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E-rate News for the Week
November 20, 2000
The following is a summary of the E-rate News for the Week November 20, 2000, prepared by E-Rate Central. Official SLD news appears in the "What’s New!" section of the SLD’s Web site .  Additional and archived information appears in the Archive Section on this Web site.

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:

  1. Centrex is not a basic telephone service and does require a technology plan.

  2. Further definitions of eligible vs. ineligible mobile services.

  3. Cable modems for Internet access are listed as eligible.

  4. On-site technical support is conditionally eligible under certain circumstances.

  5. PDAs are not eligible.

  6. Caching, DHCP, and firewall servers are not eligible.

  7. 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.

Disclaimer: This newsletter may contain unofficial information on prospective E-rate developments and/or may reflect our own interpretations of E-rate practices and regulations. Such information is provided for planning and guidance purposes only. It is not meant, in any way, to supplant official announcements and instructions provided by either the SLD or the FCC.
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