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E-Rate 2.0: Reforming E-Rate for a New Digital Era

E-Rate 2.0: Reforming E-Rate for a New Digital Era. Bridget Duff State E-Rate Coordinator Division of Telecommunications, DMS. Overview of E-Rate Program. Began January 1998 Eligible K-12 schools and libraries receive discounts of 20% - 90% on eligible: Priority 1: Connectivity

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E-Rate 2.0: Reforming E-Rate for a New Digital Era

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  1. E-Rate 2.0: Reforming E-Rate for a New Digital Era Bridget Duff State E-Rate Coordinator Division of Telecommunications, DMS

  2. Overview of E-Rate Program • Began January 1998 • Eligible K-12 schools and libraries receive discounts of 20% - 90% on eligible: • Priority 1: Connectivity • Telecommunications • Internet Access • Priority 2: Internal Infrastructure • Internal Connections • IC Maintenance

  3. Overview of E-Rate Program • Funding Year: July 1- June 30 • Annual Process • Procurement: Form 470 - Competitive Bidding, Eligible Services & Vendors, Vendor Selection, Contracts • Application: Form 471 – Category of Service, Discount Calculation, Cost Allocation, P1 vs. P2 • Review: Response to PIA, Documentation • Invoicing: SPI vs. BEAR

  4. History of E-rate Reform

  5. National Broadband Plan • March 2010, the National Broadband Plan (NBBP) was released by the FCC. http://www.broadband.gov/plan • 376 pages: set broad national broadband goals for education, government, consumers, homeland security, health care, and energy. • Education section • Twelve E-raterecommendations, most of which are in E-rate 2.0 NPRM.

  6. Interim E-rate Reforms • September 2010: FCC released Sixth Report & Order • Allowed applicants to lease fiber from any provider (not just telecommunications carriers) • Allowed applicants to lease existing dark fiber • Allowed community to use E-rate eligible services after hours – on school campus • Allowed E-rate funded services to be provided to most K-12 dorms • Created one year pilot program that provided funding for off-campus wireless connectivity through mobile devices • Allowed for annual inflation adjustment to E-ratefunding cap (FY 2013: $2.25B + $130M=$2.38B) • Eliminated tech plan requirement for Priority 1 services

  7. ConnectED • June 2013: President Obama introduced the ConnectED initiative: • Within 5 years, connect 99% of schools to 100 mbps, with a target of 1 Gbps • Provide high-speed wireless connectivity within all schools and libraries • Called on the FCC to make this happen. • FCC can change E-rate without Congressional approval

  8. E-rate 2.0 NPRM • July 2013:FCC released E-rate 2.0 Notice of Proposed Rulemaking (NPRM) • Massive document containing 175 pages • 616 questions and 357 ideas on which comments were requested • NPRM divided into six categories I. Introduction II. Goals and Measures III. Ensuring schools and libraries have affordable access to 21st century broadband that supports digital learning IV. Maximizing the cost-effectiveness of E-rate funds V. Streamlining the administration of the program VI. Other outstanding issues

  9. E-rate2.0 NPRM General • Seventeen major issues/topics being considered. • FCC seeking feedback from the applicant/vendor community • Some of the topics are actual proposals; others are issues for which they are seeking comments • Requests for data • Initial comments were due September 16; reply comments due October 16 • FCC reads all comments; especially fond of real world school and library submissions

  10. Treat Lit and Dark Fiber Equally • FCC proposes to treat lit and dark fiber more consistently by making modulating electronics and special construction charges eligible as part of dark fiber (as it now does for lit fiber) • Asks many questions related to fiber deployment: • What are barriers to fiber deployment? • Should E-rate support the purchase of WANs if it’s more cost effective than leasing? • Should one-time installation costs receive a higher discount? • Can the FCC do anything to reduce recurring costs over time by altering any of its policies? • Should Eligible Services List be amended to include additional equipment that is needed for broadband connectivity within buildings?

  11. Make Broadband Priority One • 2011 FCC survey data indicates that 80% of applicants surveyed said they did not have sufficient bandwidth • FCC proposes to update E-ratepriorities so that high-capacity broadband and the associated equipment needed to disseminate that broadband to and within buildings becomes Priority One • All other services would become Priority Two or phased out altogether • What different or additional services should be considered eligible such as filtering, caching and network security services, etc?

