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May 2012 E-rate Update
May 15, 2012
FY 2012 Priority 1 E-rate Funding: USAC is expected to begin issuing FY 2012 Funding Commitment Decision Letters (FCDLs) for Priority 1 funding requests at the end of May. 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.
FY 2012 Priority 2 E-rate Funding: As outlined in the listserve message from April 25 (http://e-ratepa.org/Listserve-Archive/2012/04-25-12.html), nationwide demand for Priority 2 services (internal connections and basic maintenance of internal connections) is $2.793 billion, an increase of 30.7% from last year. That increase, coupled with a 12.5% increase in Priority 1 requests, will leave a deficit of more than $1 billion needed to fund Priority 2 requests at just the 90% level. Under current E-rate rules, if there is not enough funding to cover an entire discount level, the funding will be distributed on a prorated basis (although the specifics of how that would be done are not spelled out). Knowing this is an unpopular option, the FCC staff will spend the next few months trying to solve this problem. We have asked the FCC to formally seek comments from the E-rate community or setting forth various proposals to solve this unprecedented problem for which stakeholders would have an opportunity to comment. I will keep you updated as this process moves forward as it is unprecedented, yet a problem that is likely to continue.
New SPIN Change Rules - Beginning with the 2011 funding year, the E-rate rules for allowable SPIN changes have became much, much more restrictive. Applicants are now 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. 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. Should you have special circumstances that require you to change vendors that don't fit into one of these three reasons, please let me know and I can help draft your explanation to USAC.
New CIPA Requirements: Every school receiving E-rate funding must begin teaching online safety to ALL students beginning with the 2012 school year, and every school must have updated their school's Internet Safety Policy by July 1, 2012 to address the new requirement to educate students about appropriate online behavior, including interacting with other individuals on social networking websites and in chat rooms, and cyberbullying awareness and response. If you have not yet updated your ISP, be sure to do this before July 1, 2012. In order to assist applicants with complying with the new CIPA requirements and understanding their requirements (filtering) under the existing CIPA law, a special CIPA webinar has been scheduled for Thursday, May 17 at 1:00. To attend, go to http://vclass.cciu.org and click on the course entitled: CIPA: Complying with the Original and New Requirements. No pre-registration is required and this is a free event. You may not wish to use a 64-bit browser to view the webinar (as I have had challenges).
Advertising on School District Websites: Is a school permitted to have advertising on their website or include Amazon-type links if the school is receiving E-rate funding for webhosting and/or Internet access? The FCC recently provided unofficial (verbal) guidance, stating they not believe that advertising on a school's website is a violation of the E-rate resale prohibition. However, they strongly cautioned that E-rate funded services must be used primarily for educational purposes and therefore if the school's website is overwhelmed with advertisements, that would be a problem. But modest advertisements would be considered ancillary and would not be in violation of E-rate rules.
Reminder about E-rate Gift Restrictions: All gifts from service providers to applicants are prohibited at any time (not just during a competitive bidding process) with these minor exceptions: 1) Modest refreshments that are not offered as part of meal (e.g., coffee and donuts provided at a meeting) and items with little intrinsic value intended for presentation (e.g., certificates and plaques); and (2) $20/$50 Rule: Items that are worth $20 or less (e.g., pencils, pens, hats, t-shirts, meals, drinks, etc) as long as those items do not exceed $50 per school or library employee from any one company per funding year. The $50 per funding year exception is computed as an aggregate value of all gifts from a company. All school and library employees, officers, representatives, agents, technology consultants, E-rate consultants, or independent contractors of schools and libraries that has any role in procurement, E-rate or technology planning. In addition, the rules apply to all school board members and library board members.
Technology Plans - If your school or library requested any Priority 2 funding for FY 2012, 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 2012 (July 1, 2012 - June 30, 2013). 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, 2012. 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.
If you have any questions about any of the issues covered in this update, please don't hesitate to contact me at jtschell@comcast.net.
-- Julie
Julie Tritt Schell
PA E-rate Coordinator
717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
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