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PY3 funding status
As indicated in our previous Weekly News, the SLD did not issue a funding wave
during the Thanksgiving week. Wave Twenty-nine is scheduled to be
released next Friday. The SLD did announce that it had finally determined
that PY3 funding would be insufficient to drop the discount level for Internal
Connections below the current 82%. Applicants with discounts at 81% with
pending Internal Connection requests will be receiving letters next week
notifying them that these requests cannot be funded.
Cumulatively, through Wave Twenty-eight, the SLD has awarded funding on over
26,240 applications totaling $2.095 billion in discounts, including $267
million for NYS applicants. The SLD currently expects that there will be
one more regular funding wave the week after Thanksgiving. Remaining
applications may be funded thereafter at irregular intervals in small
“ripples.”
Entity Number lists posted on SLD site
Many of last year’s applicants had difficulty finding Entity Numbers for
their individual school and library sites as required for the Form 471.
In an effort to ease the task this year, the SLD has posted a series of Excel
files on its Web site that list many of the Entity Numbers in the SLD
databases. Three files are provided for each state – one for school
districts, one for libraries, and one for “other entities.” The
“other entity” list covers private schools, consortia, and remaining
applicants. Applicants seeking Entity Numbers should check the
appropriate school district or library file first, then try the “other entity”
file for missing numbers.
Our analysis of the New York State files indicates that the listings are
extensive, but are not complete (even excluding some Entity Numbers used in
valid PY3 applications). The SLD apparently has several databases
containing Entity Numbers and has posted only a preliminary subset. The
files are expected to be updated periodically as additional processing occurs.
Applicants needing Entity Numbers not found in the SLD files should call the
SLD’s Client Service Bureau at 888-203-8100.
Further details on, and links to, the SLD Entity Number files for each state can
be found in our Bulletin
No. 157 .
Revised Eligibility List posted on SLD site
Another interesting posting on the SLD Web site this past week was a revised
Eligible Services List dated November 16, 2000. The new list is nine
pages longer than the previous list that had been posted only last
month. Additions, modifications, and clarifications from the last list are
noted in bold type. Interesting additions and clarifications include:
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Centrex is not a basic telephone service and does require a technology plan.
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Further definitions of eligible vs. ineligible mobile services.
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Cable modems for Internet access are listed as eligible.
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On-site technical support is conditionally eligible under certain
circumstances.
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PDAs are not eligible.
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Caching, DHCP, and firewall servers are not eligible.
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Extended warranties of eligible equipment must be prorated.
One idiosyncrasy of the new list is that two key sentences appear under the
general Internal Connections heading rather than in the normal list
format. One states that “Voice, video and data communications have been
determined to be telecommunications services,” meaning that they can be
considered eligible only if provided as a service by telecommunications
carriers. The other states that “Components of Internal Connections that
transform voice to Internet protocol for the purpose of voice over Internet
telephony (i.e., “VoIP”) are not eligible for discount.”
Further details on, and links to, the SLD’s new Eligibility List can be found in
our Bulletin No. 156.
FCC encourages SLD to explain appeal decisions
In two decisions this fall (Terral School District 3,
DA 00-2123, and Mississippi Department of Education,
DA 00-2576), the FCC has remanded funding denials back to the SLD for
further consideration because of a lack of a clear SLD explanation for its
decisions. In the Mississippi case, for example, the FCC noted that “in
the absence of an explanation by the SLD of the basis for its decision, we
conclude that the record does not support SLD’s finding of ineligibility” (See
our Archived FCC Decisions).
These FCC actions have two implications:
The SLD is being strongly encouraged to expand its explanations for funding
denials or associated appeal rejections. The SLD’s computerized format
for initial Funding Commitment Decisions Letters permits only summary denial
language, but the explanations in their administrative appeal decisions letters
have often been equally brief and incomplete. The FCC seems to be chafing
under the burden of appeals that it believes could be better handled up front
by the SLD.
The FCC actions should be good news to applicants seeking further and/or more
incisive review of adverse SLD funding decisions, particularly at the SLD
level. The bad news may be that it sets the stage for a revolving process
whereby decisions are (i) appealed to the SLD and denied with
insufficient explanation; (ii) appealed to the FCC and remanded to the SLD;
(iii) denied again by the SLD in more detail; and (iv), re-appealed to the
FCC. With each step taking 3-6 months, the full appeal cycle could become
a two-year process.
Additional NYS training session for Orange/Rockland counties
E-Rate Central will conduct its last half-day workshop for the PY4
application cycle on:
Tuesday, November 28 from 9:00 a.m. to noon
Ramapo Catskill Library System Building
619 Route 17M
Middletown, NY 10940
Tel: 845-343-1131
Libraries wishing to attend should register with Jerry Kuntz at 845-343-1131 or
e-mail jkuntz@rcls.org.
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