  12. Revise Eligible Services List • FCC proposes to phase out support for a number of specific services including: • Paging • wireless text messaging • directory assistance • custom calling features • inside wiring maintenance plans • call blocking • 800 number services. • When should such changes be made? FY 2014?

  13. CIPA • FCC seeks comment on several CIPA related questions, including: • Are laptops, netbooks with Internet access, smartphones, and Internet enabled e-readers considered computers that must comply with CIPA? • Are personally owned devices that are not owned by schools and libraries required to be CIPA compliant when used on-campus? • Are school-owned devices used off campus and used with outside networks required to be CIPA compliant?

  14. Establish Connectivity Goals • The State Education Technology Directors Association (SETDA) has set the following goals: • INTERNETconnectivity goal of 100 Mb per 1000 users by 2014 (increasing to 1 Gb per 1000 users by 2017) • WANconnectivity goal of 10 Gb per 1000 users by 2017 • Should the FCC adopt these goals? • Are these targets appropriate for all schools? • How are schools’ bandwidth needs changing, particularly in those schools that have one-to-one initiatives? • What should the goals be for schools that have very few students? • How should the FCC measure and monitor progress to such goals? • Should applicants have to install monitoring equipment to identify how much bandwidth they are actually using?

  15. Streamline E-rate • FCC proposes several options for streamlining the administration of the E-rate program, including: • Requiring all forms and USAC correspondence to be submitted/sent electronically • Providing more detailed and comprehensive funding statuses throughout the application process • Speeding review of applications and issuance of commitment decisions (asks commenters to explain problems they have had during PIA review process) • Removing distinction between telecommunications services and Internet access • More effectively identifying and capturing unused funds (why do funds go unused and how can USAC identify and de-obligate those funds more quickly?) • Streamlining the E-rate appeals review process

  16. Change Funding Distribution • FCC seeks comment on four major options for revising the distribution of E-rate funds: • Revising the discount matrixto increase certain applicants’ matching requirements through a phase-in process • What should the maximum E-rate discount be? 70%? 75%? • Should all of the discount bands be adjusted downward by a certain percentage? • Should the discount matrix be abandoned in lieu of a discount calculated as NSLP percentage plus 20% (urban) or 25% (rural)?

  17. Change Funding Distribution • FCC seeks comment on four major options for revising the distribution of E-rate funds: • Incorporating a per-student or per-building cap on fundinginto the discount matrix. • What would those caps be? • Should they apply to both Priority 1 and Priority 2 funding? • Should installation fees be excluded from the calculation? • Should there be a di minimus amount funding available? • How would consortia apply using a per-student cap?

  18. Change Funding Distribution • FCC seeks comment on four major options for revising the distribution of E-rate funds: • Providing more equitable access to Priority 2 funding • How can the FCC ensure more applicants have access to P2 funding • Should the 2/5 rule be replaced with another rule, such as a 1/5 rule? • Should P2 be funded on a rolling-funding cycle? • Should there be different priorities established, such as a broadband/Internet P1 category and other service (such as voice) become Priority 2 (or some other priority)?

  19. Change Funding Distribution • FCC seeks comment on four major options for revising the distribution of E-rate funds: • Allocating funds through a fixed dollar amount before the funding year begins • How would this amount be calculated for libraries? • How would it be calculated for schools? • How would this work with consortia? • What would the reporting requirements be?

  20. Change Funding Distribution • FCC proposestwo major revisions to E-rate discount calculations: • Change E-rate discount calculations to be based on a simple average of District’s NSLP enrollment • Current formula is a weighted average approach that uses each school building’s discount as part of the calculation • Change definition of rural to ensure greater funding to truly rural areas by using NCES codes • Should the definition be based on ‘rural’ or ‘remote-rural’ areas? • Should the rural schools and libraries receive a greater discount than they currently receive and should the rural factor also be incorporated into the highest discount bands?

