USAC began its annual all-day training series last week. The fall schedule, agenda, and training slides are available on the SLD Website. More than 270 persons, including USAC and FCC staff, attended the first training in Washington D.C., pointing to the high interest about the changes mandated by the FCC’s E-rate Modernization Order.
The training day was characterized by animated questions and responses, some of which left room for further clarification from both the FCC and USAC. It was clear that the changes to the E-rate program are significant, affecting process and administration, and that the time frame to implement the changes, provide them to applicants, and for applicants to prepare and timely submit funding requests is short. USAC repeatedly urged applicants to begin the process as soon as possible, using the currently posted Form 470 (for FY 2014). Please see the link below to USAC’s News Brief and the statement regarding the availability of the current Form 470 for FY 2015.
The interactive training focused on the Modernization Order, reviewed the draft Eligible Services List (ESL), and demonstrated the draft online versions of Forms 470 and 471. Comments and questions from the attendees were many; responses were provided by both USAC and FCC staff. Areas about which there were questions or requests for clarifications included cost allocations, budget calculations, multi-year contracts, and Category 2 services.
Some notes from the training session:
- Cost allocations may be needed for services that heretofore included both voice and data. Issues and questions were raised of how to calculate these charges.
- Emphasis was placed on the need for full and complete documentation if funding is requested for wireless data services. It was made clear that USAC will look at wireless cellular data service funding requests very minutely, requiring clear documentation for pricing efficiency.
- Price transparency via the Item 21 will be integral to the on-line Form 471. Contracts executed after the effective date of the Modernization Order may not contain restrictions that bar publication of pricing data. Applicants can opt-out of this public disclosure requirement only if a specific state law or statute, local rule, or other restriction bars publication of the purchasing price data.
- A simplified application process will be available for applicants who have multi-year contracts; they will not be required to complete a full FCC Form 471 during subsequent contract years. However, contracts cannot exceed five year terms if the applicant plans to use the multi-year contract feature on the revised Form 471.
- If rural schools and libraries plan to share broadband services, e.g. where the rural library has low broadband connectivity, but the local school across the street has significantly higher bandwidth, the FCC will consider waiving the rules on a case-by-case basis. The waiver requests are to provide to rural libraries that may lack financial resources the opportunity to quickly and efficiently benefit from the higher speed connection. However, Direct Connections waiver requests should be filed now for FY 2015.
- Beginning later this fall, invoice deadline extensions will be granted one time only and must be requested prior to the existing deadline. Subsequent invoice extension deadline requests will be denied. The rules for service delivery extensions have not changed with the existing rules remaining in place.
- NIFs are not included in determining urban/rural status.
- Category 2 has three sub-categories: Internal Connections, Basic Maintenance of Internal Connections, and Managed Internal Broadband Services; the last sub-category is new.
- Category 2 services will have budgets based on student counts for schools, and on square footage for libraries. Applicants will need to plan how to apportion the budget for their needs.
- The Category 2 budget provides a pre-discount amount of $150 per student for schools, and $2.30 per square foot for libraries. The budget will be for all services requested under Category 2. Eligible NIFs do not have pre-discount budgets; the applicant must allocate NIF costs to one or more of the entities that will benefit from the service.