Buried in USAC’s latest quarterly report to the FCC are two sentences that many people probably skimmed over, but will have a huge impact on E-rate applicants. From Page 5 of the report:
“…USAC plans to increase validation checks for…Schools and Libraries Support Mechanism beneficiary compliance with the Children’s Internet Protection Act (CIPA)….The CIPA validation is planned to be operational during 2009.”
This brings up the question…How can applicants know they have the documentation necessary to demonstrate compliance with this review process?
While USAC hasn’t shared information about this review, we hope that they are putting in place a procedure that evaluates an applicant’s CIPA compliance, but is not so rigid as to cause funding denials or revocations when they discover their review procedure doesn’t fit every situation. This would avoid unnecessary and lengthy appeals to the FCC. We’ve seen cases in the past where the FCC has stepped in and directed USAC to re-work their procedures so that applicants can obtain and retain E-rate funding in situations where a denial is not warranted.
Taking cues from documents already on the SLD’s website and documents requested of applicants during audits, we have put together a CIPA Compliance Documentation Checklist that can be found in our Applicant HelpCenter. While we can’t be certain that the checklist covers everything (again, since USAC has not shared information about this review), we think that this will help applicants assess their ability to demonstrate their compliance with the requirements of CIPA.