RHC Broadband Funding Options

Transcription

1 1 RHC Broadband Funding Options 1 2 Who We Are Founded in 1990 as Kellogg Consulting, LLC Superintendents requested Telecom Consulting, Grant applications for Technology and Distance Learning, and Technology Training for education 1996 Changed Name to Kellogg & Sovereign Consulting, LLC 1998 Asked by school superintendents to add E-rate application filing 2002 Focused only on E-rate Application Filing 2007 Added Rural Healthcare at the request of a hospital Medical Director 2016 E-rate Requests = $76,019, RHC Requests = $4,627, # of States = We Represent the Applicant Review past history with USAC if any to determine if any approved funding has not been disbursed from previous years Provide current information regarding USAC program rules Review physical locations and verify eligibility Identify services to be included in request Develop professional, thorough Request For Proposals RFP(s) Provide bidding guidance HCP makes final decisions Review contracts for compliance Prepare a comprehensive application that meets all USAC rules Guide HCP through the submission process to ensure the application is certified and is submitted appropriately Track the progress of applications and respond to all Program Integrity Assurance questions If necessary, file appeals on the HCP s behalf to either USAC or the FCC. Once funding is approved, work with the HCP to access all available funding File post funding documents required to receive the approved funds Others as necessary Do not sell any services or equipment eligible for RHC funding Kellogg & Sovereign Consulting

2 4 Why You Want to Know More Rural Entities Struggle to deliver high quality healthcare Difference between E rate and RHC significant Both are critical for broadband deployment Both under the new FCC Chairman s scrutiny However, both fall within his focus: In my first remarks as Chairman of the Federal Communications Commission to the agency s terrific staff, I stressed that one of my top priorities would be to close the digital divide the gap between those who can use cutting edge communications services and those who do not. Anticipate additional funding in RHC due to Rural Focus Both telecommunications and Infrastructure Equipment 4 5 USAC Programs Four Programs High Cost Program provides support to eligible telecommunications companies that in turn offer service to consumers in hard to serve, rural areas at rates that are comparable to those available in urban areas. The Lifeline Program provides support to telecommunications companies that in turn offer discounts on telecommunications services to eligible consumers. Most recently provided free cell phone. Proposed to change to hot spot s. The Rural Health Care (RHC) Program provides support to eligible rural health care providers (HCPs) that qualify for reduced rates for telecommunications services and broadband access. This allows HCPs to pay rates for telecommunications services similar to those of their urban counterparts, making telehealth services affordable in rural areas. The Schools and Libraries Program, commonly known as the E rate Program, provides support to eligible schools and libraries that qualify for reduced rates for telecommunications, telecommunications services, Internet access, internal connections, and basic maintenance of internal connections. 5 6 Same Service Provider Role Service providers submitting bids are prohibited from any involvement in: Setting bid evaluation criteria; Participating in the bid evaluation or vendor selection process (except in their role as potential vendors); Or preparing, signing, or submitting an HCP's FCC Form documents. 6 Kellogg & Sovereign Consulting

3 7 Comparison E-rate and RHC E Rate RHC $3.9 Billion Details E rate $400 Million Details RHC Specific Filing Window 2/27/2017 to 5/11/2017 FY 17 1 st Window 3/1 to 6/30/2017 Two Funding Categories E rate Two Programs Telecom and HCF Category One Telecommunications Telecom Telecom and IA Category Two Infrastructure Equip and MTC HCF Telecom. Equip & Mtc 470, 471, 472, 473,474, Forms Telecom (Individual Forms 498, 500 HCP's) 465,466,467,SPI Forms Forms HCF (Ind. & Consortia) 460,461,462,463 SP Forms 473,474,479, 498, 499 A, SP Forms 498,499 A, 499 Q EPC Portal RHC Portal Contracts Annual or Multi year Contracts Annual, Multi year, Evergreen 7 8 Rural Healthcare Programs $400 million in funding available Two Federal Programs available for eligible health care providers: Telecommunications Program created in 1997 Healthcare Connect Fund created in 2012 w/pilot Healthcare Connect Fund available to all HCP s Previously, Funding goes unclaimed In the past, half of the funding available went unclaimed each funding year Many eligible Health Care Providers Don t think they are eligible for funding Don t know how to initiate the funding process Are in an existing contract and think they can t get funding for eligible services 9 9 Kellogg & Sovereign Consulting

