On Dec. 19, 2013, legal counsel representing the E-rate Reform Coalition met with the legal advisor to FCC Chairman Tom Wheeler. The Coalition represents some of the largest school systems in the country. Joining the meeting were John D. Harrington, Funds For Learning CEO, and Dr. Anthony Machado, Director II/E-rate Management for Miami-Dade County Public Schools.
The Coalition encouraged the FCC to 1) adopt per-applicant funding limits, 2) eliminate the current priority system, and 3) increase total E-rate funds to the extent possible. Funds For Learning has submitted to the FCC detailed data supporting the need for each reform, and the Coalition has submitted specific formulas and proposed rule changes to implement the reforms.
The Coalition noted that the adoption of the Funds For Learning proposal offers several important advantages:
- The proposal can be implemented quickly and without the need to make major changes to the E-rate program. The FCC would not need to change the current discount matrix, eligible services list, Form 470, Form 471, or E-rate payment process.
- The proposal is highly adaptable if the FCC does elect to change any components of the program.
- The proposal ensures that every applicant, regardless of size or location, will receive a minimum amount of E-rate funding. Higher discount-rate and remote-rural applicants would receive higher minimum amounts than lower discount-rate and urban applicants.
- The proposal would make funding more predictable by assuring applicants that their E-rate budgets will remain relatively stable from year-to-year.
- The proposal would incentivize applicants to drive harder bargains with service providers, plan their E-rate purchases more carefully, and submit more accurate funding requests.
In a Dec. 20, 2013, Ex Parte Communication, legal counsel for the Coalition outlined discussion from the meeting. The Ex Parte may be viewed in its entirety by clicking here.