In February, the SLD created a task force to review current eRate policies and procedures with an eye toward streamlining the program in time for the 2000-2001 program year.
The Year Three Task Force includes members of the American Library Association (ALA), Council of Chief State School Officers (CCSSO), and National Association of State Telecommunication Directors (NASTD), along with representatives from schools, libraries, and the service provider community.
The task force was charged with redesigning the forms, streamlining the application process, and suggesting ways to improve the program for all involved. At a meeting with SLD staff in April, the task force presented its first list of suggestions, which concerned the application forms and procedures.
The most important change recommended by the group was to let applicants file a Form 470 any time during the year instead of during the application window. Such a change would allow applicants greater flexibility in starting the procurement process while still complying with the eRate’s competitive bidding requirements, the group argued.
The task force also recommended that the FCC set funding at the $2.25 billion cap each year. This would let applicants know ahead of time how much money is available and also give applicants as much funding as they’re entitled to under program rules.
Task force members reported that SLD officials were quite pleased with the suggestions. One member said she believed the suggestions struck a good balance between what would make life easier for applicants and what would realistically be possible to implement.
The recommendations, which the 16-member task force approved unanimously, are as follows:
1. The eRate should be funded at $2.25 billion per year. If estimated demand for a program yearas measured by previous years’ demand and other meansfalls short of this funding cap, collections can be adjusted downward for subsequent quarters.
2. Funding for each program year should be set prior to the application window for that year. To make rational planning and budgeting decisions, applicants need to know the program funding level before the opening of the Form 471 window (see #6, below).
3. Applicants should be allowed to file Form 470 at any time to coincide with the beginning of their procurement process for a service. Form 470 must be filed at least 28 days before filing Form 471, and must be filed each year for tariffed telecommunications services to be received in the following program year.
4. Applicants need file Form 470 just once for each new contract, and once each year for each tariffed service. Multi-year contracts require only one Form 470 to be filed when procurement begins. Each Form 470 has a unique number, which applicants will refer to in their annual Forms 471 (see #5).
5. Applicants file Form 471 each year to request discounts for services. For many applicants in future years (see #2 and 3 above, and 7 below), Form 471 will be the only form they must file to participate in the eRate in a given year.
6. An annual application “window” will be established for filing Form 471. The window should be timed to be as close as possible to the beginning of the relevant program year, but should also allow funding commitment letters to be issued enough in advance of the program start date so service providers can integrate discounts into customer bills and applicants can integrate discounts into their budgets. The opening and closing dates for the window should be consistent and predictable from year to year.
7. Form 471 will include a mechanism for applicants to indicate “okay to reimburse service providers as of the service start date,” thus eliminating need for Form 486 for those services. Form 486 will remain available as a tool for applicants who want more control over service provider reimbursements, and will be required for any applicant who must have an approved technology plan to participate in the program but does not yet have one at the time Form 471 is filed.
8. Form 486 will become a start payment/stop payment/restart payment tool. If they choose not to indicate “okay to reimburse” via Form 471, applicants can file Form 486 to signal the fund administrator to begin paying service provider invoices for a serviceand to stop payment if necessary. In addition, unlike today, Form 486 could be used to restart payment.
9. All forms should be streamlined, simplified, and improved. The task force has carefully considered a number of changes to Forms 470 and 471 to make them easier for applicants to complete while also gathering essential data for both the fund administrator and service providers. SLD staff will now work with the task force to complete mock-ups of the improved forms and may conduct additional research to assure their benefits to applicants and vendors. In addition, the task force may yet, after further development of streamlined forms, recommend an “EZ” form approach for applications of limited scope.
10. The SLD should implement any operational improvements necessary to assure broad and successful participation in the program by applicants and service providers. The task force has recommended a number of improvements SLD should make in its current outreach, communications, customer service, and application review operations. Implementing the recommendations outlined above will require even more strategic attention to these areas to assure a smooth transition to Year Three. SLD staff is encouraged to provide a full report to the task force on its plans for making these improvements.
In the next few weeks, the task force will offer a second list of suggestions concerning issues such as eligible and ineligible services. For example, the task force will address the “systemic lack of clarity and flexibility” in at least three areas: the types of services that are covered by the eRate, the location of those services, and the use of those services.
The Year Three Task Force members are:
• Phyllis Albritton, Colorado State Library
• Jose Alvarado, Fresno (Calif.) Unified School District
• Jeff Burnett, National Association of Independent Schools
• Ted Burr, Deming (N.M.) Public Schools
• Marty Fancy, AT&T
• Jackie Lamb, California State Department of Education
• Jeff Ogden, Merit Networks
• Winston Pierce, Florida Department of Management Services
• Gary Rawson, Mississippi State Network
• Dwayne Schuster, IBM
• Jackie Shrago, Tennessee State Department of Education
• Barbara Smith, Montgomery Co. (Md.)
• Mike Stauffer, BellSouth
• Julie Tritt, Pennsylvania State Department of Education
• Tony Wening, Missouri Research and
• *Ellen Wolfhagen, Washington State Department of Information Services
*Since being named to the Task Force, Ellen has joined the SLD staff.