4 10 Documents Listing & More! Proof of Eligibility (If no 460 in Proof of Eligibility: the HCF Program): Business license Portal Registration IRS not-for-profit determination letter & 990 Business license IRS not-for-profit determination Bid Criteria letter & 990 Bid Evaluation Grid Third Party Authorization (TPA) RFP with applicable Attachments A-G Community Mental Health Center (CMHC) Ck List 10 See Document List for Download on Website Basic things to know Eligible Health Care Provider Same for both programs Must be in a rural census tract, unless an urban participating in a consortium Funding ranges from 65 to 90% What is eligible for funding depends on the program in which applicant participants Basic things to know YES, the healthcare entity can participate in both programs simultaneously The Healthcare entity cannot get funding for the same service in both programs If in both programs, must be aware of both programs rules and be compliant Kellogg & Sovereign Consulting

5 Funding Year Cycle Funding starts July 1 each year Funding ends June 30 each year FY2017 is July 1, 2017 to June 30, 2018 FY2018 is July 1, 2018 to June FY2017 Program Calendar January 1 First day to submit FCC Forms 461 (HCF Program) and FCC Forms 465 (Telecom Program) and supporting documentation for FY2017. March 1 First day of the initial FY2017 filing window period. Applicants may begin submitting FCC Forms 462 (HCF Program) and FCC Forms 466 (Telecom Program). June 30 Last day of FY2016. Last day to submit FCC Forms 462 (HCF Program) and FCC Forms 466 (Telecom Program) during the initial filing window period for FY2017. Additional filing window periods to be determined based on funding demand. December 31 Last day to submit FCC Form 463 for Funding Year 2016 funding commitments ending on June 30, Eligible Health Care Provider Not for profit hospital Rural health clinic, including mobile clinics Community health center (FQHC) Community mental health center Local health department Post secondary educational institution offering health care instruction Emergency room of a rural, for profit hospital Kellogg & Sovereign Consulting

6 Eligible Health Care Provider Eligibility is determined for each entity individually By physical location What health care services are provided at that physical location? What is the address of that physical location? Rural Urban Competitive Bidding Required Appropriate program form posted to USAC website If RFP required or desired by the applicant must be available to all bidders Bidding window is 28 days long Questions submitted and answered When bidding closes bids are evaluated by eligible criteria Bidders notified of acceptance Contracts signed 17 Most Cost-Effective The method that costs the least, after consideration of the features, quality of transmission, reliability, and other factors that the health care provider deems relevant to choosing a method of providing the required health care services Kellogg & Sovereign Consulting

7 OUSF Lowest Cost Reasonable Qualifying Bid (LCRQB) For purposes of this act, 17 O.S (B)(7), "lowest cost reasonable qualifying bid" means a bid that: represents the lowest total cost proposal including monthly recurring and nonrecurring charges for eligible services, is reasonable to meet the needs of the Oklahoma Universal Service Fund Beneficiary as listed in the request for bids, is submitted during the same competitive bidding period as the awarded bid,* *Derrel Fincher OCC 19 Standing Bid Applicant is already under contract Contract is not the result of the applicant filing a Form 465 and posting to USAC website Pre existing contract is considered a standing bid by USAC when applicant undergoes competitive bidding the first time Contract is a standing bid Applicant must accept other bids for service and choose the most cost effective Standing Bid If existing contract is not the most cost effective, no funding available for services through that contract Funding is only available for the contract that is the most cost effective Motto: doesn t hurt to ask Kellogg & Sovereign Consulting

8 Evergreen Contract Both parties are identified; HCP has signed and dated the contract; Contract specifies the type and terms of service; Contract has a specified duration; Contract specifies the cost of services to be provided; and Contract includes the physical addresses or other identifying information of the HCPs purchasing from the contract Evergreen Contract Applicant who has an Evergreen Contract is not required to competitively bid again until the initial contract term has expired. Bidding is required again once the initial contract term has expired Check the evergreen contract expiration date USAC provides very carefully Almost always wrong Determine Rurality Eligible Rural Areas Search on USAC website, arch/search.asp Choose Oklahoma and view the list of counties If county says Rural all physical locations in that county are rural no further action needed If county says Urban all physical locations in that county are urban if eligible HCP must participate in a consortium to get funding If county says Rural in only in , you must determine census tract Kellogg & Sovereign Consulting

