Who will be the beneficiary of the streamlining efforts by the FCC for Funding Year 2011? Certainly not applicants who are now left to wait and ponder the late opening date of the filing window. With the promised changes to the forms, many applicants will wait to begin the procurement process and risk any penalties or confusion by USAC reviewing the old Form 470. Was the FCC listening when program stakeholders responded to the Notice of Proposed Rule Making and repeatedly pleaded to delay any changes until after July 2011? Could stakeholders have foreseen the inevitable delay to the filing window dates? USAC is now frantically programming new forms and systems to accommodate the changes in time for the filing window and has informed applicants that this development has guaranteed a late opening of the window until the first or second week of January. USAC has indicated that applicants should not fear as the window will remain open the 75 days, pushing the close of the window until late March and potentially early April.
PIA will now have 4-5 weeks less time to review applications prior to start of the funding year. How can this possibly improve USACs ability to review applications prior to the start of the funding year in July? Furthermore, many school districts across the nation close for spring break mid March and have planned vacations scheduled. With a filing window deadline looming overhead during the month of March, applicants should be warned not to schedule time off. In fact, the FCC seems to feel no urgency at all in setting the official dates of the window. They must have no true understanding of the time and effort that a school district dedicates to completing the applications and related procurement and contract requirements. Nor does the FCC seem to care about the USAC administration burden to develop a system to receive new forms with little testing before such an important deadline.
With all the efforts to streamline the process for applicants, the FCC could have been more thoughtful with their timing on when the form and subsequent changes might take place. Program stakeholders have been awaiting the promised follow up guidance from the FCC regarding the 6th report and Order, to which none has been provided as of yet. USAC encourages applicants to start their procurement efforts early however, many are waiting for further guidance on the changes on the Order and a deeper understanding of how those changes effect current contracts.
The lack of understanding how to interpret some of the changes rolled out in the 6th Report & Order, the pending changes to the Form 470 and Form 471, and the lack of a set filing window deadline all combine to create a situation of confusion and potential ministerial and clerical errors on the submissions for 2011. E-rate stakeholders can only hope that the FCC allows USAC to streamline their ability to correct ministerial and clerical errors due the constraints that this “streamline effort” may cause‚Ä¶..