E-Rate Central News for the Week
October 18, 2010
The E-Rate Central News for the Week is prepared by E-Rate Central. E-Rate Central specializes in providing consulting, compliance, and forms processing services to E-rate applicants. To learn more about our services, please contact us by phone (516-801-7804), fax (516-801-7810), or through our Contact Us Web form. Additional E-rate information is located on the E-Rate Central Web site.
Funding Status
Changes to the E-rate rules and forms are expected to delay both the opening and the closing of the FY 2011 application window. Early indications from the SLD point to a window beginning in early January and closing in mid-March. Applicants planning post-window vacations need to be careful about making non-refundable purchases.
Wave 22 for FY 2010 will be released on Tuesday, October 19th, for $25.5 million. Priority 2 funding is currently being provided at 85% and above. Cumulative funding for FY 2010 will be $1.48 billion.
Wave 70 for FY 2009 will be released on Wednesday, October 20th, for $9.2 million. Cumulative funding for FY 2009 will be $2.75 billion. The final threshold for Priority 2 funding is 77% and above.
FCC E-Rate Order - Technology Plan Requirements
The FCC's Sixth Report and Order (FCC 10-175) released last month contains a number of significant changes to the E-rate program. As discussed in our last newsletter, a number of these changes will require additional FCC and/or USAC clarification.
One set of changes that appears to be clear is the new technology plan requirements for FY 2011 and forward.
The first major change is that technology plans will not be required for Priority 1 services. The elimination of the tech plan requirement, however, does not apply to Priority 2 services. This means that:
- Low- to mid-discount rate applicants, many of whom never apply for Priority 2 services anyway, no longer need to be concerned with E-rate technology plans (although they may have other state or local planning requirements). This should significantly reduce the number of applicants who need approved technology plans. In FY 2009, for example, almost 60% of the funding, and even a higher percentage of the applications, was for Priority 1 funding.
- Higher discount rate applicants should continue to do E-rate technology plans. This advice clearly applies to applicants whose discount rates, either on average or for individual sites, are 80-90%. In our view, applicants with discount rates under 80% need to assess the likelihood of the Priority 2 funding threshold, in any given year, dropping to a lower level. Since FY 2003, that threshold was below 80% only once.
The second change is that E-rate technology plans no longer are required to include a budget component. For applicants who had previously done only one-year plans because of a reluctance to budget more than a year in advance, this means that writing a three-year plan may become a more viable option.
Note that the other four plan components remain the same — and must cover the entire tech plan period — namely:
- The plan must establish clear goals and a realistic strategy for using telecommunications and information technology to improve education or library services;
- The plan must have a professional development strategy to ensure that staff know how to use these new technologies to improve education or library services;
- The plan must include an assessment of the telecommunication services, hardware, software, and other services that will be needed to improve education or library services; and
- The plan must include an evaluation process that enables the school or library to monitor progress toward the specified goals and make mid-course corrections in response to new developments and opportunities and they arise.
Note also that budget information is still required to support annual Form 471 applications. Overall budget numbers are required in the Item 25 certification, and more detailed budgets may be required during a Selective Review (or audit).
A third, and more subtle, change is that the pre-Form 470 plan needs only to cover a portion of the next funding year, not the full year. Since most approved plans now typically expire on June 30th, this has little current effect. In the future, however, it may lead to different plan expiration dates. One logical possibility would be to prepare a technology plan expiring September 30th. Thus, for example, a plan written to cover the 2011-2012 school year could actually cover services through September 30, 2012 — nominally, the last date to receive Internal Connection services for FY 2011. In this case, the applicant would have a valid tech plan in place, covering a portion of the next year, when it became time to file a Form 470 for FY 2012.
E-Rate Updates and Reminders
2010 E-Rate Training for Applicants:
The SLD's fifth and sixth fall training workshops will be held this week in Kansas City on October 19th and in Jacksonville on October 21st. There will be another in Portland next week and a final one in Dallas the following week. Although all the fall workshops are fully subscribed, copies of the training slides are posted on the SLD's Training Web site.
The SLD's October 15th News Brief discusses and provides tips for meeting the following two October deadlines:
- Recurring service invoices for FY 2009 (October 28)
- Form 486s for FY 2010 (beginning October 29)
