A r c h i v e d  I n f o r m a t i o n

Report to the Federal Communications Commission (FCC)
by
The E-Rate Implementation Working Group (Working Group)
composed of
U.S. Department of Education
Institute of Museum and Library Services
National Telecommunications and Information Administration
Rural Utilities Service
Education and Library Networks Coalition

July 31, 1997

VI. Interim Requirements

It is probably not possible to establish a data warehouse or similar system or to achieve good data-format standardization in time to begin disbursing funds in January 1998. Although this should not be allowed to delay the starting date for the E-rate, the application process must be largely paper driven until a highly computerized system can be implemented. Since large quantities of information that has simply been digitized in textual form will be of limited usefulness, the Working Group recommends that at least during the interim phase RFP/descriptions of services should not actually be transmitted to SLC, but should instead be made available to potential bidders on request. In lieu of such transmission, the Working Group recommends the use of standardized checklists, along with a short summary description of the applicant's objectives in procuring the services, to identify material for more detailed study. We have included such checklists in our recommended application forms. ¹¹ The information required by the summary and checklists would be transmitted to SLC and posted on the website. Service providers have confirmed to members of the Working Group that this information would be more useful to them in initially culling out promising bidding prospects for further analysis than the actual RFP/descriptions of services, and they helped the Working Group develop the recommended checklists. The providers would want to see the more detailed documents on a more selective basis only after establishing a preliminary interest from the summary and checklists.

Because of budget cycling for schools and libraries, most E-rate applications submitted prior to the start of the 1998-99 school year will likely be for existing contracts within the meaning of the E-Rate Ruling. The Working Group recommends that flexibility similar to that extended to those contracts with respect to posting should be given to the inventory/assessment and approved technology plan requirements at least during the interim period.

As indicated previously, E-rate applicants will frequently not have inventory/assessments of their own but will need to rely on lower-level entities covered by their applications. Many schools and libraries already conduct inventories for their own use. However, existing inventories are not in standardized form, and schools and libraries should not be required to conduct new inventory/assessments until detailed specifications for them are available. Lead time is necessary for high-quality standardization, and the baseline data obtained from the first round of inventories should be of very high quality. In addition to existing school and library inventories of their own, similar information is already collected for other Federal and State programs, such as the surveys by the National Center of Education Statistics and the National Commission for Library and Information Science. In designing standardized inventory/assessments for the E-rate, every effort should be made to relieve the problem of multiple collections of similar data. Accordingly, the Working Group recommends that the inventory/assessment requirement not be implemented until after the interim period.

With respect to technology plans, we agree that schools and libraries should not be afforded the benefits of the E-rate without "doing their homework" (¶571). In fact, we believe that most schools and libraries are already covered by some pre-approved technology plan. There should be no need, however, for SLC to collect those plans at least during the interim period. We recommend that at least during the interim period the applicant be required to certify that every school and library receiving supported services under its application is covered by an approved technology plan, to identify those plans and approvals in its application or work papers and to provide them to SLC upon request. ¹²

¹¹ Although members of the Working Group had some discussions with service providers to attempt to ensure that these checklists are technologically neutral, the timetable for our work did not allow a sufficiently thorough investigation of the matter. If the FCC accepts the Working Group's recommendation as to the checklists, it should confirm their technological neutrality.
¹² The Working Group believes that standardization of the contracts for eligible services would interfere with State and local procurement requirements without substantial apparent benefits. We do recommend, however, that at least during the interim phase applicants retain the contracts in their working papers and provide them to SLC upon request.

[ V. Data Warehouse ]					[ VII. Aggregate Discount Rates ]

This page last updated 8/10/97 (pjh).