Spring 2011 E-rate Update
Message Posted May 5, 2011
Happy Spring, E-raters! I wanted to take this opportunity to provide you with an E-rate update.
2011 FCDLs - USAC is expected to begin issuing FY 2011 Funding Commitment Decision Letters (FCDLs) in the next few weeks. For those applicants lucky enough to be funded in Wave 1, the next step will be to file the Form 486. PIA reviews are in full-swing and if you haven't yet been contacted by a PIA reviewer, you likely will be in the coming weeks and months. If you're curious about the status of your application, go to http://www.sl.universalservice.org/menu.asp, click on 'Application Status' and enter your Billed Entity Number. The system will show you the status of each of your Form 471s. Any status which includes the words 'quality assurance' likely means your application will be included in Wave 1.
Status of FY 2010 Applications:
-- Priority 1 (telecom and internet): There are 269 Priority 1 FRNs that have not yet been funded for FY 2010 and are worth $5.052 million. I understand from USAC that these funding requests are being actively reviewed.
-- Priority 2 (internal connections and basic maintenance): Priority 2 funding is still being approved at 81% and above, and denied at 79% and below. Although the USAC Board recommended to cut off funding at 81%, the FCC has not yet approved that recommendation and may try to find the money needed to fund P2 requests at the 80% level.
-- So far, PA applicants have been committed nearly $79 million for FY 2010.
SPIN Changes - Beginning with the 2011 funding year, the E-rate rules for allowable SPIN changes have become much, much more restrictive. Applicants will be required to have a legitimate reason to change vendors and retain their E-rate funding, such as breach of contract, a vendor unable to perform service, or vendor bankruptcy. Lower price is no longer an allowable reason to switch vendors. I will be sending a more extensive message on this topic in the coming days. But it is extremely important that you keep this new rule in mind from now on. If you switch vendors for any reason other than these three (breach of contract, bankruptcy or inability to perform service), you will lose your E-rate funding for the year.
CIPA Amendment - In October 2008, Congress passed the "Protecting Children in the 21st Century Act," which contained a provision requiring schools' Internet Safety Policies to include "... educating minors about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms and cyberbullying awareness and response." Essentially this means that schools will be required to teach online safety to students as a prerequisite to receiving E-rate funding. Although the law is more than 2 1/2 years old, the FCC has not yet released the official Order that will implement the new requirements and set deadlines for compliance. We originally thought that the new provisions would begin July 2011, but that effective date is now up in the air.
In the meantime, I recommend that if you are currently writing or rewriting your Internet Safety Policy, be sure to include this new provision and be sure to have your new Internet Safety Policy be available for public comment at a public hearing (or public meeting) before it is adopted by your governing board (we have received informal advice from E-rate officials that this may be a requirement). In addition, your school should be thinking about how you will actually implement the new law when it does become effective, if you aren't providing such online behavior education already. (Libraries are exempt from the new provision.)
Technology Plans - If your school or library requested any Priority 2 funding for FY 2011, be sure that you have a technology plan that covers the services included in your 471(s) and that it covers the full Funding Year 2011 (July 1, 2011 - June 30, 2012). If your technology plan expires, needs updated, etc, be sure you submit it to the appropriate approving agency ASAP as the plans must be approved by July 1, 2011. If you are a public school entity and you are unsure when your plan is due, contact the eSP Helpdesk via email at estratplan@caiu.org or phone at 717.732.8403.
Audits - After a 2-year hiatus, E-rate audits will resume, likely in June 2011. We anticipate more audits will be conducted than before (720/year as opposed to 250), but the audits are anticipated to be conducted nearly entirely from remote locations and are slated to last only a few days, unlike the 3-6 week on-site audits that we previously experienced. I'll keep you posted as more details are released.
E-rate Timeline - Having trouble keeping track of E-rate deadlines from three funding years at the same time? Attached is a timeline that will help you keep track of where we are in the E-rate application process.
As always, if you have any questions, please contact me at jtschell@comcast.net.
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
Penn*link
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