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
IX. Application Forms
Appendix C is a set of three recommended forms for the E-rate application process during the interim period, a separate application, a funding request, and a service-commencement notification, as provided in the E-Rate Ruling (¶¶572-80). 23 These three basic forms can be combined into additional versions for special situations. For example, existing contracts within the FCC's definition and individual takedowns from master contracts would not require posting (see p.6 & n.6, n.14, above), and the necessary information from the application and possibly the notification should be combined into the funding request.
To avoid any need to duplicate unchanged information and to facilitate the linking of related forms, a system of tracking numbers should be established. The applicant would have its own unique number, which it would obtain from SLC before filing its first application, and include in the application form. When SLC notified the applicant of the posting date for its application, it would give the applicant another unique number for the application, which would then be included in any funding request relating to that application. When SLC notified the requester, which might be a different party from the original applicant, that its funding request had been granted, it would give the requester a unique number to be included in any service-commencement notification based on that funding request. Finally, another unique number would be assigned to each service provider and included in the notification.
As recommended earlier in this report (see p.11, above) the application form and funding request for the interim period would substitute a summary description of objectives and a checklist of services for the posting of a detailed description of services. Similarly (see pp.12-13, above), the recommended application form would substitute a certification as to other necessary technology components for the furnishing of an inventory/assessment during the interim period. Finally, as recommended (see pp. 13-19, above), the requester would calculate its own discount rate in its funding request according to the principles that the Working Group recommends, rather than merely submitting the necessary poverty rate(s) in the original application.
At the request of service providers, we have added additional locational information to the recommended application form. Service providers have told members of the Working Group that, since many of them have limited service areas, they need to know the location of the individual schools and/or libraries involved in aggregate applications. As in other cases, however, such requests must be balanced against the burden that would be imposed on applicants. The information requested could be quite voluminous for some applicants, such as States. Accordingly, if the applicant is an education or library governance entity with a defined geographical jurisdiction and serving all of its schools and/or libraries, such as a school district, library system or State, the applicant's name, type and address should give the necessary information. In all other cases, the application form would require the zip codes of the individual schools and/or libraries. In a data warehouse, however, all such information would be integrated into the application by reference to the identification numbers for all of the individual end users.
Service providers also requested that schools and libraries submit to SLC month-by-month projections of funding needs by individual service in order to ensure that USF support is not being requested for ineligible services. The Working Group believes that the certification on this subject contained in the recommended application form is sufficient for that purpose. Service providers are better able to supply the detailed breakdowns and could do so in their reimbursement applications, to the extent that information is required.
The Working Group has begun drafting detailed instructions for these recommended forms. If the FCC accepts these forms, we would be pleased to complete the instructions and any combination forms that may be appropriate.
23
If the FCC meant to change the nature of the third form or add a fourth (see n.8, above), we shall make the appropriate modifications.
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