Funds For Learning submitted reply comments to the FCC’s Draft FY2019 Eligible Services List (ESL) and supports the State E-rate Coordinator Alliance (SECA)’s positions on clarifying many aspects of the ESL for both Category One and Category Two services. In terms of Category Two issues and concerns, Funds For Learning believes that “SECA raises an important point about the use of buck or sub-category designations as a determining factor in USAC’s application review and funding commitment decision process.  These types of classifications should never be allowed to create the sorts of systemic hurdles that now plague the funding and payment process.  Applicants should not be penalized and/or forced to appeal any sort of dropdown selections.  These options exist, in theory, to facilitate application review, not to serve as administrative gotchas…”

SECA’s Initial Comments can be viewed here.
Funds For Learning Reply Comments can be viewed here.
 
Additional FY2019 Draft ESL Reply Comments include: