaptive accessories necessary to use the distributed equipment?

Yes. The reasonable costs of cables, switches, clamps, and adaptive accessories will be reimbursed by the NDBEDP if they are necessary for the consumer to use the equipment distributed. Personal accessories that facilitate or enable other life functions are not reimbursable (e.g., a wheelchair to facilitate mobility).

Are the costs of alerting devices reimbursable?

Yes. The reasonable costs of alerting devices such as flashing lights are reimbursable when they are necessary to use the equipment distributed to make telecommunications, internet access, or advanced communications accessible to low-income individuals who are deaf-blind. Assistive lighting that is used separate and apart from the distributed equipment is not reimbursable.

Are the costs for batteries or upgrades reimbursable for equipment that was not distributed by the NDBEDP?

Yes. The NDBEDP will reimburse for batteries or upgrades on previously distributed equipment (hardware, software, applications, etc.) as long as these are reasonable and necessary to make telecommunications, internet access, or advanced communications accessible to low-income individuals who are deaf-blind.

When an equipment recipient moves to another state, which state certified program will be responsible for the upkeep of the equipment?

When an equipment recipient relocates to another state, the former state’s certified program will no longer be responsible for upkeep of the recipient’s equipment, nor will it be permitted to seek reimbursement for maintenance of such equipment no longer in use within the former state. In such cases, upon the request of the recipient, the former state must transfer the recipient’s account and any control over the distributed equipment to the new state’s certified program. The certified program in the state where the recipient relocates then will be responsible for the cost of upkeep of the distributed equipment. If the recipient needs new equipment after relocating, the recipient will be permitted to apply for such equipment in the new state.

Is there a searchable national database that certified programs can use to determine if program applicants have received NDBEDP equipment in another state?

With the start of the permanent program, the FCC was tasked with developing a national database. Entities will be notified when it is operational. As noted above, when a recipient relocates to another state, upon the recipient’s request, the certified program must transfer the recipient’s account and any control of the distributed equipment to the new state’s certified program so that the individual need not reapply.

Could one person receive two identical pieces of equipment?

Yes. With appropriate justification (such as one for home and one for residential school housing), one person may receive two identical pieces of equipment; it is within the certified program’s discretion to determine how it will distribute equipment.

Do NDBEDP equipment recipients have a right to newer, better, or upgraded equipment when it becomes available?

No. However, each NDBEDP certified program has the discretion to determine whether it will provide newer, better, or upgraded equipment, with the reasonable costs of such upgrades and replacements being reimbursable. Because NDBEDP funding is not unlimited, certified programs may want to consider carefully how best they can use their limited funding to distribute equipment to the largest number of low-income individuals who are deaf-blind.

Will the NDBEDP provide reimbursement for an inventory of loaner equipment which would be available for use when program distributed equipment is being repaired?

Yes. Reasonable costs for an equipment loan program, to be used when previously distributed equipment is being repaired, are reimbursable, but a loan program is not required. Loaner equipment is reimbursed under Maintenance of an Inventory, which also includes equipment that is used for assessments, training trainers, and outreach demonstrations.

Can a certified program charge a client for damage to NDBEDP equipment, caused by the client’s negligence?

The NDBEDP rules neither require nor prohibit certified programs from charging a client for negligent damage to distributed equipment.

Can the NDBEDP certified program pay for a portion of a piece of equipment in conjunction with another program?

Yes, as long as the equipment is covered by the NDBEDP program rules and partial payment for the equipment is noted as part of the reimbursement request in reports to the FCC and/or TRS Fund Administrator.

Can the NDBEDP certified program pay for a portion of a piece of equipment in conjunction with another program, and the NDBEDP certified program cover the cost for the associated training?

Yes, as long as the equipment is covered by the NDBEDP program rules and partial payment for the equipment is noted as part of the reimbursement request in reports to the FCC.

If there is another funding source to pay for equipment, could the NDBEDP cover the costs of related services (such as training) associated with that equipment, even if the NDBEDP does not cover any part of the cost of the equipment?

No. To be reimbursed, related services need to be associated with the distribution of a piece of equipment that is covered under and paid for, in whole or in part, by the NDBEDP.

Does the NDBEDP reimburse the cost of providing interpreter or translation services for languages other than English or American Sign Language?

Yes, interpreter or translation services will be provided when they are needed to ensure effective communication with program clients and to facilitate equipment distribution and the provision of related services that are permissible under the NDBEDP.

Can the attestations for eligibility determination be made by e-signature?

Yes, to the extent that such form of signature is recognized as a legally valid signature under applicable federal law or state law.

How do we determine low-income eligibility when a student who is deaf-blind is not living with his or her family?

If the deaf-blind student could be claimed as a dependent by another taxpayer (as a qualifying child or qualifying relative), then the certified program should consider that taxpayer’s family or household size and income to make an income eligibility determination.

Can certified programs shift its certification to other entities?

No. Certification is granted to a single entity in each state that is eligible for reimbursement. While certified programs may contract with other entities to perform NDBEDP-related tasks, ultimately the certified entity remains responsible for ensuring that all NDBEDP-related tasks are performed and is the only entity authorized to receive compensation from the TRS Fund.

Is there a limit on the amount of money a certified program can spend on each client?