  21. Increase Funding Cap • FCCseeks comment on whether to increase the annual $2.25B funding cap (temporarily or permanently) to ensure high capacity broadband connectivity to and within schools and libraries

  22. Reform Competitive Bidding • The FCC seeks comments on how to reform the competitive bidding process: • What are reasons that applicants do not receive multiple bids? • How can they reduce the number of applicants that don’t receive multiple bids? • Does the Lowest Corresponding Price Rule help ensure that applicants receive cost-effective prices? • Should applicants be exempted from the Form 470 bidding process if they have complied with state procurement rules or if their total E-rate funding is below a certain amount? • Should applicants be required to submit all competitive bidding documentation with their Form 471s or should they be required to submit a bid evaluation sheet?

  23. Reform Competitive Bidding (CONT) • Does the current system provide enough information to vendors to formulate bids? • Should all state master contracts automatically be deemed E-rate eligible even if they were not procured under the E-rate competitive bidding system? • Should the deadline for signing contracts with vendors be revised to make it easier to comply with E-rate deadlines? • Should technical assistance be offered by USAC to help applicants figure out cost effective pricing options and/or planning and procuring cost effective networks?

  24. Increase Consortia/Bulk Buying The FCC seeks comment on ways to increase consortium purchasing • Does consortia purchasing reduce costs? • How should the FCC encourage more consortia and other types of bulk buying opportunities? • Should applicants be required to buy from state or regional master contracts • Should the FCC or USAC establish a bulk buying program?

  25. Increase Transparency • FCC proposesto increase the transparency and seeks comments on the following: • Transparency of E-ratespending • How can the FCC increase transparency with respect to how E-rate funds are allocated and spent? • Transparency of prices available for E-rate supported services • How can the FCC best increase the transparency of prices for E-rate supported services? • Transparency of prices being bid for E-rate supported services • Should the FCC consider making bid responses public or at least accessible to other E-rate applicants? • Transparency of actual purchase prices • As an alternative to requiring public disclosure of all bids to provide E-rate services, should the FCC make available the prices applicants are paying for E-rate supported services?

  26. Direct Payments to Applicants • FCC proposes to permit schools and libraries to receive BEAR reimbursement checks directly from USAC and not have to pass through the respective service providers • Should invoicing deadlines be more rigid in order to recapture and reuse unspent funds?

  27. Permit Multi-year 471s • FCC proposes to have PIA only review the first year of a three year contract, provided there was no changes to the contract or recipients of service in the second and third years of contract. • In the second and third years, applicants would still have to request E-rate funding via the Form 471, but their contracts would not be subject to PIA review. • Should FCC also consider multi-year funding commitments? • Should applicants only be permitted to sign contracts up to three years in length?

  28. Expand Document Retention • FCC proposes to extend the E-rate program document retention requirements from five to at least ten years and seeks comments on the benefits and burdens of doing so • Should applicants and vendors be required to keep records of all communications relating to bids for and purchases of E-rate services/equipment? • Should the additional retention period only be required on an “as-notified” basis?

  29. Permit Community Wireless Hotspots • Should E-rate support be available for off-site Internet access for students and the general public through “community wireless hot spots?”

  30. Restrict Authorized Signatories • The FCC proposes to require E-rateapplications to be signed by a person with authority equivalent to that of a corporate officer (presumably this is to eliminate E-rate consultants from signing forms) • The FCC proposes to require a corporate officer of the service provider sign certain forms submitted to USAC

  31. Filing Comments with the FCC • Comments should: • Include your organization’s name and date on each page • Use a table of contents, regardless of the length of the submission • Track the organization set forth in the NPRM in order to facilitate or internal review process (i.e., refer to paragraph numbers from the NPRM) • Begin with a short and concise summary of your argument • Be submitted in .PDF format

  32. Filing Comments w/the FCC • To submit your comments, go to: http://apps.fcc.gov/ecfs/upload/display?z=xj9g5 • Click ‘Submit a Filing’ at the top left under ECFS Main Links. • That will take you to an input page, asking for contact information. • Proceeding # is 13-184 • Helpful filing guide available at: http://e-ratepa.org/erate_2oh.htm

  33. Questions?

  34. DMS E-Rate Assistance Team Bridget Duff bridget.duff@dms.myflorida.com 850-921-1650 Adolfo Arauz adolfo.arauz@dms.myflorida.com 850-921-1651 Lauren Harris lauren.harris@dms.myflorida.com 850-922-7503

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