e-Rate filing window opens Dec. 2

Schools and libraries can begin applying for 2009-10 e-Rate discounts on Tuesday, Dec. 2, and they’ll have until 11:59 EST on Thursday, Feb. 12, to submit all necessary Form 471 application materials, says the Schools and Libraries Division (SLD) of the Universal Service Administrative Co., the agency that administers the program.

In recent years, the e-Rate filing window has opened toward the beginning of November. This year’s filing window opens later than usual. And while that won’t affect the amount of time schools and libraries will have to apply for their share of $2.25 billion in telecommunications discounts, it could affect how long it takes the SLD to process all the applications and issue funding commitment decision letters to applicants.

And that, in turn, could push back notification of more schools and libraries beyond the July 1 start of the new program year, some applicants fear.

Cheryl Stepp, instructional technology supervisor for Florida’s Osceola County Schools, noted that e-Rate applications have undergone increased scrutiny in recent years.

"With all the checking and cross checking, [coupled with the delay in the opening of the filing window,] they won’t be approving many 471s in time," Stepp predicted of SLD officials. "Thank goodness we apply for reimbursement, and not for the SLD to pay part of our phone bill [directly]. Those are the people who will suffer. If [schools] apply to have the SLD pay a portion of their bill and it is not approved until late July or August, the poor schools … might be paying the whole July bill [by themselves]."

Bonnie Tollefson, director of the Levy County, Fla., public library system, expressed another concern with the late opening of the filing window.

"Because my 471 has to go through the county attorney and the Board of County Commissioners before it can be submitted, and [because] the December holidays are coming up, I won’t be able to submit it until late January," she said. "That will push us [farther back] in the approval process, which will mean we’ll have to have funds in our budget to handle the bills until the discounts kick in."

SLD spokesman Eric Iverson downplayed the concerns. Despite the delayed start to the application process, "the window will be open for the same time period as it has in the past," Iverson said. He also said there "shouldn’t be any material impact on applicants" in terms of how quickly they will start to receive funding. 
Peter Kaplan, director of regulatory affairs for e-Rate consulting firm Funds for Learning (FFL), agreed with Iverson’s take.

"Schools typically don’t wait until the announcement of the window to start their e-Rate procurements," Kaplan said. "If the window closes [in] mid-February, the SLD should be able to process applications in a timely manner. This past spring, FFL released an analysis of the pace of funding, commitments and the SLD [has made] improvements in processing Form 471s each year."

The SLD had to delay the opening of the filing window while it waited for the Federal Communications Commission (FCC) to issue its annual list of products and services that are eligible for e-Rate discounts.

That took longer than usual this year, because the FCC was considering several proposed changes to the program’s Eligible Services List (ESL).

Earlier this year, the FCC issued a Notice of Proposed Rule Making in which it sought public feedback about these proposed changes. In particular, the agency wanted to know whether e-Rate stakeholders thought it should add filtering software, antivirus software, firewall services, broadcast messaging services, and several other new products and services to the ESL. (See "FCC seeks comments on e-Rate eligibility.")

When all was said and done, the agency chose not to act on any of its proposed changes–at least, not this year. The ESL for the 2009-10 e-Rate program year remains the same as last year’s list.

Many of the responses the FCC received objected to these proposed changes, Kaplan said.

While the SLD "can only disburse a little over $2 billion each year, … close to $4 billion gets requested each year," he explained. "If you make more services eligible, that makes it less likely that poor school districts will get access to the Priority Two products and solutions they desperately need."

Kaplan said it’s also possible that the FCC did not want to make any major changes to the program until a new administration takes over in Washington. FCC officials were unavailable for comment.

The agency’s inaction regarding the ESL disappointed some applicants.

"We are very disappointed that the [new ESL] did not include the proposed changes," said Osceola’s Stepp. "The software mentioned–antivirus, filtering, etc.–is expensive software. As the SLD requires us to provide the protection for the students as well as the equipment and network, [it] should be willing to assist in those costs."

The e-Rate is a $2.25 billion-a-year federal program that provides discounts on telecommunications services, internet access, and internal connections for all eligible schools and libraries. Applicants can request discounts of between 20 and 90 percent of the cost of eligible products and services.


Schools and Libraries Division

Federal Communications Commission

Osceola County Schools

Funds for Learning