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Waiver Request from Form 470 Guidance

On March 16, 2018, the Ohio Information Technology Centers (“Ohio ITCs”) spoke with the FCC about the competitive bidding requirements for Internet access and data services in funding year 2018.  The Ohio ITCs expressed concern “over changes made to the instructions, filing guidelines, and definitions of permitted eligible services for the FCC Form 470…” The Ohio ITCs shared that these changes have caused “extensive confusion among E-rate applicants and service providers alike and could result in costly funding denials for schools and libraries.”
The State E-rate Coordinators Association (SECA) filed a response agreeing with the Ohio ITCs concerns. In its letter, SECA proposed that the FCC “instruct the E-rate administrator to not issue any funding denials where applicants attempted to comply in good faith with the Form 470 posting requirements for Internet service.”
Funds For Learning filed comments agreeing with SECA’s proposal that there be flexibility given for applicants affected by the confusing SLD guidance.   Funds For Learning stated that “regrettably, these are not new complaints; nor should they come as any surprise to the FCC.  For more than a year, there have been comments, appeals and waiver requests submitted to the Commission about problems with the E-rate competitive bidding requirements for data and Internet services.”
Underscoring this need, EducationSuperhighway submitted a statement in support of the waiver stating that “19% of relevant Category 1 applications were misfiled because of this issue” in funding year 2018.
The FCC has not released an official response; however, the FCC did take one step: it did not delay the close of the 2018 E-rate filing window, an idea that the Ohio ITCs had floated in its discussions. SECA, Funds For Learning, EducationSuperhighway, and CSM all submitted comments in support of closing the filing window as planned on March 22, 2018.
Below are links to the FCC filings.
  • Ohio Information Technology Centers (here)
  • State E-rate Coordinators Association (here)
  • Funds For Learning (here)
  • EducationSuperhighway (here)
  • CSM (here)
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