[Erate] E Rate Central News for the Week of September 25, 2006

Mon Sep 25 15:02:08 PDT 2006

E-Rate Central News for the Week of September 25, 2006

*	FY 2006 and FY 2005 Funding Status
*	FCC Global Resolution Order on Discount Rate Justification
*	SLD News Brief on Technology Planning

The E-Rate Central News for the Week is prepared by E-Rate Central.
E-Rate Central specializes in providing consulting, compliance, and
forms processing services to E-rate applicants and service providers.
To learn more about our services, please contact us by phone
(516-832-2880) or by e-mail <mailto:services at e-ratecentral.com>
(services at e-ratecentral.com).  Additional E-rate information is located
on the E-Rate Central Web site <http://www.e-ratecentral.com>
(http://www.e-ratecentral.com).

FY 2006 and FY 2005 Funding Status

Wave 23 for FY 2006 is scheduled to be released on September 26th for
about $28 million.  Cumulative national FY 2006 funding is now $896
million.  Funding is still being provided only for Priority 1 services.

A review of the funding decisions included in last week's Wave 22
revealed a historic first.  The status memos for 26 FRNs read:  "The FRN
was increased from $xxx to $yyy at the request of the applicant."  These
FRNs were adjusted upwards as the result of applicant-submitted Bishop
Perry corrections increasing the requested funding amounts.  Such
corrections were permitted under new procedures announced by the SLD
last July (see our E-Rate News for the Week newsletter of July 17, 2006
at
http://www.e-ratecentral.com/archive/News/News2006/weekly_news_2006_0717
.asp#b2).

Wave 58 for FY 2005 is scheduled to be released on September 27th.  This
will be a small wave of $2.5 million dollars.  The Internal Connections
funding threshold remains at 81%.

FCC Global Resolution Order on Discount Rate Justification

On Thursday, the FCC released the fifth in a series of Global Resolution
Orders ("GROs") which began with the Bishop Perry Order.  A copy of this
new GRO can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-06-1907A1.doc.  As
was the case with the previous GROs, the new Order granted a number of
FCC appeals and instructed the SLD to adopt more applicant-friendly
procedures.  An updated list of GROs is shown below.

GRO #	    FCC #	  Common Name	Date	# Appeals
Subject	

1	FCC 06-54	Bishop Perry	05/19/06	196	Clerical
and ministerial errors	
2	FCC 06-55	Pattern Analysis	05/19/06	30
Form 470 similarities	
3	DA 06-1642	Academia Discipulos	08/15/06	30
Bid assessments	
4	DA 06-1871	Alaska Gateway	09/14/06	128	Form 486
deadline	
5	DA 06-1907	Academia Claret	09/21/06	91	Discount
rate justification	
Note: Web links to any of these decisions can be found at
http://hraunfoss.fcc.gov/edocs_public/attachmatch/XX-06-YYA1.doc where
XX is either FCC or DA, and YY is the FCC sequence number as shown in
the table above.

The new GRO addressed 91 appeals, broken down into four groups.  For the
two largest groups, involving 69 private schools in Puerto Rico, the FCC
determined that the schools had properly used special NSLP survey
procedures created on an exception basis by the U.S. Department of
Agriculture for Puerto Rico and the Virgin Islands.  For the other two
groups, involving applicants located elsewhere in the U.S., the FCC
decided either that the applicants' supporting documentation was
sufficient or that USAC had not given the applicants sufficient time to
provide supporting documentation.  In the latter cases, the FCC
indicated that "USAC should not deny those funding requests where the
applicant made a good faith effort to comply with the survey guidelines
but did not include some information on the student survey regarding the
student's grade, address or number of persons in the household.  USAC
should provide applicants with a limited 15-day opportunity to file
additional documentation, if necessary, in order to support the
applicant's calculation of the correct discount rate and should accept
information already provided by the applicant that USAC deemed late."

The most important aspect of the new GRO is the procedural instructions
the FCC gives to USAC for handling future applicant inquiries on
discount rate calculations and/or related surveys.  Paralleling previous
GROs, the FCC ordered: "In future applications involving discount
calculations issues, USAC must inform applicants of any errors regarding
the discount rate calculation it identifies, along with specific
explanation of how the applicant can remedy such errors.  USAC must give
applicants a reasonable period of time in which to provide requested
information."

The GRO also suggests more flexible USAC procedures for accepting
late-filed information.  In the case of three religious schools, which
had requested supporting documentation from the state education
department that arrived after the PIA deadline (but in time for the
appeal), the FCC indicated:  "The explanation provided by the State of
New York was late, but supported the applicants' originally requested
discount percentage.  It appears from the record that the applicants
submitted the information they had in a timely manner and USAC should
therefore accept the late-filed information to determine the correct
discount rate."

SLD News Brief on Technology Planning

Last week's Schools and Libraries News Brief (see
http://www.universalservice.org/_res/documents/sl/html/sl-newsbrief-2006
0922.aspx) contains timely reminders and information on the program's
technology plan requirements.  It covers:

o	Definition of "basic" telephone, the only services for which a
plan is not required;
o	Integration with other programs' technology plans (e.g., EETT);
o	Requirement to demonstrate "budget resources;" and
o	Finding a USAC-certified Technology Plan approver.

Most importantly, particularly for applicants whose current plan
approvals expire June 30, 2007, it includes a reminder that plans
covering at least the next funding year must be "created or written" -
not necessarily approved - before the applicants file their Form 470s
for FY 2007 services.

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Disclaimer: This newsletter may contain unofficial information on
prospective E-rate developments and/or may reflect E-Rate Central's own
interpretations of E-rate practices and regulations. Such information is
provided for planning and guidance purposes only. It is not meant, in
any way, to supplant official announcements and instructions provided by
either the SLD or the FCC.

Sabrina Ganoe
Oregon Department of Education 
Office of Assessment and Information Services 
255 Capitol St. N.E. 
Salem, Oregon 97310 
(503) 947-5858 
(503) 378-5156 fax 
sabrina.ganoe at state.or.us 
Messages to & from this e-mail address may be made available to the
public under Oregon Law

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