9 Using the tool Compare the Census Tract in the result to USAC s website listing. If census tract is included in list of rural census tracts; location is rural. Otherwise, it is urban Kellogg & Sovereign Consulting

10 28 Telecommunications Program Telecommunications Program Mileage based discounts OR Urban/Rural differential Telecommunications Program Telecommunications Program Original funding program based on 1996 Act Annual filing requirement for applicants Funding is available for telecommunications services Two options for funding Mileage Based funding request Urban/Rural Differential Kellogg & Sovereign Consulting

11 Telecommunications Program (cont d) Service Provider must have Eligible Telecommunications Provider (499) Filer status in order for services to be eligible for funding Cable companies are generally not eligible Service provider solely responsible for invoicing USAC post receipt of HCP support schedule Basic Application Steps: Telecommunications Program Eligibility & Competitive Bidding Form 465 Report services chosen Form 466 Confirm services received Form Eligible Expenses (Telecom) PRI T 1, DS3, OC3 MPLS Ethernet Fiber Primary Circuit and or Redundant Circuit Standard installation expense (less than 5K) Any telecommunications service with an urban/rural differential is eligible for funding! Kellogg & Sovereign Consulting

12 Eligible Expenses (Telecom) Funding to the physical location of the HCP only Funding is not available for service to a device Air cards for I pads, laptops, etc. Cell phones, blackberries, etc. No funding for broadband equipment Routers, firewalls, switches, etc. (ONLY in HCF) No funding for internal connections Wifi repeaters throughout building No funding for infrastructure upgrades Two ways to calculate funding Mileage Based Funding per mile of circuit Subtract standard urban distance Urban/Rural Differential Service provider provides similar urban rate Or can use Tariff rates Funding is difference between urban and rural rate Standard Urban Distance Each state has a standard urban distance (SUD) sp Mileage based funding is calculated as follows: Information from service provider invoice: Channel Termination Charge $ x 2 = 200 Mileage Charge for T1 connection = $3,000 Total miles billed = Kellogg & Sovereign Consulting

13 Standard Urban Distance Calculations: Cost Per 3,000/50 = $60.00 per mile SUD = 21. Mileage eligible for funding: = 29 Funding is: 29*$60.00 = $1, per month Urban/Rural Differential Rural rate urban rate = funding amount Rural rate is all expenses related to the eligible service (channel termination, mileage, taxes, surcharges). Best results is when the comparison is done an apples to apples bases. If the rural entity has a 60 month contract, the urban rate should be a comparable 60 month rate USAC has safe harbor rates on its website for a few services. Prices are based on MTM tariff rates Use only as a last resort Positive: Simple math compared to mileage based Negative: difficulty for applicant to obtain best urban rate Kellogg & Sovereign Consulting

14 Urban/Rural Differential Rural Rate = $3, using previous example For this example, lets say this is a T1 connection on a 60 month contract USAC s MTM urban rate is $ per month rbanrates/2017/result.asp $3,200 $ = $2, per month Cox T1 pricing for 60 months is $ per month in Tulsa using 2011 tariff $3, $ = $3, per month Funding Commitment Letter The letter from USAC indicates the following: Confirmation of eligibility of expense item Calculation of Funding Evergreen Contract Status Month to Month (MTM) If MTM, must competitively bid again by June 2nd prior to start of next funding year Evergreen If Evergreen, must competitively bid again at least 29 days prior to contract expiration Remember, USAC usually has incorrect contract expiration date FCC Form 467 The Funding Commitment Letter is NOT the last step in the process Form 467 confirms that services were received Can modify start date of service to actual installation date Can modify end date if circuit has been terminated This form must be filed order funding will be rescinded Kellogg & Sovereign Consulting

15 Things to keep in mind The Telecommunications program is administratively intensive Expect the funding to come six to nine months after filing a funding request File EARLY! Best chance of getting funding committed prior to the end of the funding year Healthcare Connect Fund Healthcare Connect Fund 65% flat funding Individual Only Rural Broadband & CPE only Consortium Rural and Urban Lots of expenses eligible Healthcare Connect Fund Two Options for Funding Kellogg & Sovereign Consulting

