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January 10, 2011

Introduction

The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us web form. Additional E-rate information is located on the E-Rate Central website.

Funding Status

The application window for FY 2011 will open at noon EST on Tuesday, January 11, 2011, and close at 11:59 p.m. EDT on Thursday, March 24, 2011. In preparation for the window opening, the Apply Online portion of the SLD's Web site was shut down for maintenance last weekend. The new online versions of the Form 470 and Form 471 should be available by January 11th.

Wave 33 for FY 2010 will be released on Tuesday, January 11th, for $32.8 million, including $540 thousand for six New York applicants. This will raise cumulative funding for FY 2010 to $2.09 billion, including $204 million for New York. Currently, Priority 2 funding is being awarded at 81% and above, and denied at 79% and below.

Wave 78 for FY 2009 will be released on Wednesday, January 12th, for $218 thousand - none for New York. Cumulative funding for FY 2009 is $2.79 billion.

Form 470 Transitional Certification Issues

The SLD issued a special News Brief - Update on January 5th addressing the various situations in which an applicant would find itself if caught in the transition from the old version of the Form 470 to the new one. The basic problem is that the move to the new version of the Form 470 will be a flash cut. Once the new version is activated online, the old online version will no longer be available. This will affect an applicant's ability to certify a previously filed Form 470 online (including printing out the old certification for submission) or USAC's ability to data-enter a paper version of the old form.

The SLD's Update provides guidance on the following potential situations:

  1. An applicant has not yet started a Form 470.
  2. An applicant has started a Form 470, but has not yet submitted it.
  3. An applicant has submitted a Form 470, but has not yet certified it.
  4. An applicant has submitted, but not certified, a Form 470 and the authorized person is unavailable.
  5. An applicant has submitted a Form 470 on paper whose form status is "INCOMPLETE."
  6. An applicant has submitted a Form 470 online and mailed a paper certification, but whose form status is still "COMPLETE."
  7. An applicant has submitted and certified a Form 470. In this case, no action is required.

Our two recommendations are:

  1. If you need to file a new Form 470 for FY 2011, wait until the new version is available (probably on January 10th). If there is no pressing need to file an online Form 470 next week, it might be prudent to wait another week in case there are early system bugs to be resolved.
  2. If the older version of the Form 470 has already been filed, make sure that it is complete and certified. This can best be done by using the Form 470 Search Posted facility on the SLD Web site. If there is a problem, follow the guidance in the SLD's Update.

E-Rate Updates and Reminders

FCC E-Rate Broadband Survey:

The FCC released an interesting report entitled 2010 E-rate Program and Broadband Usage Survey (DA 10-2414). The key findings are as follows:

  • 95% of all E-rate survey respondents have some form of terrestrial broadband connection to at least one facility, while 2% use satellite and 3% use dial-up.
  • However, nearly 80% of all survey respondents say their broadband connections do not fully meet their current needs.
  • Slow connection speed is the primary reason current Internet connectivity does not meet the needs for 55% of these respondents.
  • 39% of E-rate survey respondents cite cost of service as a barrier in meeting their Internet needs, and 27% cite cost of installation as a barrier.
  • 56% of all E-rate survey respondents expect to implement or expand the use of digital textbooks in the next two to three years, and 45% expect to implement or expand the use of handheld devices for educational purposes.
  • 10% of E-rate survey respondents have broadband speeds of 100 Mbps or greater and most (55%) have broadband speeds greater than 3 Mbps.
  • More than half of school districts (60%) subscribe to a fiber optic connection.
  • 66% of respondents provide some wireless connectivity for staff, students or library patrons.
  • For schools, e-mail is the most used application. Almost all schools (98%) regularly use or access e-mail, and most schools (69%) consider it the most essential application.
  • For libraries, access to online reference materials is both the most used application. 86% of staff and patrons regularly use or access online reference materials, and the most libraries (62%) consider it the most essential application.

Non-Recurring Services Invoice Deadline:

The deadline for submitting SPI or BEAR invoices for non-recurring services is Friday, January 28, 2011 (i.e., 120 days after September 30, 2010, the last day to receive services). Specifically, this deadline applies to FRNs for installation services for either:

  • FY 2009, unless the normal service delivery deadline has been extended (typically until September 30, 2011).
  • Earlier funding years for which the service delivery deadline had been extended until September 30, 2010.

Prohibited Gifts - A little black humor:

One of the questions submitted to the SLD in connection with last week's monthly service provider conference call read:

During the Christmas holiday season, a service provider provides a $60 gift basket of edible fruit and candy to an entire school staff rather than to any particular individual. In the future, the service provider intends to include a notation that no one individual should take more than a quarter of the contents in order to stay in compliance with E-rate gift rules. Does this approach violate any provision of the new rules?

Though somewhat tongue-in-cheek, the question addresses a specific limitation in the new E-rate rules of $20 per gift (or an aggregate of $50 per year) per employee. In responding to the question, the SLD acknowledged the humorous phrasing, but made the following two key points:

  1. If a gift over these dollar limits is provided, consideration should be given to the number of people benefiting; and
  2. A larger concern is whether the gift might be perceived as an attempt to influence the competitive bidding process. This would be a serious and prohibited action.

Schools and Libraries News Brief dated January 7 - FY 2011 Tips and Reminders

The SLD's January 7th News Brief includes a very basic review of the major rule changes for FY 2011, a few filing tips, and the key application filing dates.