SLD Fall Applicant Training:
The SLD has scheduled eight one-day applicant workshops this fall from late September through early November. As of last Friday, registrations are being accepted on a waiting list only basis for Washington DC, Philadelphia, New Orleans, Los Angeles, St. Louis, and Orlando. Regular registrations are still being accepted for Minneapolis (10/13/2014) and Portland (10/28/2014).
USF Strike Force:
Last week, the FCC announced the creation of a Universal Service Fund (“USF”) Strike Force “dedicated to combatting waste, fraud, and abuse in Commission funding programs.” E-rate is one of the four Universal Service Fund programs. The Strike Force will be led by Loyaan Egal, who joins the FCC after serving as a senior Assistant United States Attorney in the Fraud and Public Corruption Section of the U.S. Attorney’s Office for the District of Columbia.
Additional provisions for E-rate rule enforcement are expected to be included in the E-rate modernization order discussed above.
CEP Deadline:
Beginning with the 2014-2015 school year, schools in all states will be eligible to participate in the Community Eligibility Provision (“CEP”), a USDA program designed to encourage free meals for all students in low-income schools. The program, previously known as the Community Eligibility Option (“CEO”), has been phased in several states at a time over the past three years. An excellent description of the CEP program is available from the Food Research and Action Center (“FRAC”).
To encourage maximum school participation, the deadline for enrolling schools in CEP (normally March 31st of the previous school year) has been extended until August 31st this year.
A school’s or school district’s eligibility to participate in CEP is based on at least 40% of their students being identified as needy through the state’s direct certification process. Meal reimbursement is then calculated at 1.6 times the identified student percentage. This has resulted in 100% reimbursements for many participating CEP schools. This has been problematic from an E-rate perspective because E-rate rules have not recognized the 1.6x multiplier as a valid measure of student eligibility for discount rate purposes. For early CEP adopters, this has meant the use of older NSLP percentages for E-rate. Reportedly, however, the E-rate modernization Order will include a provision adopting the 1.6x multiplier. We will discuss the impact of this change in a future newsletter.
FCC Appeal Decisions Watch:
The FCC issued one appeal decision last week for the Community Partnership of Madera et al (DA 14-1011). As it has done in earlier cases, the FCC granted requests from five applicants whose funding requests had been denied for failure to respond to PIA requests in a timely manner. One decision also included a waiver of the 60-day appeal deadline because the FCC found that the applicant had filed its appeal “within a reasonable amount of time once it received USAC’s decision letter.”