There are notable constants within the eRate program. Every funding year, there is a pool of $2.25 billion to be disbursed. Every funding year, two groups of recipients–schools and libraries–apply for money from that pool to acquire telecommunications services and internet access, and to fund projects that provide (and sustain) the necessary infrastructure for these services. Ironically, the most reliable constant in the eRate program is that it’s continually changing and evolving–and so applicants must adapt along with it.
The success of your eRate application depends on your timely receipt of funding to help you achieve the goals you’ve outlined in your technology plan. To achieve these goals while avoiding the expenses of extra time and work, you must carefully follow the changing landscape of the eRate process. Here are three key pieces of advice this year:
1. Plan your internal connections projects, and your corresponding eRate applications, around the “Two-in-Five” rule.
The 2007 funding year marks the first application of the “Two-in-Five” rule. Previously, if you had a high discount percentage rate, you could confidently acquire funding for eligible internal connections requests for every funding year in which you applied. Now, however, all applicants are limited to receiving funding for internal connections requests in only two out of every five funding years.
The Federal Communications Commission (FCC) adopted this rule with the intention of allowing a greater number of schools to benefit from the internal connections category of funding. The rule was enacted in the 2005 funding year, so if any of your sites have received funding commitments for internal connections in both the 2005 and 2006 funding years, these sites will be ineligible to receive further internal connections funding until the 2010 funding year.
If this is your situation, start planning now to determine your course of action for the 2010 funding year and what internal connections solutions you’ll be seeking at this time. Alternatively, some of your school sites might have received internal connections funding for only one, or neither, of the two previous funding years. In that case, you’ll want to strategize your applications to maximize your internal connections funding for each site during a given five-year period.
The Two-in-Five rule makes it imperative that you keep accurate records of your funding commitments, to ensure that simple mistakes will not limit the funding your sites might receive. For instance, suppose you had two requests for internal connections during the same funding year, one of which was for half of your sites and the other was for the remainder, and one of these funding requests was denied. You would need to keep an accurate record of which sites received funding for internal connections and which did not. If you need a project completed for your entire district (a cabling upgrade, for instance), you’ll need to know if any of your sites have already used their two years of eligibility and then exclude them from your funding request. Proper planning and foresight will be invaluable for anyone who wants to use internal connections funding to meet their technology goals.
2. Take advantage of the newly streamlined reimbursement process. The Schools and Libraries Division (SLD) of the Universal Service Administrative Co., which administers the eRate, has developed a new online process for the submission of the Billed Entity Applicant Reimbursement (BEAR) form. The SLD hopes this new web tool will help alleviate the amount of work involved submitting the BEAR form, which historically has been submitted in paper form.
The BEAR form is for applicants who have chosen to pay the full cost of eRate-eligible services up front and now seek reimbursement for the discounted portion. Both the applicant and the service provider must sign the paper version of the BEAR form, but with this new web tool, the applicant and service provider can “sign” the form electronically with a personal identification number (PIN), which is provided by the SLD. Here’s how it works: The applicant prepares and signs the BEAR form online, and then the SLD sends an eMail message to the designated service provider contact, notifying him that his signature (PIN) is required to continue processing the form. If the form has been waiting for the service provider signature for seven days, the service provider contact will receive another prompt from the SLD requesting this signature. If the BEAR form is left unsigned by the service provider for 15 days, the form will be canceled by the SLD and the applicant will need to prepare a new form to seek reimbursement.
If used appropriately, this web interface can help streamline the reimbursement process, leading to a quicker turnaround time for receiving your check. However, like any tool, it will only serve users well if it’s properly utilized. If either the applicant or the service provider does not use the web interface correctly, the process could result in costly and frustrating delays. Make sure your service provider understands the form and responds promptly to requests for a signature.
3. Pay close attention to the outcomes of recent funding appeals and of legislation pending in Congress.
The FCC has been granting a variety of favorable appeals this year. The decision that has perhaps the most far-reaching impact is the Bishop Perry Order. This order calls for the SLD to amend its policies to include avenues for applicants to correct ministerial and clerical errors on their Forms 470 and 471. The SLD has created new standards that allow corrections for errors that would cause the forms to fail its minimum processing standards. The SLD will contact applicants if it discover errors on their forms, and applicants also may contact the SLD to correct an error they find themselves. These new guidelines will apply to all pending and future applications, as well as those now under appeal.
The eRate is now operating under a temporary waiver of the Anti-Deficiency Act (ADA). If the government decides to require the program to operate under the provisions of the ADA, the SLD would not be able to promise funding to applicants until it had such funding in hand, resulting in lengthy delays of funding commitments. The telecommunications bill now before the Senate contains an amendment that would permanently exempt the eRate from complying with the ADA.
In July, the House of Representatives passed the Deleting Online Predators Act, which would require recipients of eRate funding to take steps “to protect minors from commercial social-networking web sites and chat rooms.” If this bill becomes law, applicants will have to take the necessary steps to ensure their internet policies are compliant to be eligible for discounts.
The eRate challenges applicants to be constantly vigilant of the regulations and procedures that govern it. However, the program does not have to be daunting for applicants. Take the time each year to become familiar with any changes to the program, reevaluate your strategies and goals to remain compliant with its rules, and fully utilize the opportunities that eRate discounts provide.
Micah Rigdon is a client account specialist with Funds for Learning LLC , a nationally recognized eRate consulting firm (http://www.fundsforlearning.com).