I certainly recognize that there are many important and complex issues that the FCC is struggling with and that you have been consumed by creating and now implementing the National Broadband Plan. However, E-rate stakeholders are waiting patiently for guidance from the FCC regarding the proposed CIPA changes.
Proposed CIPA Rules
In November 2009, the FCC proposed that E-rate recipients that receive Internet access and internal connections should be required to certify on its Form 486, for FY2010 that it has updated its Internet Safety policy to include plans for educating minors about appropriate online behavior. Internet safety policies should now include language addressing interacting with other individuals on social networking websites and chat rooms and cyberbullying awareness and response, as required by the Protecting Children in the 21st Century Act.
We are two weeks into FY2010 and many applicants have received funding commitments and already notified USAC that services have begun on their approved commitments. However, these same applicants are still confused to when the new CIPA rules may be in effect, what the new rules will be and how USAC will confirm compliance. Since FY2010 has begun without clarification of the new rules of compliance, the FCC should make it clear to E-rate stakeholders that the new standards will not be applied retroactively during audits.
Please release the new rules now in order for the education community to avoid further confusion over the expectations.
Thank you for your continued hard work on making the E-rate program easier to manage.