16 Healthcare Connect Fund The FCC created the HCF with three main goals in mind: 1. Increase access to broadband for HCP s, particularly those serving rural areas 2. Fostering the development and deployment of broadband health care networks 3. Maximizing the cost effectiveness of the program Healthcare Connect Fund Major differences compared to Telecommunications Program 1. Flat percentage of 65% for eligible expenses 2. Broadband and equipment eligible for funding If requesting funding for equipment, broadband must also be funded by HCF 3. Up to three funding years on a single commitment 4. Broadband to off site admin office and off site data center eligible for funding 5. Individual applicant (must be rural) OR consortium applicant (rural and urban) Basic Application Steps: HCF HCP Eligibility Form 460 Competitive Bidding Form 461 Report services chosen Form 462 Invoicing Form Kellogg & Sovereign Consulting

17 Consortium Driven Approach Drawing on our Pilot Program experience, we implement a Healthcare Connect Fund that will encourage HCPs to work together to preserve and advance the development of health care network across the country Encouraging Consortia 1. Urban entities eligible to receive funding too Funding restricted for urbans if the consortium is not at least 50% rural within three years Large hospitals (400+ beds) funding capped 2. More expenses are eligible for funding for consortia participants Equipment necessary to manage, maintain and control the broadband network Upgrade facilities Ownership of facilities (construction of new facilities, IRU purchase, etc.) Eligible Services Expense Type Individual Consortium Reasonable and customary installation YES YES (Less than $5,000) Lit Fiber Lease (not ownership) YES YES Dark Fiber Lease (not ownership) YES YES Dark Fiber Ownership NO YES Connection to Research and Education YES YES Network Connections to and between off-site data centers and admin officers YES YES Kellogg & Sovereign Consulting

18 Eligible Services (cont d) Expense Type Individual Consortium Upfront charges for deployment of new NO YES or upgraded facilities HCP constructed or owned facilities NO YES (which includes IRUs) Premise based broadband equipment YES YES (small router, small firewall) Equipment necessary to manage, control or maintain broadband service or dedicated broadband network NO YES Evergreen Contract Applicant who has an Evergreen Contract is not required to competitively bid again until the initial contract term has expired. Check USAC s start and end date for the evergreen contract determination almost always wrong When initial contract term has expired, may use voluntary contract extension without undergoing new competitive bid The requirements in HCF are different than in the Primary (Telecom) Program! FCC Form 460 A single form used just to collect information on the entity participating in the program (eligibility verification Collects physical location and other statistical information Once filed, only needs to be re filed if any of the information collected on the form changes Should be updated within 30 days of change Does NOT serve the same purpose as the 470! Kellogg & Sovereign Consulting

19 FCC Form 460- Consortium One form for the Consortium itself One form for each physical location participating Each HCP, eligible and ineligible, get their own HCP identification number by USAC Then connect each HCP to consortium Letter of Agency upload FCC Form 461 Consortium Applicants Competitive bidding document Minimum posting period is 28 days Can choose a longer posting period of desired Will always need to competitively bid unless under an existing evergreen contract Will always need to post a Request for Proposals if undergoing competitive bidding Network Plan is required FCC Form 462 Individual One form per service provider Can be a single expense request Or can be a multiple expense request Use Network Cost Worksheet Funding cannot exceed: More than three funding years Beyond the contract term Administratively burdensome on USAC Expect your funding request to take 3 6 months to process depending on when you file the request Kellogg & Sovereign Consulting

20 FCC Form Consortium One form per service provider Network Cost Worksheet to claim expenses Funding cannot exceed: More than three funding years Beyond the contract term If the request if filed correct, can be processed in less than a month Requests with errors usually processed in three months or less FCC Form 463 Initiated by the Applicant Counter signed by Service Provider Reviewed by USAC Documentation is not required but you have the option to upload documentation Invoice Letter of explanation Payment is directly to the service provider All Form 463 s must be submitted and counter signed by service provider within 6 months of end date of the FCL Sites/Service Substitutions An HCP may request a site or service substitution if: The substitution is provided for in the contract, within the change clause, or constitutes a minor modification; The site is an eligible HCP and the service is an eligible service; The substitution does not violate any contract provision or state, Tribal or local procurement laws; and The request change is within the scope of the controlling request for service, including any applicable request for proposal used in the competitive bidding process Kellogg & Sovereign Consulting

