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SLD Releases Draft Version of Revised Eligible Services List

The Schools and Libraries Division Sept. 26 released a draft version of the latest revisions to the E-rate program's official list of eligible services, reflecting several major changes in the Federal Communications Commission's position on some services and products.

The draft was released at the SLD's annual training session for state E-rate coordinators. It will be posted on the SLD's web site when the language is finalized, but SLD officials said they did not expect the final version to be substantively different from the draft.

According to the draft list, these major changes would occur:

• Firewalls, described as "a hardware and software combination that sits at the boundary between an organization's network and the outside world" would become eligible for support, either as a service or when purchased as an internal connection. SLD staff members indicated the change reflected policy makers' heightened concerns about network security. However, a standalone proxy server would remain ineligible because it was deemed "not necessary to transport information."

• Dark fiber, or "fiber optic cable for which the service provider has not provided modulating electronics," which was previously defined as an eligible service, would become ineligible on the latest edition of the list. The draft statement said, "the FCC has not resolved whether unlit dark fiber is a telecommunications service. Pending resolution of this issue, it is not eligible for funding." The SLD said the FCC had not yet provided it with guidance on how it should treat existing multi-year contracts that applicants had put in place when dark fiber was considered eligible.

• Although the draft version said equipment that supported voice or video over IP would remain eligible in the internal connections category, the position on voice/video over IP as a service changed. The list said that the FCC "has yet to determine whether VoIP is a telecommunications service or an application provided over an unregulated information service. Pending resolution of this issue, VoIP service is not eligible for funding."

• The draft list clarified that voice mail service would become eligible in either the Telecommunications Services or Internet access categories, and that voice mail equipment could be purchased in the Internal Connections category. That language helped clarify the intent of the FCC's Second Report and Order, adopted last April, which discussed voice mail only as a "service." The draft list also stipulated that "end-user products such as answering machines" would not be eligible under this definition.

• Web hosting, defined as "an Internet service provided by an Internet Service provider," and provided as a part of a bundled service offering or an optional service, would become eligible. However, the draft list said that eligibility would be limited to the hosting service only, and not for the creation and modification of content.

• The eligible services list also clarified the definition of eligible maintenance and tech support services for internal connections equipment. "Technical support," it said, "may include the installation, maintenance and change to various eligible services and equipment under contract." Maintenance involves "the repair, replacement or reconfiguration of eligible components." The list said "Basic maintenance services are eligible if they are a component of a maintenance agreement/contract for an eligible service or product, and these maintenance services are cost-effective. The agreement or contract must specifically identify the eligible products or services covered, including product name, model number and location. Only services that are necessary to ensure that the network is capable of transmitting information to the school or library are eligible. End user support is not eligible. Network management services, such as monitoring of bandwidth usage, are not eligible.

The SLD staff indicated that additional information will be forthcoming related to "Special Eligibility Condition for Eligible Users and Locations," which should guide the determination of who is eligible to receive cellular and paging services under a new FCC definition of "educational purposes." As part of its Second Order, the FCC specified that activities that are "integral, immediate and proximate" to the education of students, or in the case of libraries to library patrons would be presumed to be eligible. SLD staff also said that its guidance on the eligibility of services and products supplied to administrative offices will also be revised.

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