E-Rate Central News for the Week
September 16, 2013
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 (516-801-7814), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.
Wave 18 for FY 2013 will be released on Wednesday, September 18, 2013, for $107 million. Funding is currently being provided for Priority 1 services only. Cumulative funding for FY 2013 will be $660 million. USAC has indicated that the target for cumulative FY 2013 funding by the end of September is $1 billion.
Wave 60 for FY 2012 will be released on Thursday, September 19, 2013, for $1.98 million. Priority 2 funding is being provided at 90%, and is being denied at 89% and below. Cumulative funding for FY 2012 will be $2.75 billion.
Wave 117 for FY 2010 will be released on Tuesday, September 17, 2013. Priority 2 funding is being provided at all discount levels. Cumulative funding for FY 2010 will be $3.06 billion
E-Rate 2.0 – Early Comments
As indicated below, today, Monday, September 16th, is the deadline for submitting initial comments to the FCC’s broad Notice of Proposed Rulemaking (“NPRM”) to modernize the E‑rate program. This being an educational program, we expect that many filers will have pulled all-nighters Sunday in order to submit their comments today. We will be reviewing many of these comments in future newsletters.
In the meantime, we commend those who filed early. Many (over 350) of the early-filed comments were one-pagers, simply asking the FCC to either increase E-rate funding or preserve the eligibility of web hosting and/or e-mail. Links to a sampling of the more substantive comments, filed as of Friday, are provided below.
E-Rate Updates and Reminders
FCC Public Comment Schedule:
Notice of Proposed Rulemaking: Modernizing the E-rate Program for Schools and Libraries (FCC 13-100):
|Reply Comment Date:
Filed comments on the E-Rate 2.0 NPRM are available on the FCC website, accessible through the ECFS Search screen. Simply enter “13-184” in the Proceeding Number field, and push “Enter.”
FCC Cybersecurity Forum:
In recognition of October being Cybersecurity Awareness Month, the FCC’s Consumer and Governmental Affairs Bureau will host a forum and hold technology demonstrations dedicated to cybersecurity issues consumers face, with a particular focus on safeguarding children on the Internet. The forum will take place in Washington, DC on October 1, 2013.
FCC Appeal Decisions Watch:
The FCC released the following three applicant-specific appeal decisions last week — all involving competitive bidding issues:
- Bell Gardens Christian School (DA 13-1883): The FCC agreed with a USAC decision rescinding funding on an FY 2006 award after an audit determined that the school could not provide adequate bid assessment documentation. The school had produced a bid assessment matrix comparing two bids, but could produce only a copy of the winning bid. The school claimed that, although it had received interest from several vendors, it had only received one actual bid. But, as the FCC noted, the bid assessment matrix indicated that it had received at least two bids. The decision highlights the importance of maintaining good documentation. Note that the FCC decision came more than six years after the end of the 2006-2007 funding year (although the audit, which served as the basis for USAC’s decision, fell within the five-year record retention period).
- Henrico County School District (DA 13-1884): The FCC denied a petition for reconsideration of an earlier decision finding that the district had failed to assign the greatest weight to price in its bid assessment. In its petition, the district introduced a new argument that the rejected bids were non-responsive. The FCC not only rejected the basis for this argument, but also noted that petitions for reconsideration “may be dismissed or denied where the petitioner relies on facts or arguments not presented in the original appeal.”
- Net56 & Wheeling School District 21 (DA 13-1891): For the most part, the FCC denied requests for review by the district and its supplier involving two competitive bidding issues. The first concerned the extension of a one-year contract without a competitive rebid (and accompanying Form 470). The second concerned several instances for which price was not the most heavily weighted factor. In the latter situations, the FCC waived the pricing rule in just one case where it found that the district had in fact selected the lowest bidder. In cases where it did not, the requests were denied.
Schools and Libraries News Brief Dated September 13 – Getting Ready for FY 2014
The SLD News Brief for September 13, 2013, reviews a number of applicant tips for completing required actions for FY 2012 and FY 2013 in order to clear the decks for the upcoming FY 2014 application cycle. In outline form, the News Brief covers the following tips:
- Finish filing BEAR forms for FY 2012 recurring services.
- File invoices online if possible.
- Prepare BEAR forms in time for service provider review and approval.
- Read the BEAR form instructions.
- If filing on paper, use the new version dated July 2013.
- Verify the amount of funding remaining on your FRN(s).
- Provide your current contact (and remittance contact) information.
- Don’t file duplicate invoices or line items.
- Check the status of FY 2012 non-recurring services.
- Request a service delivery extension on or before September 30th if needed.
- Check the expiration date on your contract. Extend if necessary and notify USAC via a Form 500.
- If September 30, 2013, is the last date to receive service, then January 28, 2014, is the last date to invoice USAC for those services.
- File a Form 500 to reduce or cancel unneeded funding commitments.
- Assuming you’ve been funded for FY 2013, submit your Form 486.