21 Site/Service Substitutions For consortium applicants it is possible to do a site/service substitution within an existing FCL if there are un used funds 1:1 swap Decrease in cost for certain line items makes funds available to reallocate to a new line on the network cost worksheet Otherwise the site/service substitution will be a new funding request because it is new dollars For this to work, the contract must have evergreen status Must file the funding request in the funding year in which the new service starts; otherwise lose funding Voluntary Contract Extensions Healthcare Connect Fund only A voluntary contract extension must be Documented in the original contract Must be of a certain term month to month does not count Applicant may choose to invoke a voluntary contract extension in lieu of initiation a new round of competitive bidding Cannot exceed more than five years The decision to use a voluntary extension must occur prior to filing a Form 462 requesting funding Voluntary Contract Extension Example One Initial contract term is five years Contract allows for 2, two year voluntary extensions Can get funding for extension 1 for two years Can then get funding for extension 2 for two years Example Two Initial contract term in three years Contract allows for 3, two year voluntary extension Can get funding for extension 1 for two years Can they get funding for extension 2 for two years Can then get funding for ONE year of extension 3. Last year of third voluntary extension is not eligible for funding Kellogg & Sovereign Consulting

22 Planet Bids Online Bid Portal Electronic bid notification, registration and bid filing. All KSLLC clients will be using this system to manage the RFP process. 1. Create a company login 2. Search for posted opportunities 3. Download all files associated with the RFP This will register you as a bidder for the opportunity. 4. Use the portal for all questions you have on the registered opportunity. 5. Submit all required bid documents electronically through the portal prior to the bid deadline Planet Bids Online Bid Portal m?companyid= Questions & Answers Kellogg & Sovereign Consulting

23 Web References Kellogg and Sovereign Consulting Rural Health Care website: FCC Healthcare Connect Fund Order: Heartland Telehealth Resource Center website: USAC RHC Welcome Packet: FCC Universal Service Fund website: service fund National Broadband Plan: KSLLC Contact Information RHC Contacts: Debi Sovereign Marci White Stacy Simpkins Jane Kellogg Shannon Tice 1101 Stadium Drive Ada, OK P F Website: Oklahoma Universal Service Fund Special OUSF funding Kellogg & Sovereign Consulting

24 OUSF Changes At a Glance HB 2616 OUSF Modernization O.S. Title 17 Sec. 139 became effective 5/9/2016 Changed the OUSF process from litigated to an administrative process Competitive bidding is based on statute Defined the Lowest Cost Reasonable Qualifying Bid (LCRQB) Removed the public interest except in cases of fraud Pre Approval process Requires the OUSF to pay no more than 25% above the LCRQB Provision of bandwidth per standards as recommended by the Federal Communications Commission (FCC) OUSF Changes At a Glance Oklahoma Corporation Commission (OCC) Chapter 59 Emergency Rules became effective 8/12/2016 Emergency rules were put in place to bring them into compliance with the new statute Telemedicine recertification is no longer required Telemedicine Bandwidth Standards Competitive Bidding The following are requirements for request for bids per Statute and Commission rules: The bidder must be an eligible provider as defined in statute (CCN or OneNet) Bidding should not be structured in a manner to exclude carriers eligible to receive OUSF funding where the OUSF Beneficiary is located. The bid request must require ineligible services be priced separately from OUSF eligible services. The bid request shall clearly identify the bandwidth range requested by the OUSF Beneficiary Bids must contain all costs to provide the Special Universal Service. Any bid containing estimated costs, other than fees and taxes to be paid to a third party, will be disregarded as not meeting bid requirements. Bids that do not conform to requirements for public entities may be disregarded Kellogg & Sovereign Consulting

