Databus Issue: 2003 4 10/02/2003
E-rate and CTF
Wayne Shimizu Education Programs ConsultantStrategies for Hitting the Moving Target
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Have you ever tried to hit a moving target? It ‘s difficult, but not impossible. Managing your district’s telecommunications discounts is like hitting a moving target. It is difficult, requires aim and an understanding of the changing direction of the E-rate and California Teleconnect Fund (CTF) programs. Both the E-rate and the CTF programs have adopted new program rules and, with these changes, there are opportunities for increasing the telecommunication services discounts you can receive. Because of shrinking school budgets, it is time to take a new aim with your participation in E-rate and CTF and to reevaluate your strategies for receiving telecommunications discounts.
In the April 30, 2003, FCC Second Report and Order, the FCC clarified the definition of educational purposes (eligible purposes) for E rate eligible services. The new definition states that activities that are “integral, immediate, and proximate to the education of students” are eligible purposes for E-rate eligible products and services. What this means is that some of the administrative telecommunications services, that were not eligible in the past, will be eligible beginning with E-rate Funding Year 2004. Some examples of educational purpose under the clarified definition are a school bus driver’s use of wireless telecommunications services while bussing students and staff use of wireless telecommunications service while accompanying students on a field trip. The caution is that the operational definition of eligible educational purposes still needs to be developed by the Schools and Libraries Division (SLD). The SLD announced that they would issue instructions on implementing the new definition of educational purpose prior to the opening of the Year 2004 Form 471 window.
The FCC also ruled that wireless telecommunications services are eligible for E-rate discounts. If wireless service is used at the school or library for educational purposes, that service is eligible for support to the same extent as requests for wireline-based telecommunications services. Eligibility of wireless services is subject to the educational purpose standard.
Another ruling in the April 30, 2003, order is that voice mail is eligible for E-rate discounts as a Priority One service just as e-mail is currently eligible. Again, the SLD will define the eligibility of voice mail in an updated Eligible Services List, which is anticipated prior to the Year 2004 Form 471 window. E-rate applicants should monitor the SLD Web site (http://www.sl.universalservice.org/) for guidance on the new eligible services and the new operational definition of educational purpose. Year 2004 E-rate applications should take advantage of these opportunities to increase your E-rate discounts.
There are other telecommunications discount strategies that you, as E-rate rate applicants, can consider. For example, filing separate Form 471s for Priority One and Priority Two requests. Typically, Priority One telecommunications and Internet access requests are approved earlier in the year than Priority Two internal connections applications. To improve your chances of receiving commitments for Priority One requests early in the year, submit your requests for Priority One and Priority Two requests on separate Form 471s. You can submit multiple Form 471s referencing one Form 470.
The SLD has increased the focus on E-rate application reviews and audits. To help address questions from the SLD, you should clearly document activities related to your E-rate application. SLD Program Integrity Assurance reviews and selective reviews are intended to verify that applicants have secured access to all necessary resources (e.g., training, technical support, infrastructure, etc.) to make use of the requested technology, to have the ability to pay for the non-discounted portion of E-rate eligible services, to have considered all vendor responses to the Form 470, and to have made an appropriate vendor selection.
Other Strategies to Consider
o Engage your telephone provider(s) to help you manage your telephone bills by using available summary billing and electronic billing data systems.
o Increase your E-rate discount rate by maximizing your count of students eligible for free and reduced price lunches by using income surveys or other approved alternate discount methods (http://www.sl.universalservice.org/reference/alt.asp).
o File your Form 486 on time because your E-rate discounts will not be disbursed until the Form 486 is received and processed by the SLD. Many applicants lose discounts because of late Form 486 filings (http://www.sl.universalservice.org/reference/8form486.asp)
The California Teleconnect Fund program has also changed. With Resolution T-16742, effective May 8, 2003, the California Public Utilities Commission (CPUC) expanded the CTF to additional hospitals and community based organizations and set CTF discounts at 50 percent for all eligible entities. New CTF applicants must submit the new CTF application form, dated May 8, 2003, (http://www.cpuc.ca.gov/static/industry/telco/public+programs/ctf+app.pdf) directly to the CPUC Telecommunications Division. School districts already receiving CTF should contact their telecommunications provider to determine how new lines and additional services will be identified and submitted for CTF discounts because you are no longer required to submit applications for additional eligible CTF services to the CPUC. Instead, customers will be approved just once as an entity and the phone company will submit new service discount requests to the CPUC.
The procedures and policies for E-rate and CTF have changed. With the changes, you must take a new aim to maximize your telecommunications discounts.
