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

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

Bridget Duff

State E-Rate Coordinator

Division of Telecommunications, DMSSlide3

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 MaintenanceSlide4

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. P2Review: Response to PIA, Documentation Invoicing: SPI vs. BEARSlide5

History

of

E-rate Reform

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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-rate

recommendations, most of which

are in

E-rate 2.0 NPRM.

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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 fiberAllowed community to use E-rate eligible services after hours – on school campusAllowed 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-rate

funding cap (FY 2013: $2.25B + $130M=$2.38B)Eliminated tech plan requirement for Priority 1 services

Interim E-rate Reforms

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ConnectED

June 2013: President

Obama introduced the

ConnectED

initiative:

Within 5 years, connect 99% of schools to 100 mbps, with a target of 1 GbpsProvide 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

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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 requestedNPRM divided into six categoriesI. 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

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E-rate

2.0 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 commentsRequests 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

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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?

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Make

Broadband Priority

One

2011 FCC

survey data indicates that 80% of applicants surveyed said they did not have sufficient bandwidthFCC proposes to update E-rate priorities 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?12Slide13

Revise

Eligible Services List

FCC

proposes

to phase out support for a number of specific services

including: Pagingwireless text messagingdirectory assistancecustom calling featuresinside wiring maintenance

plans

call blocking

800

number services.

When should such changes be made? FY 2014?

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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?

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Establish

Connectivity Goals

The State Education Technology Directors Association (SETDA) has set

the following goals:

INTERNET

connectivity goal of 100 Mb per 1000 users by 2014 (increasing to 1 Gb per 1000 users by 2017)WAN connectivity 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?

W

hat

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?15Slide16

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

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Change

Funding Distribution

FCC

seeks comment

on four major options for revising the distribution of

E-rate funds:Revising the discount matrix to 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)?

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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 funding into 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?

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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 fundingShould 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)?

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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?

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Change

Funding Distribution

FCC

proposes

two 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? 21Slide22

Increase Funding Cap

FCC

seeks 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

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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?

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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?

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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 contractsShould the FCC or USAC establish a bulk buying program?

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Increase

Transparency

FCC

proposes

to increase the transparency and seeks comments on the following:Transparency of E-rate spending 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?26Slide27

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? 27Slide28

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?

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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? 29Slide30

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?”

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Restrict

Authorized Signatories

The FCC

proposes

to require

E-rate applications 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

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Filing

Comments

with the

FCC

Comments should:

Include your organization’s name and date on each pageUse 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

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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 13-184Helpful filing guide available at:http://e-ratepa.org/erate_2oh.htm

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Questions?Slide35

DMS E-Rate Assistance Team

Bridget Duff

b

ridget.duff@dms.myflorida.com

850-921-1650

Adolfo Arauzadolfo.arauz@dms.myflorida.com850-921-1651Lauren Harrislauren.harris@dms.myflorida.com850-922-7503