With a new eRate application season about to dawn for schools and libraries, here are five tips that can help ensure success in getting your fair share of nearly $2.3 billion in telecommunications discounts.
1. Always check the Eligible Services List (ESL) before buying.
“One thing that we always encourage applicants to do is to take a look at the Eligible Services List, which is the document that governs product or service eligibility,” said Brian Stephens, senior technology and regulatory analyst for eRate consulting firm Funds for Learning.
Applicants often purchase a new product or service that is eRate eligible but then don’t apply for discounts on this product or service—perhaps because they weren’t aware of its eligibility, Stephens said. By evaluating all new purchases for eRate eligibility, schools and libraries might save themselves money.
The Universal Service Administrative Co. (USAC), the agency that administers the eRate, issues a revised ESL before the filing window opens for each new funding year. The new ESL for funding year 2012 is now available for downloading from USAC’s web site.
2. Apply regardless of your discount level.
Some applicants who fall below the 80-percent discount threshold—the typical cut-off for Priority Two discounts on internal connections—might think: Why bother submitting an application? Yet, earlier this year, the Federal Communications Commission said it would tap into unspent monies to fund all Priority Two requests for the 2010 program year. The FCC is rolling over an additional $850 million in unspent funding for use in the 2011 program year as well.
“That’s actually the first year of the program, since [its debut in] 1999, when all of the Priority Two funding requests were satisfied,” Stephens said, noting that in funding year 2009, funding for Priority Two requests extended only to the 77-percent discount level.
Even if your school district doesn’t qualify for a high discount percentage on Priority Two services, apply anyway, Stephens recommended. Every year, there is some funding that is committed, but never used for one reason or another. After the deadlines pass, that money can be rolled forward for redistribution.
“You just never know what’s going to happen. You could have a year when some funding gets reallocated, like in 2010. Or, you could have a funding year where the rules change in midstream, and … that might lower the discount threshold,” Stephens said.
Not only does submitting an application increase your chances of getting funded—after all, you can’t receive discounts if you don’t apply—but it also lets the FCC know there’s a high demand for Priority Two connectivity.
For funding year 2012, there will be at least $2.29 billion available for distribution. The official amount has not been announced, but as of last year, the $2.25 billion-a-year funding cap originally established for the program now increases each year to account for inflation.
3. There are alternative ways to calculate your discount level.
“The National School Lunch Program eligibility is one of the methods that can be used to calculate the discount rate, but there are other methods that can be used as well,” Stephens said.
For example, many applicants have had great success in conducting a survey to determine their discount rate, as oppose to using the NSLP numbers, he said. For one reason or another, school district officials might believe their NSLP participation numbers don’t accurately reflect the relative poverty level in their area. There are specific requirements about the kinds of questions you should ask and the return rate you get on responses; USAC provides sample survey tools on its website for reference.
4. Be ready for an audit.
“Document retention is critical to success in the eRate program,” Stephens said. “It’s really not enough to do things correctly. You need to be able to prove that you’ve done things correctly.”
The most successful applicants are the ones who have very robust and organized document retention policies and procedures, he said.
Keeping documentation organized involves a lot of cooperation within school districts, Stephens said. Many departments have to work together: Verification of school lunch data might fall to food services, competitive bidding might fall to accounts payable, and implementing the services might fall to the technology department.
“Getting that coordination to occur and making sure everyone is on the same page is critical,” Stephens said. “Sadly, there are a lot of applicants every year who have funding either denied or rescinded because they were unable to produce documentation that proves they were compliant with some type of program requirement.”
5. Stay on top of changes to the rules and regulations.
“Another big part of being successful in the eRate program is not being denied,” Stephens said. “You definitely don’t want to be denied on some sort of technicality, some sort of new rule that you were unaware of when you submitted your application.”
Last year, there were many regulatory and procedural changes, including brand-new Forms 470 and 471. This year, the changes are fewer—but for many applicants, it still will be the first time they will have encountered the new forms.
“We are certainly encouraging everyone to be sure they are giving themselves adequate time when they are preparing their applications,” Stephens said. “We are encouraging everybody to … review the training materials that are out there on USAC’s website.”
The more applicants can stay educated and knowledgeable about the eRate’s rules and regulations, the better their chances of success. Keeping up with deadlines and following through with every step of the process also improves your chances.
“It’s amazing how many applicants go through all that work to get funding requests approved and then for whatever reason never use them,” Stephens said.
Funds for Learning offers free news, analysis, and commentary about the eRate on its website. Readers can subscribe by eMail, RSS feeds, Facebook, or Twitter. The company also offers an online tool that helps applicants through the entire eRate process—from creating forms and staying compliant to keeping track of changes and deadlines.
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