Using the three-month extension for internal connections

At the eSchool News Grants & Funding for School Technology West conference held in San Diego April 29 and 30, SLD president Kate Moore revealed that first-year applicants who wish to take advantage of the three-month grace period for the installation of internal connections and the use of other non-recurring expenses will have to file a Form 486 to let the SLD know of their intent. At press time, a formal announcement of this was expected to be made on the agency’s web site shortly.

The SLD was also expected to announce how first-year applicants could receive an additional six months of funding if their contracts expired before Dec. 31, 1998. In March, the FCC reversed its decision to exclude these applicants from extending their contracts for telecommunications services and internet access to the new program end date of June 30, 1999.

It’s expected the SLD will require these applicants to fill out a second Form 486 indicating that an affected contract has been extended through June 30, and the agency would then issue an amended letter increasing the funds awarded under the applicable Funding Request Numbers (FRNs). Check the SLD’s web site for confirmation of this procedure, though.

Appealing a first-year decision to the FCC

If you appealed a first-year funding decision to the SLD and were denied, you have the option of appealing directly to the FCC. This is a somewhat formal process, though, and you need to follow certain procedures. You should also note that, compared with the SLD, the FCC most likely will take a stricter position with regard to the rules of the eRate.

Appeals to the FCC must be made within 30 days of the SLD’s decision. Your original appeal and four copies should be mailed (with proof of delivery) to:

Federal Communications Commission

Office of the Secretary

445 12th Street, S.W.

Washington, DC 20554

Your appeal should include the following identification header:

Before the FEDERAL COMMUNICATIONS COMMISSION

Washington, DC 20554

In the matter of: Docket Nos. 97-21 and 96-45

Request for Review by (Your name) of Decision of Universal Service Administrator

Your request for review should contain the following information:

1) A brief statement setting forth your interest in the matter.

2) A full statement of relevant, material facts with supporting affidavits and documentation (including references to application and FRN numbers).

3) The question presented for review, with reference—where appropriate—to the relevant FCC rule, order, or statutory provision.

4) A statement of the relief sought and the relevant statutory or regulatory provision pursuant to which relief is sought.

Your appeal should conclude with your name, title, and address and should be signed and dated.

Receipt Acknowledgement Letters

The first wave of Receipt Acknowledgement Letters (“RALLYs”) were mailed by the SLD the week of May 10. Additional waves are now expected weekly. According to SLD president Kate Moore, applicants who filed their Forms 471 online receive letters before those who filed by mail.

A RALLY confirms that your Form 471 has been received by the SLD and has gone through the initial data entry process. The letter does not indicate SLD approval of your actual eRate requests.

As soon as you get your RALLY, you should carefully check the summary information provided to make sure the key data on your Form 471 was entered correctly. The SLD “strongly encourages” applicants to correct any wrong information in their RALLY letters within two weeks. Data entry problems that aren’t brought to the SLD’s attention quickly are likely to result in erroneous funding decisions that would require formal, more difficult appeals—so if possible, you should try to catch errors in this pre-funding stage.

The first step in reviewing a RALLY is to make sure that every request in Items (15) and (16) of your Form 471 has been captured by data entry. Last year, some applicants found the SLD had missed a few line items or—in some cases—entire pages of items. The second step is to compare each line item shown in the RALLY with your original Form 471; in particular, check the vendor SPIN, class of service, funding request amount, and associated discount rate.

Any data entry errors should be brought to the SLD’s attention within two weeks in the following manner:

1) Photocopy your Receipt Acknowledgement Letter.

2) Draw a line through each incorrect item, and clearly mark next to it what the correct information should be.

3) Make a photocopy of your marked-up letter to keep for your files.

4) Mail (with proof of delivery) your marked-up RALLY as soon as possible to:

Data Entry Corrections

Schools and Libraries Division

Box 125 – Correspondence Unit

100 South Jefferson Roads

Whippany, NJ 07981

Note that the RALLY process is only designed to correct data entry errors. If you find errors in your original Form 471, you can try mailing a letter or an amended Form 471 to the same Whippany address, but you might have to wait to appeal a final funding decision instead.

In addition to RALLYs, the SLD is also issuing postcards to applicants whose Forms 471 were received after the filing window closed at 11:59 p.m. EST on April 6. The postcards are intended to let these applicants know they missed the window and are unlikely to receive any funding.

Additional information about RALLYs, including a sample letter, is available on the SLD web site at: http://www.sl.universalservice.org/announce.asp#ral.

Year Two funding commitment letters

According to Kate Moore, the SLD will begin to issue funding commitment letters 7-10 days after the FCC sets the funding for the second program year. Funding commitment letters will be issued in waves again this year, beginning with applicants who requested discounts on “priority one” services (telecommunications services and internet access) only, then proceeding to applicants who requested discounts on internal connections, and moving down the scale of discount percentages until the money is gone.

Two developments that are new this year, according to Moore:

1) There will be a regular flow of waves each week, beginning on the same day of the week, so it will be easier for applicants to track each wave. The waves will flow according to a schedule published in advance on the SLD’s web site.

2) The SLD will proceed to notify all applicants on their requests for priority one services first, then go back and notify applicants on their requests for internal connections separately. This means applicants who combined their requests for priority one services and internal connections on the same Form 471 will receive two separate decision letters—one for priority one services, and one for internal connection requests.

Last year, the SLD held notification for applicants who’d combined their requests for priority one sevices and internal connections on the same Form 471 until the agency could make a decision on the entire application. The SLD’s goal was to notify applicants with a single decision letter—but this held up the commitments, and in turn the funding, for many applicants.