Seeking a better understanding of the rules governing the $2.25 billion-a-year federal eRate program, more than 200 members of the school, library, and vendor communities gathered in Washington, D.C., on Sept. 30 for a day-long intensive workshop.
The event, sponsored by the Schools and Libraries Division (SLD) of the Universal Service Administrative Co. (USAC), which oversees the school wiring program for the Federal Communications Commission (FCC), aimed to put applicants on the path to compliance and streamline a process that some critics have branded slow, cumbersome, and inefficient.
Despite USAC’s best efforts to explain the program more clearly, however, service providers and applicants who attended the meeting seemed to leave with more questions than answers. USAC officials declined to say when the filing window for the 2006 funding year might open, for instance (the filing window has opened in November during the past few program years), and they danced around questions regarding the eligibility of some products and services.
Though the eRate remains a valuable source of funding for schools, critics contend that too much uncertainty leaves the door open for creative interpretations of the rules. Many applicants blame their inability to secure funding in part on a persistent bureaucratic morass.
For its part, USAC has taken steps to reduce the burden on schools and other program applicants by providing tools designed to make applying for and receiving eRate dollars easier.
Officials spent much of the day trumpeting upgrades to the SLD web site, demonstrating technical advances designed to help educators, library directors, service providers, and other eRate stakeholders cope with the paperwork that has dogged applicants throughout the funding process.
As part of a mid-day presentation, Phil Gieseler, who works with the SLD to determine what technologies are eligible for discounts under the program, highlighted several enhancements engineered to keep eRate paper-pushing to a minimum.
Among the upgrades available to applicants this year is a new PIN system, or Applicant Personal Identification Number.
According to Gieseler, the new PIN numbers–which USAC intends to distribute automatically to past applicants before the 2006 funding window opens–will lead to “a faster, more efficient” process. It will allow applicants to submit more of the required documentation online, Gieseler said. In the end, he said, the new online system should translate into quicker decisions from USAC regarding funding commitments.
The new PIN system replaces an older system that had fewer capabilities and reportedly was used sparingly by program applicants.
The six- to eight-character identifiers will save time and money by eliminating the need to mail additional documents, such as Form 470 and Form 471 certifications; replace the need for paper submissions; do away with handwritten signatures on certain forms in favor of electronic certifications for everything except contracts; reduce processing delays; and expedite the funding approval process, among other benefits.
Another online feature, called the Block 4 Bulk Upload, will enable schools, districts, libraries, and consortia to complete Block 4 of Form 471 offline and then upload it to the official form. Block 4 is typically used by large school districts and consortia to calculate their eligible discount rate based on the size of their enrollment and the services they seek.
In the past, online applicants had to complete Block 4 in conjunction with the rest of Form 471. That’s no longer the case with the new upload feature, however. Realizing how complex and intensive Block 4 calculations sometimes can be for larger institutions, USAC now will give applicants the opportunity to complete Block 4 offline, edit it, and then upload it to the system before submitting the finished application for review.
The idea, explained Gieseler, is to cut down on time and reduce the potential for error, giving applicants the opportunity to exercise caution when filing important forms.
A third feature, called Online Item 21, encourages applicants to create their Item 21 attachments–documents detailing how they plan to use the services provided–entirely online and share them with their contracted service providers.
Working together, service providers and applicants can use the Online Item 21 form to minimize discrepancies or oversights in the description of services that would force USAC to deny any portion of the funding request, Gieseler said.
Though it’s against program rules for eRate applicants to consult with service providers before the competitive-bidding process, USAC officials actively encourage more cooperation between applicants and providers once the contract is awarded.
By supplying service providers with a copy of their Item 21 attachments, USAC officials say, applicants can do their part to help speed up the processing of invoices. With better communication comes fewer filing mistakes–and that’s better news for everyone, said Gieseler.
