It’s in with the new … and in with the old as well: To fully leverage 2011 e-Rate funding in boosting broadband access, it’s important to understand the latest changes to the program (and there are many)—but don’t overlook the things that didn’t change, too.
The more things change…
The regulatory adoptions and clarifications highlighted in the Federal Communications Commission’s Sixth Report and Order align with the agency’s desire to streamline the application process, further protect against waste, fraud, and abuse, and codify the rule regarding gifting—as well as articulate the community usage of e-Rate funded resources.
Streamlining the application process
Technology plans: Before the new rules were released, school and libraries that wanted to apply for e-Rate support had to develop a technology plan that covered five required elements, including the applicant’s technology goals, strategy, and a budget necessary to meet these goals. Applicants had to submit their technology plans to an agency certified by the Universal Service Administrative Co. (USAC) for approval.
To further the FCC’s goal of streamlining the application process, the new rules eliminate this requirement for schools and libraries applying for discounts only on Priority One services (telecommunications services and internet access). This change will streamline the process for many smaller applicants who only request reimbursement on phone and internet charges.
While the technology plan requirement has been eliminated for Priority One services, you’ll still need to create and submit a technology plan to receive e-Rate discounts on Priority Two services (the wiring, switches, file servers, and other equipment needed to bring internet access into classrooms). However, if you’re seeking discounts on Priority Two services, you’ll only need to include four of the five elements in your technology plan: You no longer have to include the budget portion that was required before.
Applications: The two primary application forms, the Form 470 for procurement and the Form 471 for requesting discounts, both have undergone stylistic and substantive changes. The new forms should be available before the Funding Year 2011 filing window opens, but you can use the old Form 470 until that time. However, if you file the old version of the Form 470 on paper, the certification pages must be postmarked before the revised Form 470 becomes available on USAC’s web site. Otherwise, the agency will honor the postmarked date on the form, but you’ll have to resubmit the form using the revised version.
Protecting against waste, fraud, and abuse
Rules on gifts: Applicants now will be subject to federal law regarding gifts from vendors, and any breach of this regulation will be considered a competitive-bidding violation. Service providers may offer gifts if the total value of each individual gift is less than $20 and the total value of all gifts does not to exceed $50 per funding year, per school or library employee. Modest refreshments not offered as a part of a meal, or items with little to no intrinsic value (such as plaques or certificates), are permissible.
Articulation of community use
With its Sixth Report and Order, the FCC is letting applicants open up e-Rate funded services to the community for after-hours use, as long as this does not interfere with educational purposes. This will allow community members to have broadband access at school and library sites in their area, furthering the FCC’s goal of providing broadband access to all Americans.