eRate officials should increase education, simplify rules, and toughen enforcement procedures and compliance requirements to prevent further waste, fraud, and abuse of the $2.25 billion-a-year program, according to a draft of recommendations a special eRate Task Force plans to submit to the Federal Communication Commission (FCC).

The task force was created by the Schools and Libraries Division (SLD) of the Universal Service Administrative Co.—the agency that administers the eRate—to explore ways of tightening program compliance after a handful of "bad actors" gained considerable public attention recently, sparking renewed criticism of the eRate from conservative members of Congress.

The 14-member task force—which consists of representatives from the state, school, library, and vendor communities—drafted the recommendations at its second meeting, held May 29 and 30 in Kansas City, Mo.

The public is welcome to eMail comments to task force members about the recommendations, which are available for review on the SLD web site. The recommendations expand on the following "problem areas" the group identified in its first meeting held earlier in May:

• Lack of clarity in program rules and requirements;
• Rules and processes that might inadvertently encourage waste;
• Shortcomings in applicants' competitive bidding processes;
• Need for review and clarification of "eligible" services;
• Lack of accountability and consequences for program violations;
• Funding models and their impact on waste, fraud, and abuse;
• Maximizing the deployment of SLD resources; and
• Required standards for applicant documentation of program compliance.

Enforcement and compliance

The task force recommends toughening enforcement procedures and compliance requirements when it comes to issuing identification numbers to service providers and designating eligible telecommunications providers. Also, consultants who help schools and libraries apply for eRate discounts should have stricter disclosure guidelines that would, for example, require them to submit a standardized disclosure statement that details their relationship with service providers.

The SLD should expand its current labeling system to indicate more clearly the extent of any violations, the task force suggested. Currently, applications are identified either as compliant or non-compliant, with no gray areas.

The SLD also should ensure that applications are processed according to the rules that were in effect during that program year and should give priority in the appeals process to applications that were held up because of SLD's own mistakes.

To give applicants more control over the disbursement of funds to vendors, the task force proposed giving applicants the option of reviewing Service Provider Invoice Forms for specific internal connections requests prior to SLD approval.