The most simple and direct solution is not to accept anything from service providers. If an applicant refused any gifts, meals, donated equipment, speaking opportunities, trade show raffles, etc., it would be impossible to be found in violation.
However, this is not practical, especially given the current economic climate. Many schools are dependent on charitable donations, and to refuse them in an effort to be overly cautious could be irresponsible. So, what can applicants do?
Do not allow personnel to accept gifts from service providers, especially if they are directly involved in the eRate process.
Look to see if the donation requires the donor’s service. One thing that the gift rules are clear about is that charitable donations cannot increase the demand for the donor’s service. If a service provider is offering you a specific piece of equipment that can only run with its services, it would be best to decline.
Put yourself in a competing service provider’s shoes. Could it misread a charitable donation as unfairly influencing the competitive-bidding process? A scorned service provider might be the one to blow the whistle if it thinks it has been wronged.
Stay abreast of changes in the program. The FCC should release another order based on USAC’s latest set of questions. Clarification will come soon, so watch for it closely to ensure you’re in compliance.
Nick Shipley is a compliance analyst for eRate consulting firm Funds For Learning LLC.
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