News of the Week

Internal Connection funding is still being provided only for applicants at the 90% discount rate. No Internal Connection funding is available below 80%. The availability of Internal Connection funding for applicants receiving discounts in the 80-89% range cannot yet be projected, but requests for funding in this range are currently being reviewed by the SLD.

Note that Wave 23 is being released three weeks after Wave 22 rather than on the normal two-week cycle. By waiting until after March 1, the SLD has assured applicants funded in this (and later waves) that they will be able to use non-recurring services through September 30, 2004, rather than by the normal September 30, 2003, deadline.

Wave 24 is expected to be released one week later on March 10th, thus returning the SLD to the previously established two-week cycle. March 10th is important because, as announced last month, the SLD has established an internal goal of completing the review of all the remaining FY 2002 applications by this date. Remember, however, that the date comes with a major disclaimer - it applies only to applications not subject to special reviews. We believe this excludes applications worth at least $400 million involving ongoing investigations of fraud or other major program violations. Additionally, since the validity of these pending requests - many at the 90% discount level - cannot be determined at this time, we do not expect funding decisions for applicants in the 80-89% discount rate band to be determined by, or even soon after, March 10th.

Updated SPIN Change Sample Letters

Based on recently revised SLD guidance on Service Provider Identification Number ("SPIN") Changes, two new model SPIN Change letters have been added to the Forms Rack of the E-Rate Central Web site. The letters reflect the two types of SPIN changes that can be requested, "Corrective" and "Operational."

A "Corrective SPIN Change" letter is used to correct a SPIN. The critical factor in a "Corrective" situation is that no real vendor change occurs. The SPIN shown on a Funding Commitment Decision Letter ("FCDL") could be in error because it had been provided incorrectly on the Form 471, it had been changed by the supplier as the result of a merger or internal consolidation, or it was incorrectly changed by the SLD during the data entry or review process. If the SPIN shown in the FCD letter is wrong, the supplier name is probably also wrong. Both would need to be corrected.

An "Operational SPIN Change" letter must be used when a service is actually switched from one vendor to another. This will be allowed only if several conditions are met. First, the change must be allowed under all applicable state and local procurement rules. Second the change must be allowable under the terms of the contract, if any, between the applicant and the original service provider. In other words, there must be no breach of contract. In the case of services provided under tariff or month-to-month billing arrangements, there are no contractual problems (although termination charges may apply). Finally, the applicant must have notified its original service provider of its intent to change service provider. Operational SPIN Change letters are required to contain certifications that these conditions have been met.

Additional information on SPIN changes can be found in the Reference Section of the SLD Web site at SPIN Change Guidance . Note that the SLD now requires contact information (name, telephone, and e-mail) for both the original and new service providers. Name and telephone information is available in the BEAR/SPIN Search area of the SLD Web site at SPIN Contact Search. E-mail addresses can often be obtained from the service provider's own Web site (use "N/A" if the e-mail address is not available).

All letters should also include full contact information of the requesting party. An applicant's e-mail address is particularly important for receiving the SLD's approval notification.