Do You Know Where Your WAPs Are?
Schools are still on summer break and most administrators are busy preparing for school to open in the next few weeks, not focused on what is happening in the E-rate regulatory world. However the FCC released new E‑rate rules on July 23rd and all administrators, technology directors, or any school official involved in the procurement of technology needs to understand how the new rules will impact their budget planning, purchasing, procurement rules, E-rate project implementation and new FCC E-rate compliance requirements.
The FCC will be phasing out voice services, creating different discount rates for different services, adding to the document retention regulations and many more changes included in E‑rate 2.0. The FCC has set aside $1 billion in Funding Year 2015 and another $1 billion in 2016 specifically for what is now Category Two funds (a WiFi-centered version of the old Priority Two set of services and products). This is a huge change, because in FY 2013 no E-rate applicant received funds for internal connections or basic maintenance, and the SLD is now recommending to the FCC that all Priority Two projects in FY 2014 should be denied as well.
As I was reading in the Order about the new Category Two funding budget system, it struck me that now every applicant will need to be aware of the FCC asset tracking requirements for applicants that purchase equipment with E-rate funds. In fact, the Order specifies that school administrators will need to “…verify the actual location of such equipment for a period of 10 years after purchase…”
In FY 2011 and 2012, only 4,412 applicants have received commitments for Priority Two applications, making them subject to this regulation. In FY 2014, 27,186 applicants requested E‑rate funds, and we would expect all of these applicants will take advantage Category Two funds in order to better serve their respective communities. That’s over 27 thousand applicants who will need to keep ten-year asset tracking records.
The FCC, along with releasing new E-rate rules, also created a Universal Service Fund Strike Force - to guard against waste, fraud and abuse in universal service programs, including the E‑rate program. E-rate administrators need to be aware that auditors will want to be able to confirm, with on-site visits, the location of each piece of equipment purchased with E-rate funds. At a minimum, the auditors will want to see tracking for the name, invoice tag, FRN, make, model, serial number, purchase date, installation date and site location as part of the asset tracking documentation.
Funds For Learning tracks asset data for our E-rate compliance clients with our proprietary E‑rate Manager online compliance tool. Online, cloud-based records provide easy documentation access at any location, and help to keep E-rate records centralized, organized and safe.