Seeking a better understanding of the rules governing the $2.25 billion-a-year federal eRate, more than 200 members of the school, library, and vendor communities gathered in Washington, D.C., recently for a day-long intensive workshop.
Participants got an early look at some of the changes designed to streamline the eRate application process for funding year 2006, including a new PIN system designed to rid the need for applicants to file paper-based signatures and certifications.
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 eRate stakeholders cope with the mountain of 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 which 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 PINs–which USAC intends to distribute automatically to prior applicants before the 2006 filing 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 funding decisions from USAC.
The new PIN system replaces an older system that had fewer capabilities and reportedly was used sparingly by program applicants.
Another new online feature, called the Block 4 Bulk Upload, will enable applicants to complete Block 4 of their 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 their Form 471. That’s no longer the case with the new upload feature. Realizing how complex and intensive Block 4 calculations 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 their finished application for review.
The idea, explained Gieseler, is to save 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 encourages more cooperation between applicants and their vendors once the contract is awarded.
By supplying service providers with a copy of their Item 21 attachments, USAC officials say, applicants can help speed up the processing of invoices. With better communication comes fewer filing mistakes–and that’s better news for everyone.
Despite these advances, service providers and applicants who attended the session were hesitant to credit USAC with eliminating the bureaucratic pitfalls that have exposed 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 current rules.
Though USAC officials tactfully sidestepped some of the most pointed questions, presenters did offer several tips designed to help applicants improve their odds of getting 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 a presentation on the dos and don’ts of the program.
Official technology plans, which applicants must submit to USAC along with their funding request, must include these five 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 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.
Another rule that eRate administrators say they’ll pay particular attention to this year is the new “Two in Five Rule,” which limits applicants to requests for internal connections–including routers, switches, file servers, and wiring for building sites–to twice every five years. If you receive a funding commitment, but do not go ahead with your project, you can file a Form 500 to cancel the request, and the rule will not take effect, Noran said.
Gieseler warned against getting too creative when applying for discounts. Better to stay within the spirit of the rules, he said, than to try to make the federal dollar stretch into areas it wasn’t intended for.
Going too far, he cautioned, could result in an audit and–in the event that rules were broken–an attempt by USAC to recover funds.
To help ensure program compliance, USAC last year started conducting 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 note 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, 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, officials said.
Regarding the products that are eligible for discounts in 2006, USAC officials could not say when the final revised Eligible Services List would be available. But a draft copy of this list–which still awaited approval from the FCC at press time–has been posted to the SLD web site and lists several proposed changes for the 2006 program year.
Chief among these changes are a new entry for terminal servers, which better defines for applicants what types of equipment constitute a “terminal server” and under what condition these tools can be used; and a clarification regarding wireless internet access, which specifies that eRate funds can be used to install wireless service only in “eligible locations.”
See these related links:
Universal Service Administrative Co.
Schools and Libraries Division
Federal Communications Commission