Form 470 Changes Are Coming
Last week, I said I would provide a few ideas for improving the Category Two system. You will have to wait another week for that because I would like to focus your attention on an important news item. USAC is releasing a new Form 470 in EPC. While well-intentioned, I am concerned that this new system will lead to more funding denials: “Items listed on Form 471 do not match items listed on Form 470.”
The entire application process is beginning to be administered at a nano-level scale. What do I mean by this? If cheeseburgers were eligible for E-rate support, you could no longer go into the EPC restaurant and simply order a cheeseburger. Instead, you would have to order two pieces of bread, a quarter-pound of beef, 1 slice of cheese, a piece of lettuce, and so on. You also would be required to pay for each of the items individually. Even more frustrating is the fact that you have to specify you want a cheeseburger. What if you are just interested in lunch and would like to know what your options are?
When it started, the E-rate program allowed applicants to specify solutions and encouraged them to keep an open mind about different technologies and the various methods for achieving their goals. That was the past. The new trend is towards a system that all but requires applicants to have a specific bill of materials in their hands just to complete the Form 470. An applicant can no longer specify their bandwidth requirements and see what proposals come their way. Now, they must pre-select their technology and lay out all the details of their project ahead of time.
State and local bidding requirements should guide the competitive bidding process; and applicants should have the freedom to specify their desired solutions at a level and in a manner of their own choosing.