• Explaining the rationale behind a request or recommendation
  • Equipping others with the purpose of an assignment and the significance of information
  • Giving the details, sharing the context and removing the mystery behind our words and actions

Funds For Learning has a set of Guidemarks that help guide us on how we will treat our colleagues as well as our customers. One of my favorite Guidemarks is “share the reason”. We all want to be treated with respect and not just told what the rules are at times, but would like to better understand the rationale or reasoning behind them. I recently had a conversation with an equipment manufacturer and they wanted to understand the gift rules. They were quite certain that they would not be subject to the gift rules because they do not sell direct. I shared with them that within the E-rate rules the word “service provider” is not defined and does not distinguish between a manufacture and a reseller who sells to schools directly. An attorney could argue that equipment manufactures do not sign the Form 473 which is the Annual Certification Form and thus are not technically agreeing to abide by the E-rate rules. However, I further explained that in the real world and practical application of all the competitive bidding regulations, that if a manufacturer attempts to sway an applicant purchasing decisions through the use of gifts such as laptops, it would be extremely likely that there would either be a funding denial or in the event of an audit, funds would have to be given back to USAC because of this violation. It is important for Funds For Learning customers to make decisions based on what the rules are and how USAC interprets them.

The E-rate is complex and there are often times has shifting guidance and standards. Funds For Learning will always “share the reason” to our customers as to why we believe the E-rate rules will be interpreted in a certain way.

Key Words and Phrases

Offer a rationale; Explain; Give details; Clarify; Describe; Put in plain words; Make clear; Enlighten.

Opposite Terms

Mystery; In the dark; Secrecy; Ambiguity.

GuideMarks – Distinguishing Characteristics of FFL E-rate Guides

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