No, this is within the discretion of the program so long as each amount is reasonable.

If a certified program does not have enough qualified trainers in-state, can a qualified trainer be brought in from another state?

Yes. The NDBEDP will reimburse certified programs for a trainer’s reasonable travel costs.

Are the percentage caps for administrative, outreach, and train-the-trainer costs based on the certified program’s annual funding allocation or the certified program’s total reimbursable expenses?

The caps (15% for administrative, 10% for outreach, and 2.5% for train-the-trainer) are all based on the certified program’s total annual funding allocation and not on current reimbursable expenses.

Are the costs of renting physical facilities for the distribution of equipment or provision of related services reimbursable?

Yes. The cost of renting physical facilities is reimbursable as an administrative expense, subject to the 15% cap for administrative expenses.

How is “income” defined for the purpose of determining income eligibility for the NDBEDP?

“Income” is all income actually received by all members of a household. This includes salary before deductions for taxes, public assistance benefits, social security payments, pensions, unemployment compensation, veteran’s benefits, inheritances, alimony, child support payments, worker’s compensation benefits, gifts, lottery winnings, and the like. The only exceptions are student financial aid, military housing and cost-of-living allowances, irregular income from occasional small jobs such as baby-sitting or lawn mowing, and the like.

How is “household” defined as it is used within the definition of income for the NDBEDP?

A “household” is any individual or group of individuals who are living together at the same address as one economic unit. A household may include related and unrelated persons. An “economic unit” consists of all adult individuals contributing to and sharing in the income and expenses of a household. An adult is any person eighteen years or older. If an adult has no or minimal income, and lives with someone who provides financial support to him/her, both people shall be considered part of the same household. Children under the age of eighteen living with their parents or guardians are considered to be part of the same household as their parents or guardians.

Is the FCC asking for a higher than regular audit standard, such as a forensic standard, specifically designed to prevent and detect fraud, waste, and abuse?

No.

What kind of audit is needed to comply with the NDBEDP audit rule?

For purposes of complying with the NDBEDP audit rule, an independent auditor must conduct a program audit that includes a traditional financial statement audit, as well as an audit of compliance with the NDBEDP rules that have a direct and material impact on NDBEDP expenditures and a review of internal controls established to ensure compliance with the NDBEDP rules.

Compliance areas to be audited include, but are not limited to, allowable costs, participant eligibility, and reporting. The audit report must describe any exceptions found, such as unallowable costs, lack of participant eligibility documentation, and missing reports. The report also must include the certified program’s view as to whether each compliance exception is material and whether any internal control deficiencies are material.

If the auditor finds evidence of fraud, waste, or abuse, the auditor must take appropriate steps to discuss it with the certified program management and the FCC and report the auditor’s observations as required under professional auditing standards. This program audit standard is comparable to that required for Office of Management and Budget (OMB) Circular A-133 audits. We believe that such audits of NDBEDP certified programs, conducted annually by an independent auditor, will detect and prevent fraud, waste, and abuse, which will satisfy the NDBEDP audit rule.

Would an audit performed in accordance with OMB Circular A-133 comply with the NDBEDP audit rule?

Questions about whether the Single Audit Act applies to the Interstate Telecommunications Relay Service Fund (the TRS Fund) and whether reimbursement of NDBEDP expenses from the TRS Fund should or should not be included in an OMB Circular A-133 audit should be directed to OMB. However, because the program audit criteria described above are similar to that of an OMB Circular A-133 audit, an audit performed in accordance with OMB Circular A-133 will satisfy the NDBEDP audit rule.

Telecommunications Carriers receive invoices, July through June, for their share of the annual budget of the Interstate TRS Fund. The assessments are calculated and invoiced based on information provided to, or estimated by, the Universal Service Administrative Company’s (USAC) Form 499-A annually by April 1st. Contact, revenue, and other information provided on the form is provided monthly to RolkaLoube to account for any updates, assessments are calculated, and invoices due to the Interstate TRS Fund are sent out by email, unless an email address is not provided on the Alternative Billing Arrangements Form, Form 499-A line 208, 208.1, or 212. The email contains instructions explaining how to make a payment through Rolka Loube’s invoice and payment portal. Carriers receive an introductory message prior to this email as well. If you have any questions, please visit our TRS FAQs page.

For the 2021-2022 program year, the fund will calculate the Carrier Contribution Factor applicable to assessments invoiced July 2021 – June 2022 based on two factors (factor one to cover non-IPCTS related costs and the second factor to cover IPCTS related costs). The rates are as follows:

• 0.01331 covering non-IPCTS related costs to the TRS Fund (based on line 514b of Form 499A)

• 0.00831 covering IPCTS related costs to the TRS Fund (based on line 514a of Form 499A)

The Carrier Contribution Factors applicable to assessments invoiced July 2020 – June 2021 are 0.01360 for non-IPCTS related costs and 0.00962 for IPCTS related TRS costs per FCC Order DA- 20-692A1.

The Carrier Contribution Factor applicable to assessments invoiced July 2019 – June 2020 is 0.02779 per FCC Order DA-19-607

The Carrier Contribution Factor applicable to assessments invoiced July 2018 – June 2019 is 0.02801 per FCC Order DA-18-680.