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In This Week's Issue
» Funding Status Update
» E-Rate 2.0 NPRM Reply Comments
» E-Rate Updates and Reminders
» Schools and Libraries News Brief for Dated November 8 – Eligible Services

E-Rate Central News for the Week
November 11, 2013

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 (516-801-7814), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.

Funding Status

The FY 2014 application window is not scheduled to open until at least January 8, 2014, and to close “commensurate with past practice.”  If, in fact, the window does open on January 8th, we would expect the window to close on or about March 18th.  The critical timing issue for opening the window may be the approval and the online implementation of the revised Form 471.  The release of the new Form 471 currently hinges on OMB approval, public comments for which are due November 25th.  

Wave 26 for FY 2013 will be released on Thursday, November 14, 2013, for $41.5 million.  Funding is currently being provided for Priority 1 services only.  Cumulative funding for FY 2013 will be $1.33 billion.

Wave 68 for FY 2012 will be released on Friday, November 15, 2013, for $13.1 million.  Priority 2 funding is being provided at 90%, and is being denied at 89% and below.  Cumulative funding for FY 2012 will be $2.81 billion.

E-Rate 2.0 NPRM Reply Comments

Friday, November 8th, was the deadline for submitting reply comments to the FCC’s broad Notice of Proposed Rulemaking (“NPRM”), more formally known as the Notice of Proposed Rulemaking: Modernizing the E-rate Program for Schools and Libraries (FCC 13-100).

As of last week, over 450 additional comments and reply comments had been filed since the FCC reopened on October 17th.  Again, as with the initial comments, many of the reply 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.
One of the most complete sets of reply comments submitted was filed by the State E-Rate Coordinators’ Alliance (“SECA”).  Topics covered by the SECA filing, shown below, illustrate the breadth of issues covered.

  • The primary goal of all streamlining measures should be more prompt issuance of funding commitment decision letters for Priority 1 requests before July 1 each year
  • Procurement
    • Evergreen contracts
    • Consortium purchasing and State Master Contracts
    • Reliance on state and local procurement requirements
  • Program streamlining measures must include improvements to the PIA process and more transparency in the application review process
    • Evergreen Form 471 applications [for multiyear contracts]
    • Automated review and approval of “routine” applications
    • Improvements to the Application Status Tool are vitally needed
    • Deadlines should be established for the SLD’s processing of all forms and appeals
    • There must be an overhaul of procedures to avoid asking duplicate questions of applicants concerning Form 471 applications
    • The whistleblower process must be revamped to more fairly treat applicants who are subject to anonymous accusations of improprieties
  • District wide simple average discount calculations should be adopted
  • Coordination among the existing USF mechanisms is essential in order to improve efficient use of E-rate and other USF funds and to facilitate the ubiquitous availability of broadband throughout the Country
  • The NSLP Community Eligibility Option must be integrated into the E-rate discount methodology in a fair and equitable manner
  • Commitment Adjustment Decision Letters and Recovery of Improperly Disbursed Funds should be re-examined so as to result in more equitable [and fair] treatment of applicants that commit inadvertent and unintentional program infractions
  • Direct payments to applicants are legally authorized by statute and should be implemented
  • Signatures and certifications
    • A requirement for corporate officers to sign forms may not be needed
    • Consultants should not sign forms
  • The Children’s Internet Protection Act should apply only to school- or library-owned devices
  • The purchase of wide area networks should be eligible of E-rate funding for applicants that seek this option when procurement results show that the purchase option is the most cost-effective
  • Wireless community hotspots should be approved first on a trial waiver basis
  • National emergency procedures should be expanded and codified
  • The per pupil/per building funding proposals raise many questions and concerns that have not been adequately addressed by proponents

Links to a sampling of other more substantive reply comments are provided below.

Both initial and reply comments filed to date are available on the FCC website, accessible through the ECFS Search screen (enter “13-184” in the Proceeding Number field, and push “Enter”).

E-Rate Updates and Reminders

November Deadlines:

Typically, a Form 486 must be filed no later than 120 days from FCDL issuance or the start of service.  Assuming services started July 1, 2013, the deadlines for early FY 2013 funding waves 1-8 have already passed (although USAC will be giving a grace period to late filers).  The upcoming Form 486 deadlines for the remainder of November are:

      Wave 9       11/13/2013
      Wave 10     11/20/2013
      Wave 11     11/27/2013

SLD Fall Training:

The last of the SLD’s fall applicant training workshops was held last week.  The presentation slides for these workshops are posted on the SLD website.

Schools and Libraries News Brief Dated November 8 – Eligible Services

The SLD News Brief for November 8, 2013, references the Eligible Services List for FY 2014, focusing on the distinction between lit and dark fiber, a clarification on web hosting, and a summary of the basic categories of service.  It also reviews other eligibility issues to be considered, including:

  • Partial eligibility
  • Conditional eligibility
  • Ancillary use
  • On-premise Priority 1 equipment
  • Wide area networks
  • Educational purpose
Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.