How to avoid eRate rule violations

The FCC is investing millions of dollars to remove eRate waste, fraud, and abuse. Here’s how to make sure you’re not caught in its net

This summer, the Federal Communications Commission (FCC) created a Universal Service Fund (USF) Strike Force, which is tasked with combating waste, fraud, and abuse in various USF programs, including the eRate.

This newly created Strike Force, which is part of the FCC’s Enforcement Bureau, will almost certainly expend considerable resources ensuring that the procurement practices of schools receiving eRate funding comply with FCC rules.

To avoid a future encounter with the Strike Force, schools should re-evaluate their internal compliance programs—and here’s how.

For schools, one of the biggest challenges in the eRate process has been complying simultaneously with state and local procurement rules and with the separate, occasionally inconsistent requirements of the eRate.

While the eRate requires adherence to state and local procurement laws, the program also requires applicants to comply with a number of rules that are unique to the program, or face a denial of funding. Because these eRate rules are not always ingrained into a school district’s procurement practices, they are sometimes ignored or misinterpreted—with disastrous results.

(Next page: The most common eRate rule violations—and how to avoid them)