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Districts Should Appeal "30% Unsubstantiated" Denials
~ Affected Districts and Sample Appeal Language Below ~
Message Posted June 5, 2003

In Year 6, the SLD changed the way it interpreted the 30% ineligible rule to say that if an applicant submits a request, of which they cannot substantiate 30% or more of the amount, the SLD will deny the entire FRN.

Previously, the 30% rule stated that if an FRN request was more 30% ineligible, the entire request was denied. In Pennsylvania, 52 FRNs have been affected by this new rule interpretation (listed below).

While we understsand the SLD's desire to expedite the review process and not have to manually reduce FRNs where applicants have requested more than they need, this rule change was made without any notification provided to applicants.

After a lengthy discussion with the SLD and FCC, we have good reason to believe that this rule will now be implemented for Year 7 and that all Year 6 affected applicants should appeal by their appeal deadline (July 1 for most) to the SLD. Sample language is provided below the list of entities that you should print on letterhead and e-mail or fax to the SLD with your pertinent information.

Even if your name is not listed below, you should be advised that from now on, you should be very careful to only request funding amounts that you can justify with bills or a contract. The "30% unsubstantiated rule" will be strictly enforced for Year 7 (next year).

If you have any questions, please feel free to e-mail me at jtschell@comcast.net


FRN # Applicant Name Requested Amount
959716 AC Valley School District $9,240.00
948878 AUSTIN AREA SCHOOL DISTRICT $8,460.00
1012655 BELLEFONTE AREA SCHOOL DIST $12,240.00
941224 BENTON AREA SCHOOL DISTRICT $4,290.00
942006 BENTON AREA SCHOOL DISTRICT $7,260.00
941236 BOROUGH OF NEW CUMBERLAND $3,734.40
967116 BRISTOL BORO SCHOOL DISTRICT $17,040.00
967187 BRISTOL BORO SCHOOL DISTRICT $34,080.00
967291 BRISTOL BORO SCHOOL DISTRICT $4,260.00
967274 BRISTOL BORO SCHOOL DISTRICT $25,560.00
913804 CEDAR GROVE CHRISTIAN ACADEMY $2,160.00
938506 CLELIAN HEIGHTS SCHOOL $2,700.00
1039472 COUNCIL ROCK SCHOOL DISTRICT $100,800.00
1039654 COUNCIL ROCK SCHOOL DISTRICT $43,200.00
1039628 COUNCIL ROCK SCHOOL DISTRICT $67,200.00
991602 DEER LAKES SCHOOL DISTRICT $807.58
1004642 DIOCESE OF GREENSBURG SCHOOLS $1,275.26
958522 EAST LYCOMING SCHOOL DISTRICT $2,760.00
958595 EAST LYCOMING SCHOOL DISTRICT $828.00
965627 EAST STROUDSBURG AREA SCH DIST $889.20
932322 EXETER TOWNSHIP SCHOOL DIST $12,300.00
994335 GREENWOOD ELEMENTARY SCHOOL $6,174.86
980579 HARAMBEE CHARTER SCHOOL $20,196.00
972282 HOLLIDAYSBURG AREA SCH DIST $1,764.00
980581 IMHOTEP CHARTER SCHOOL $7,992.00
999216 IMHOTEP CHARTER SCHOOL $26,456.44
939188 KEYSTONE CENTRAL SCHOOL DIST $260,400.00
983176 KEYSTONE CENTRAL SCHOOL DIST $10,416.00
982957 KEYSTONE CENTRAL SCHOOL DIST $1,860.00
950952 KEYSTONE SCHOOL DISTRICT $1,864.20
1038938 KIDS PEACE DIAGNOSTIC SCHOOL SAYLORSBURG PA $19,137.60
945680 LANCASTER CATHOLIC HIGH SCHOOL $7,002.38
925244 LIGONIER VALLEY LIBRARY $390.00
965622 LINE MOUNTAIN SCHOOL DISTRICT $2,304.00
1011351 LOCUST GROVE MENNONITE SCHOOL $2,640.00
1002746 MAHANOY AREA SCHOOL DISTRICT $2,160.00
977389 MIFFLINBURG AREA SCHOOL DIST $2,736.00
1045905 Manito Inc. Administration $1,434.56
917281 PENN CAMBRIA SCHOOL DISTRICT $33,191.40
1006244 QUBA INSTITUTE $2,808.00
1057789 RIDLEY SCHOOL DISTRICT $12,600.00
1057793 RIDLEY SCHOOL DISTRICT $13,104.00
1013013 RIVERSIDE BEAVER CO SCH DIST $1,297.44
971740 SELINSGROVE AREA SCHOOL DIST $1,026.00
971719 SELINSGROVE AREA SCHOOL DIST $342.00
955616 ST CHARLES BORROMEO SCHOOL $1,167.07
955632 ST CHARLES BORROMEO SCHOOL $384.00
1029043 TRI VALLEY SCHOOL DISTRICT $611.95
941821 WARWICK SCHOOL DISTRICT $15,384.00
984278 WILLIAMSPORT AREA SCH DISTRICT $15,600.00
992397 WINDBER AREA SCHOOL DISTRICT $13,200.00
1031460 WINDBER AREA SCHOOL DISTRICT $1,980.00


Date
Letter of Appeal
Schools and Libraries Division
Box 125 – Correspondence Unit
80 South Jefferson Road
Whippany, NJ 07981

e-mail to: appeals@sl.universalservice.org
or
fax to: 973-599-6542

RE: LETTER OF APPEAL OF "30% UNSUBSTANTIATED" DENIAL DECISION
Contact Name
Contact Address
Contact Phone
Contact Fax
Contact e-mail
Funding Year 6
471 #
FRN # (listed above)
Date of your Funding Commitment Decision Letter

We are writing to appeal a Year 6 decision in which the SLD denied our request stating that more than 30% of the funding request is unsubstantiated. While we understand the SLD's desire to conduct expedited application reviews, we believe this is a new interpretation of the "30% ineligible" -- an interpretation that never was communicated to applicants before or during the Year 6 application window.

Because this rule was changed without notice ever being provided to the applicant community, we respectfully request the SLD to overturn this denial and approve funding for our request. Our Year 7 application will not contain such unsubstantiated charges.

Sincerely,
Authorized Signature
Authorized Name
Authorized Phone
Authorized E-mail

Julie Tritt Schell

jtschell@comcast.net
(717) 730.7133 (voice)
(717) 730.9060 (fax)

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