Commentary

We’ve all heard the phrase that a picture is worth a thousand words. Well, I’m proposing a new phrase: a picture is worth $2.25 billion. Let me explain.

Today school districts, administrators, teachers and students are encouraging the innovative use of technology, showing how digital tools have helped improve student success by participating in Digital Learning Day.

Have you ever seen Real Time with Bill Maher?* Toward the end of the show, there is usually a segment called “New Rules,” which consists of short quips about politics and other absurdities.

The Stress Management Center and Phobia Institute in North Carolina estimates that 17 to 21 million people in the U.S. have a diagnosable phobia of Friday the 13th. So fair warning, Friggatriskaidekphobics and Triskaidekaphobics may want to avoid the following story. In honor of Friday the 13th, we have put together a list of 13 things you want to avoid during the E-rate filing window.

I recently read and wrote a review of Disrupting Class, by Clayton Christenson. The author’s basic premise is that the Internet is about to reshape education in America. In the hands of capable teachers, I believe that the Internet does, indeed, hold the promise of positively impacting student lives.

Have you read our open letter and petition to increase the size of the E-rate fund? The response so far has been amazing! Over 1,000 parents, community members, and school employees have joined us in recognizing the importance of advanced communications technologies for improved education. And while we could extol the virtues of the E-rate from dusk to dawn (it’s what we do, after all), many of you have written in to share your opinions as well. Here are a few selected quotes provided to us by petition signers.

There is a desperate need for a standard Form 471 filing deadline, allowing applicants to plan for each year. It has previously been recommended that the FCC establish a set annual deadline for the Form 471 filing window - and for good reason. The lack of a set date leaves much uncertainty and often results in delayed planning and late application submissions.

What is a consultant? Long trusted Merriam-Webster’s dictionary defines a consultant as “one who gives professional advice or services.” In USAC’s October 28 Schools and Libraries News Brief, you will find that the definition of a consultant is “any non-employee of the entity applying for funding that assists in filing the application materials for a fee. Consultants can be organizations with one or more employees or they can be individuals.”

Can we establish a permanent E-rate filing window from January 15 to March 1?

When it comes to the E-rate, there are numerous topics that we can - and should - debate. Many of them require in-depth understanding and thorough analysis; however, setting a permanent filing window from January 15 to March 1 is not one of those topics. It is a simple step that would improve the entire program for all stakeholders.

As discussed in my recent commentary, “Truth or Dare,” the FCC has made a significant change to the discount calculation methodology for FY2012. This change raises several concerns.

How many times have we heard the following statement? “USAC/SLD cannot make E-rate policy, only the FCC can do that.” Yet in practice, most of us know this is simply not the case. To wit: this week, USAC announced what is essentially new program policy - applicants’ discount rates will now be calculated using National School Lunch Program participation, not eligibility.

Overall, the SLD works hard to get funding letters, invoices and appeals processed in a timely manner. However, there are times when applications, appeals and invoices have been stuck in what E-rate stakeholders refer to as a “black hole” where no resolution or decision gets made, or the decision literally takes years. In fact, on August 1, the State E-rate Coordinators Alliance (SECA) submitted an ex parte with the FCC outlining their concerns about this particular SLD practice.

Does this sound familiar? A well known politician once wrote that it “takes a village to raise a family” and in one sense, while not debating the merits of those remarks, the same principle applies to the E-rate invoicing process. It takes applicants, service providers and the SLD working together to ensure a smooth process.

Funding Year 2010 may have come in with a bang and left with a whimper, but the effects of the changes from the past year will be felt for funding years to come. As we officially start a new funding year on July 1, here is a look back at what was FY2010 and a look forward to FY2011.

We all know that the E-rate program can be complex and bureaucratic at times. But what many stakeholders - schools and vendors alike - do not focus on enough is protecting their interests when things go wrong.

From time to time, USAC will release new guidance and then retroactively apply new rules to select applicants and service providers. Recently the SLD denied three applicants and four service providers nearly $900,000 in funding on FY2010 Applications based on the new SLD guidance for FY2011. This of course, should not happen.

This week I had the opportunity to attend the USAC 2011 Service Provider Spring Training and am pleased to see the progress the administrator of the program has made to reach out to program participants.

New to the Form 470 and Form 471 this year is a fifth option for the Applicant Type field: Statewide Application. But did anyone actually use it?

As we all know, the E-rate rules are complex and this year has been particularly challenging with the new rules being released, as well as a new Form 470 and Form 471. I'm hoping that the FCC will grant USAC additional authority to work with applicants to correct any mistakes on their Form 471 which occurred as a direct result of the new rules and guidance over the last few months.

It appears that Funding Year 2011 is going to have approximately $3.5 billion worth of funding requests filed within the next 10 days. So, for applicants that still need to file, here is a last bit of advice to help you through the process.

One of the most common questionsfrom stakeholders regarding appeals is the following: "Is it worth my time filing an appeal?"

On January 24, 2011, USAC recommended that the final discount threshold for Funding Year 2010 be set at 81%. The SLD cited their belief that they will ultimately not have enough funds to cover any Priority Two requests below this level. However, this recommendation doesn’t fall in line with the reported funds available for carryover or the FCC’s desire to increase the availability of Internal Connections funding for all schools.

How would you like it if you bought a new SONY television and after getting it home and setting it up, you realize that your remote control doesn’t work? Upon further investigation you come to realize that the remote you purchased is not compatible with your new TV...

From the shock wave that was the FCC Sixth Report and Order, to the introduction of electronic USAC payments, the E-rate program saw some substantial changes in 2010. E-rate stakeholders saw guidance (or lack thereof) in a number of different areas in 2010 as USAC attempted to simplify and streamline the process. Bookmarked by record setting snowstorms, 2010 saw a blizzard of E-rate activity all year long.

You haphazardly toss the cardboard lid in the general direction of the file box you had spent the last hour searching. Hundreds of documents, thousands of pages, you continue to see the reoccurring names and numbers when you close your eyes.

You’ve seen this show on MTV, The Real World, right? They take a handful of overly attractive twentysomethings, put them up in a designer home in the hippest part of a big city, and videotape their day-to-day activities. But the reality of The Real World is that real life as we know it isn’t like the real life the show’s producers are trying to create. After seeing some of the recent competitive bidding guidance that has been published within the last week, I’m starting to wonder if some MTV producers have recently taken positions at USAC as there is a detachment from the reality they are trying to produce and the actual reality for applicants and other E-rate stakeholders.

With all the efforts to streamline the process for applicants, the FCC could have been more thoughtful with their timing on when the Form and subsequent changes would take place.

Oscar Wilde once said, “I never put off till tomorrow what I can do the day after.” It appears that many E-rate applicants share this philosophy. A Funds For Learning Analysis revealed that 97% of applicants wait until the final week of the filing window to file their Form 471.

One has to ask with the recent shift and focus of the USAC 2010 Fall Applicant Training sessions how often schools are bribed by service providers with the promise of extravagant gifts and meals? If you attended a training this fall you may also be puzzled by the focus on the FCC “Gift Ban”. The training session led many to believe that schools were overflowing with funds and service providers wining and dining and showering school personnel with gifts and food.

According to the parent of the Universal Service Administrative Company, unbundled warranties are not necessary to maintain “the degree of reliability ordinarily provided in the marketplace”. Why, therefore, would the FCC allow USAC to use administrative USF funds to purchase unbundled warranties? Is the FCC telling schools and libraries “do as I say, not as I do”?