Despite these advances, service providers and applicants who attended the session were hesitant to credit USAC with effectively eliminating the bureaucratic pitfalls that have opened up the embattled program to the waste, fraud, and abuse that have marred its reputation in recent years.
Some eRate coordinators questioned whether the guidance outlined in USAC’s presentation meshed with what has been communicated in the past by the FCC, while others expressed confusion over eligible services and criticized program officials for a lack of specifics with regard to what is and is not allowed under the current rules.
Though USAC officials tactfully sidestepped some of the most pointed questions, presenters did offer several tips and hints designed to help schools and other applicants improve their odds of getting coveted eRate funds.
In the upcoming funding year, a big point of emphasis will be effective technology planning, said USAC’s John Noran as part of an early-morning presentation on the dos and don’ts of the funding program.
Official technology plans, which applicants must submit to USAC along with their funding request, must include these five essential elements:
- Goals and strategies for using the technology;
- A plan for professional development and training related to the upgrade;
- An assessment of the applicant’s overall needs;
- A detailed project budget; and
- An evaluation process designed to test how well the project was implemented.
Though technology plans are not required for standard phone and voice-mail services, Noran said, they must be submitted for any other type of technology request–“and the plan must be submitted and approved before services start,” he said.
Stressing the need to maintain the integrity of the program, USAC’s Catriona Ayer called on eRate coordinators and others to exercise due diligence and restraint when applying for funds.
“In the end, the applicant is going to be the one who’s on the hook here,” she said. “We’re looking for you to have thought about what you need and listed this in your technology plan. You need to have retained all of your information in order to respond to us.”
Another rule program administrators say they plan to pay particular attention to this year is the new “Two in Five Rule,” which limits applicants to requests for internal connections–including switches, hubs, routers, and wires for building sites–to twice every five years. If they receive a commitment, but do not go ahead with the project, applicants can file a Form 500 to cancel the request, and the rule will not take effect, Noran said.
Gieseler pointed out that it’s essential for applicants to pay attention to program rules, especially with regard to conditional eligibility.
He also warned against getting too creative. Better, he said, to stay within the spirit of the rules, than to attempt to make the federal dollar stretch into areas it was not originally intended for.
Going too far, he cautioned, could result in an audit. And, in the event that rules were broken, an investigation can lead to USAC attempting to recover the funds.
To help ensure program compliance, USAC last year conducted a series of 1,000 random “Site Visits.” Though USAC officials contend the visits are intended primarily to help them get a better sense for how the program is working in schools, they point out that auditors are required to report any program irregularities, which could lead to a more expansive audit.
While applicants will always have an opportunity to appeal any disciplinary actions taken by USAC as a result of an audit or Site Visit, Ayer said, the best way to protect against any potentially damaging action is to keep your paperwork in order, adhere to the rules and regulations outlined on the SLD’s web site, meet all filing deadlines, and stay away from questionable projects and service providers.
Regarding the products that are eligible for discounts in 2006, USAC officials could not specify when the final revised Eligible Services List would be available. But a draft copy of this list–which awaits approval from the FCC–has been posted to the SLD web site and lists several proposed changes for this year.
Chief among these changes are a new entry for terminal servers, which better defines for applicants what types of equipment constitutes a “terminal server” and under what condition these tools can be used; a clarification with regard to eligible wireless internet access, which specifies that eRate funds can be used to install wireless only in “eligible locations”; and a change that enables applicants to request wireless wide-area network components as Priority Two internal connections. Previously, wireless WAN components were eligible only as Priority One services, officials said.
The next eRate training session is scheduled for Oct. 6 in Chicago. Additional training sessions also will be held in Los Angeles on Oct. 11 and Newark, N.J., on Oct. 21. Attendees must pre-register with USAC.
USAC’s 10 eRate mistakes to avoid at all costs
Universal Service Administrative Co.
School and Libraries Division
Federal Communications Commission
“Summary of Proposed Changes to FY 2006 Eligible Services List”