25 Lowest Cost Reasonable Qualifying Bid Represents the lowest total cost proposal including monthly recurring and nonrecurring charges for eligible services. Is reasonable to meet the needs of the OUSF Beneficiary as listed in the request for bids. Is submitted during the same competitive bidding period as the awarded bid. Is for a bandwidth within the range requested for bid and selected by the OUSF Beneficiary. Is for the same contract term as the bid that was selected by the OUSF Beneficiary. Meets the requirements specified in the request for bid by the OUSF Beneficiary Was the result of a fair and open competitive bidding process as defined in statute Telemedicine Bandwidth Standards Department of Corrections up to 100 Mbps Federally Qualified Health Centers Urban Locations up to 500 Mbps Rural Locations up to 100 Mbps County Health Departments/City County Health Departments Urban Locations up to 500 Mbps Rural Locations up to 100 Mbps Telemedicine Bandwidth Standards Not for Profit Mental Health and Substance Abuse Facilities (certified facilities pursuant to OAC 450, Chapters 17 and 24) that are not staffed 24 hours each day up to 100 Mbps Eligible healthcare entities that are staffed 24 hours each day, including academic facilities, large medical center, hospitals, and mental health and substance abuse facilities (certified facilities pursuant to OAC 450 Chapter 23) 1 to 50 beds up to 500 Mbps 51 to 100 beds up to 1 Gbps 101 to 200 beds up to 3 Gbps 201 or greater beds up to 10 Gbps Kellogg & Sovereign Consulting

26 Telemedicine Bandwidth Standards Request can be made for additional bandwidth funding above the approved levels by providing additional information such as: Number of healthcare providers and staff at the HCP Number of beds at the HCP Services provided at the HCP Support for other telemedicine facilities that require broadband access with consideration for any payments received by the supporting facility; Prior bandwidth usage, not including public network usage Charges Covered The OUSF will fund reasonable installation and network termination equipment owned and operated by the eligible provider that is necessary to provide the eligible telemedicine service. Funding for eligible services, including federal funding, shall not exceed actual eligible expenses Charges Not Covered Redundant services The OUSF will not fund more than one provider for the same service at the same location for the same time period, except during a transition period not to exceed 30 days. The OUSF will not reimburse an Internet subscriber fee or charges incurred as a result of services accessed via the Internet. Voice services that use separate lines or have allocated bandwidth. Surcharges and fees Kellogg & Sovereign Consulting

27 79 AFFIDAVITS Pre-Approval & Service Provider Funding Request 80 OUSF Affidavits Preapproval of Funding Request for Funding Request for Change in Funding Pre-Approval OUSF Beneficiary Pre approval is a new process available to OUSF Beneficiaries who desire to have certainty regarding the amount that will be paid from the OUSF. The OUSF Administrator will review the documentation submitted with the request and issue a preapproval funding letter to the OUSF Beneficiary and eligible provider within 90 days of a properly completed preapproval request. An OUSF preapproval funding letter will be issued without a Commission order. 81 Kellogg & Sovereign Consulting

28 82 Request for Funding Service Provider An eligible provider may seek and obtain funds from the OUSF by filing a Request for OUSF Funding with the Commission Court Clerk s Office. The OUSF Administrator will review and determine the accuracy of the complete request and issue a Determination of funding within 60 days if a preapproval funding letter was issued or within 90 days if no preapproval funding letter was issued. Any affected party may file a request for reconsideration of the determined funding within 15 days of the Determination being filed. A Determination of funding will be issued without a Commission order. Changes in service or price after a pre approval funding letter has been issued will require an updated Affidavit Request for Change in Funding Service Provider Needed for changes in monthly recurring amounts or other funding related changes (i.e. level of bandwidth) from the approved amount. Changes will not be approved in the Monthly Payment process without supporting documentation submitted via the Affidavit KSLLC s Role OUSF Document & Compliance Services includes preparation and submission of: Pre Approval Request submitted to the Commission Request for Funding submitted to your provider Request for Change in Funding submitted to your provider Data Requests 84 Kellogg & Sovereign Consulting

29 85 Questions & Answers Web References USAC RHC Website Home page for FCC's support programs for health care providers. The FCC Health Care Connect and Rural Health Care programs are both administered by the Universal Service Administrative Company (USAC). Kellogg & Sovereign Online Bid Portal Rural Health Care Register as an eligible bidder and search posted RFPs. FCC Healthcare Connect Fund Order FCC Order detailing the creation of the new Healthcare Connect Fund OUSF Webpage (Oklahoma Corporation Commission) Webpage for the Oklahoma Universal Service Fund FCC Health Care Website FCC website for Health Care related programs and updates. The National Broadband Plan Website for the FCC's National Broadband Plan KSLLC Contact Information RHC Contacts: Debi Sovereign Marci White Stacy Simpkins Jane Kellogg Shannon Tice 1101 Stadium Drive Ada, OK P F Website: Kellogg & Sovereign Consulting