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SLD Highlights Some Changes for 2005, Decisions Delayed on Others

The Schools and Libraries Division this week detailed some changes in its application forms and procedures for the 2005 funding year, but was unable to provide information about some key remaining questions.

The SLD clarified that it will apply a new Federal Communications Commission rule, restricting sites to "receive commitments" for internal connections in only two out of every five years, at the point commitments are approved, rather than disbursed. This should force applicants to be more careful in applying for commitments that they actually intend to use because a commitment will count against them at the point that it is approved.

The exception to that rule is network maintenance. The new Form 470 and 471 applications for the 2005 funding year will feature a new "basic maintenance of internal connections" category, for which applicants can receive support every year, assuming that they are poor enough to qualify. The traditional internal connections category will now be described as "internal connections other than basic maintenance."

The new forms will include a number of additional certifications and information items, that SLD staff members said should speed its ability to review applications. These will include places where applicants can indicate that their applications include requests for special schools, requests that are duplicated on another application, and requests involving a multi-year contract. New certification statements will more explicitly target areas that have turned up as issues with auditors or in the SLD's efforts to address waste, fraud and abuse in the program.

Applicants will be required to tally the amount of money they will be expected to provide to be able to use all of their funding requests. In addition, applicants will be asked to provide their "total budgeted amount allocated to resources not eligible for E-rate support.".SLD staff said that these changes were in response to applicants who did not understand how much of their own money they were expected to provide, or that they were also expected to have the funds available for such necessary resources as staff development and adequate personal computers. The SLD staff said that applications would not be rejected on the basis of these answers, but could be subjected to additional questioning.

An SLD staff member explained, "What we are worried about is all the people who say, ‘I had no idea of what my non-discount share was.' It was not on the form before. Now it is."

Under a new FCC order, all E-rate program participants, including applicants, service providers, consortia and consultants, will be required to obtain an FCC Registration Number, known as "FRN" in general FCC parlance. Entities will be expected to obtain an FCC registration number by November 1, although the number will not be required to complete the Form 471 application for 2005. The SLD staff said that after November 1, Program Integrity Assurance reviewers would begin asking program participants for their FCC numbers when they interact with them.

Numbers can be obtained by accessing the FCC's web site at and clicking on the link to "CORES," the FCC's data base. To obtain a number, participants are asked to provide a Taxpayer ID Number (or TIN), typically an Employer ID number or Social Security Number for federal tax purposes. The SLD said that applicants will be expected to obtain FCC numbers for all of their traditional SLD entity numbers.

On their applications, schools will once again have to supply their "NCES," or National Center for Education Statistics, numbers, a system that the SLD abandoned in the early years of the program. Libraries will be expected to provide their "FSCS Code," a number used by the federal government to identify libraries.

An SLD staff member was greeted with applause when he said that applications would no longer be rejected for failure to complete Minimum Processing Standards if information was missing from a discount worksheet. Instead, he said, applicants would be contacted for the necessary information. In addition, the SLD has revised the format of the discount worksheets into a single page, with different columns that must be completed, based on the situation of the applicant.

The SLD said applicants who had filed a Form 470 this year before the new application form was ready would not have to file a supplemental form with additional certifications. Instead, the SLD said, those certifications would be incorporated into the Form 471 for this year.

SLD and FCC staff members could provide no specifics on when funding commitment waves for 2003 and 2004 would be resumed, but said they hoped the issues would be resolved soon. Funding commitments were put on hold in August after the FCC and the Universal Service Administrative Company encountered issues in moving USAC to the governmental accounting system.

It was also unclear how quickly the final version of the Eligible Services List for the 2005 funding year would be released. The list is supposed to be issued at least 60 days before the start of the 2005 filing window, but officials said the FCC might be required to waive that rule to keep the application process on schedule.

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