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Form 470 Essentials

The FCC has wisely called for comments on the Form 470 drop-down menus, and how they can be improved from their current unwieldy and confusing state. The comment period for this public notice runs through October 31, 2019, and I encourage all E-rate stakeholders to take this opportunity to let the FCC know what needs to change on the Form 470.

The problem isn’t just with the form, but also with how the Form 470 is handled throughout the E-rate process. Here are a few ground rules that I believe would help E-rate applicants and bidders alike.

Forms should open opportunities, not restrict them
The bidding process should open opportunities for applicants to achieve their goals, and not limit them. This complements the FCC’s desire to have the form be technology neutral – offering no advantage to a particular technology, but also setting no roadblocks to impede solutions that may not have been apparent when the applicant first asked for bids. If during the bidding process an applicant is presented with a cost-effective way to provide the solution that they need, then they should have the confidence to know that they can move forward with this solution and not have to open a new bidding process.

The Form 470 should be focused on allowing the applicant to identify the issue(s) that they are trying to address (i.e. on-campus wireless connectivity, caching, etc.), and permitting bidders to come up with effective and low-cost solutions to meet applicant needs within the 28-day minimum bid period. Any scenario where this occurs would be a positive case study of the competitive bidding process. The form 470 should foster competition, not limit creativity.

Bidders should be able to ask questions and receive answers
The current application of “cardinal change” requirements stifles competition and unfairly limits both bidders and applicants in the bidding process. With no clear definition of how the “cardinal change” rules will be applied and what would constitute such a change, applicants are discouraged from providing answers and feedback to potential bidders.

The best use of the 28-day minimum bid time frame isn’t to give bidders more time to tweak photos on their bids, but to allow for communication and refinement of bids through open flow of information. Bidders can be handicapped by applicants who are justifiably afraid of providing too much information and risking a funding denial, and applicants are disserved by needing to tip-toe around a mysterious rule.

Selections should not be used as a “gotcha” against applicants
The line items that an applicant selects should not be used to limit their ability to purchase from a bona fide bid proposal – these should be treated as helpful guidelines for prospective bidders, but not as hard and fast restrictions on what can be bid and purchased.

Reason will have to guide here, but it should be clear that when an applicant asks for a switch, they also need to get all the necessary components of a switch, even if the transceivers, power cables, power supplies, patch cables and modules are priced separately. The focus of the Form 470 should be on the issue, “I need LAN switching,” and not on the minutia of the solution.

Forms should provide the best path toward funding
The Form 470 should be a tool that provides solutions for applicants, not a weapon used against applicants. The E-rate process is hard for most applicants, and the bidding process can be particularly tricky, because mistakes or issues cannot be fixed retroactively.

The complexity or simplicity of a form at the beginning of the E-rate process can impact the entire journey to getting a funding commitment. Most applicants are simply trying their best to stay compliant with E-rate rules and get better pricing for their critical connectivity needs. For all of these E-rate coordinators trying to navigate the process, the Form 470 should be a welcome means to funding, not a pitfall.

Technical expertise should be optional
Some E-rate applicants have robust technology staffing, with complex networks that require high levels of expertise, but other applicants are coming from an environment where technology is someone’s 10th responsibility in a long list of different roles. Both kinds of applicant need a bidding process that works for them.

Not every applicant will know how many WAPs they need or what download speed will be enough for the next five years, and that should be okay. Every applicant should still have the opportunity to find the solutions that will meet their needs, even if they aren’t using technical language.

Let the FCC know what you think by submitting your comments about the Form 470 – particularly if you have been caught up in the drop-down web. E-rate applicants are best positioned to let the FCC know how these forms should work, so make the most of this opportunity while the FCC is focused on this important step in the process.
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