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698 Applicants At-Risk Due to Form Design

On May 6, 2019, Funds For Learning submitted comments to the FCC detailing where applicants incorrectly selected “Internet only – No Transport” as the Category One service on their Form 470 in FY 2019.  From the beginning of the E-rate program, applicants have been required to notify potential vendors of their intent to purchase goods and services. For most of the program’s history, applicants could describe their needs using their own terms and descriptions. However, since the reform of the program, the FCC has required applicants to describe their technology needs using pre-defined “drop-down” menus – and then penalizing applicants who do not pick the correct menu item as defined by the FCC.  Based on a Funds For Learning analysis,  the E-rate dollars associated with these applicants in FY 2019 is $23.7 million and could negatively impact 698 applicants.  
The Funds For Learning FY 2019 Form 470 Drop-Down Comments can be viewed here.
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