Eligible Services List for FY 2007 Approved
Message Posted October 26, 2006
The Eligible Services List for Year 10 (FY 2007-2008) has been approved by the FCC and is available at: http://www.universalservice.org/_res/documents/sl/pdf/EligibleServicesList_102006.pdf. There are several significant changes to the list, which become effective July 1, 2007, but which may be included on your Form 470’s that are being posted now. Those changes are for the following services and are described in detail below:
- Blackberry-type Services
- Web Hosting Services
- VoIP Services
- Basic Conduit Internet Access
- Redundant Components
- KVM Switch
- USF Admin Fees
Blackberry-type Services:
In recent funding years, the SLD has been denying requests for Blackberry-type services (internet and e-mail delivered via a cellular device). The FCC revised this item in the ESL to read: “A wireless Internet access service designed for portable electronic devices is eligible to be funded if used for educational purposes.” Such services, however, are eligible as Internet Access and not as Telecommunications.
If schools and libraries would like discounts on Blackberry-type services, they should be included in the Internet Access and Telecommunications categories of the Form 470 to be safe. However, applicants are permitted to include them in the Telecommunications category of the Form 471 if they are being bundled with cellular service and being provided by an eligible telecom provider.
Also, because Blackberry-type services are not considered basic phone service, but rather are considered data and e-mail services, they must be included in your approved technology plan in order to be eligible for discounts.
And finally, such services are only eligible if they are being used for educational purposes and schools and libraries should make sure they have a policy in place that restricts such usage for educational purposes only and that any other uses be excluded from funding requests and invoices, particularly if a system has been designed where employees reimburse the school or library for personal use.
Web Hosting Services:
The FCC included strong language regarding web hosting which severely restricts its eligibility to basic web hosting. Specifically, the ESL states that web hosting is a service that provides a means for a school or library to display content on the Internet is eligible. Funding is limited strictly to the eligible web hosting function. Some web hosting services include ineligible features, such as software applications and content editing features and funding will not be provided for such features. Further, these items also are ineligible:
- Internet content or charges for the creation or display of information.
- Internet access that provides features or content that go beyond basic conduit access to the Internet.
- Costs attributable to the creation or modification of information, such as a web site creation fee or content maintenance fee.
- Software, services, or systems used to create or edit Internet content.
- Charges to access Internet content or limited-access Internet Access information.
- Web site creation fee
Although the SLD has previously funded requests for web hosting services from Application Service Providers (such as eChalk, SchoolWires, TeacherWeb, SchoolNet, SchoolOne, etc.), the revised eligibility list may lead to different results for future requests. Applicants wishing to apply for basic web hosting services should perform a cost allocation and only apply for the portion of a bundled service that is for basic web hosting – the cost of hosting the school or library’s website only. Any claims from vendors that a large percentage of their bundle is E-rate eligible should be closely evaluated with the new ESL language.
VoIP Services:
The FCC has decided that VOIP -- Voice over Internet Protocol -- services (such as Vonage and others) are eligible for E-rate discounts under the Internet Access category of funding. This means that applicants seeking VOIP services must submit their request under the Internet Access category of both the Form 470 and 471. Simply requesting local and long distance services is not enough.
Also, because Blackberry-type services are not considered basic phone service, but rather are considered data and e-mail services, they must be included in your approved technology plan in order to be eligible for discounts.
Basic Conduit Internet Access:
The FCC reiterated a long-standing policy that E-rate discounts for Internet Access are only available for basic conduit access to the Internet or for services that are an integral component part of basic conduit access. To qualify as Internet access, all services must reach the boundary of public Internet space.
Because some providers of broadband services are not eligible telecom providers, some applicants have simply listed their service under the Internet Access category, even though voice, data and video were being used over the WAN connections in addition to Internet. E-rate discounts are available for Wide Area Network facilities under Internet Access if the service is limited to basic conduit access to the Internet only. Any other uses for such WANs provided by a non-telecommunications provider must be cost allocated from the E-rate funding request so that only discounts on the Internet Access portion is being requested.
The SLD provided additional cautions about what is eligible under Internet Access in their July 21, 2006 newsbrief, available at:
http://www.universalservice.org/_res/documents/sl/html/sl-newsbrief-20060721.aspx.
To determine if your service provider is an eligible telecom provider (and thus their WAN services can be requested under the telecommunications category), go to the SPIN Contact Search feature on the SLD’s website at: http://www.sl.universalservice.org/Forms/SPIN_Contact_Search.asp. Enter the vendor’s 9-digit SPIN and check to see if there is a “Y” in the Eligible Telecom Provider column.
Other ESL Changes:
In general, the 2007 ESL has been shortened and consolidated and now provides an index and a glossary of terms. For consistency and clarity, ineligible services or components that were listed alongside eligible services were moved to separate sections for ineligible services and products. Thus, services that are not eligible for support are listed at the end of each category.
Redundant Components: Components that are installed in standby mode, redundant, not active and online, or otherwise not an essential element in the transmission of information within the school or library, are not eligible.
KVM Switch: KVM switch (“keyboard-video-mouse” switch) has been added to the 2007
ESL as an eligible internal connection.
USF Administration Fees: Charges for the Universal Service Fund (USF) that appear on your telecommunication bills are eligible for E-rate discounts; however, separate vendor charges for USF Administration fees are not eligible.
Julie Tritt Schell
717-730-7133 - o
717-730-9060 - f
jtschell@comcast.net
www.e-ratepa.org
Penn*link
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