Your School Connected: E-Rate Updates for 2019

The filing window for the School and Libraries Universal Service Support Program—more commonly known as E-Rate—is nearly open. E-Rate has been a significant relief on school spending and helped districts stretch their already thin budgets.

Administrative Window

Make certain your organization’s E-Rate Productivity Center (EPC) profile is correct and up to date. The administrative window to update profiles is open until the application filing window opens. Make certain your FCC Registration Number is correct, contact info is up to date, and if any entities under you are active and present. If you’re a school, make certain your student count is from the most recent information available, as that effects the discount rates the school is eligible for.  For libraries, verify the square footage and the main library branch. If you’re independent, choose your library as the main branch.

Discount rates are in Figure 1, per the Universal Service Administrative Co. (USAC).

Figure 1: USAC Discount Matrix

A new FCC Form 470 might not be necessary, as an FCC Form 470 can be good for a few years because the equipment and services requested on it might be on a multi-year contract. However, the corresponding FCC Form 471 needs to be resubmitted each year with reference to the standing Form 470 to continue to receive discounts on those goods and services.

That time is upon us.

Funding Year 2019 (FY2019)

The Federal Communication Commission released the 2019 Eligible Service List (https://docs.fcc.gov/public/attachments/DA-18-1173A1.pdf) which reflects a few changes from previous years. We’ve broken it down further into plain language below.

E-Rate is divided into two categories, appropriately names Category One (C1) and Category Two (C2). We’ll address the changes in each one individually.

Category One (C1) Changes, Clarifications, and Updates

The first category of eligible supported services includes the equipment and services needed to support broadband connectivity to schools and libraries.

Maintenance and Operations

Previously this was referred to as ‘Maintenance and Technical Support’ and it was just a yes/no question. Now, Maintenance and Operations is an item in the C1 services drop down menu (see figure 2).

Voice Communications

Dedicated voice channels on an ISDN circuit are no longer eligible. This follows the 2014 First E-Rate Order that declared it would phase down E-Rate program funding for VoIP services. FY2018 was the last year VoIP was eligible for discounts, and Voice Services will no longer appear on the FY2019 form. USAC shared what the new service drop down menu will look like in their “Preparing for Funding Year 2019” webinar on December 12, 2018:

Figure 2: FY2019 FCC Form 470 C1 Services Drop Down Menu

You’ll notice that while Voice Services is no longer there, Cellular Data Plan/Air Card Service is still available. For more of a breakdown of what each service entails, you can read about them in detail in USAC’s C1 Reference Table (https://www.usac.org/_res/documents/sl/pdf/handouts/FCC-Form-470-C1-Dropdown-Table.pdf).

While Voice Services has been removed from the FCC 470 C1 Services Drop-Down menu, VoIP is still considerably more affordable than landlines (https://business.frontier.com/blog/voip-vs-landline-phones/). Individual landlines can cost up to $120/month, versus individual VoIP lines can run as low as $28/month (although you might be left to your own phone support at that price). If your school or library already has VoIP enabled telephony equipment, Advance2000 offers SIP extensions for significantly less than the national average price listed here.

Choose Bids Wisely

Competitive bidding needs to be an essential consideration in the provider you go with. When schools are audited for managing the approved budget as efficiently as possible, healthy funds shows leadership competency. The E-Rate program recommends maintaining all bid quotes, not just the bid you go with, for 10 years.

A shining example of smart bidding is Rochester Community Schools. They received praise for running a tight ship when an unmodified audit opinion revealed their school district was in “great financial standing” (https://patch.com/michigan/rochester/rochester-school-district-praised-good-financial-standing). The audit from the previous year wasn’t as rosy, and an action plan to spend down in specific areas helped the Rochester, MI district correct course. The district currently receives 75% of their funding directly from the State, however leadership is well aware that number isn’t guaranteed year over year. Director of Financial Services Matthew McDaniel pointed out that “[w]ith a new political environment, we are uncertain as to the resources that will be made available to Michigan schools…If funding were to be cut, we have enough resources to continue operating our organization.” Make certain that any audit performed on your school will result in similar praise for management of funds.

Eligible Category One Network Equipment

Some of the language has been changed to help clarify eligibility of network equipment. Any additional equipment or modulating electronics necessary to make a school or library’s network equipment functional is eligible for E-Rate. The Order specifically reiterates that “all equipment and services …must be competitively bid” (page 2 https://docs.fcc.gov/public/attachments/DA-18-1173A1.pdf).

There is the option for schools and libraries to lease or rent network equipment. Incurred fees for rented equipment are also eligible for E-Rate support (page 2).

Category Two (C2) Changes, Clarifications, and Updates

Possibly the more confusing of the two categories, due to the scope of eligible items, C2 is dedicated to “the internal connections necessary to bring broadband into, and provide it throughout, schools and libraries” (page 10). Like C1, both equipment and services required to make this possible are eligible for E-Rate discounts.

Supporting Software for High-Speed Broadband Distribution

This isn’t new, but it is being clarified, as supporting software was previously thrown into the Miscellaneous section and there was confusion as to whether it was covered or not. If any software is needed to distribute broadband throughout the school and library, that software is eligible for E-Rate discounts.

Important to note: Software upgrades and patches are considered basic maintenance and are not eligible as supporting software. Whichever service provider you go with, make certain their basic maintenance packages include software upgrades and patches.

Eligibility of Category Two Equipment

Same as C1, equipment that makes high-speed broadband service functional is eligible. That includes, but is not limited to, leased or rented equipment. This means that “[f]unctionalities…that can be virtualized in the cloud, and equipment that combines eligible functionalities, like routing and switching, are also eligible” (page 10).

Cloud hosted services and support have been our bread and butter for the past 20 years here at Advance2000. We’ve saved schools, governments, and businesses tens of thousands of dollars a year virtualizing their IT departments. If your school or library is tight on space, concerned about vandalism, or is looking to upgrade equipment without the monstrous costs associated with updating, we can help determine if a cloud solution makes sense for your individual situation (https://www.advance2000.com/).

Basic Maintenance Contracts

E-Rate support is available for yearly basic maintenance services for broadband connectivity. Be certain to take advantage of Basic Maintenance support during the 2019 filing window, because as the Order restates, the Commission only extended broadband basic maintenance eligibility through the FY2019 (page 5, footnote 41).

Per the FY2019 Order, the Basic Maintenance eligible for discount under E-Rate is here in Figure 3:

Figure 3: FY2019 Order Eligible Basic Maintenance

Advance2000’s support plans include and hold to these restrictions to maintain our E-Rate partner standing.

Specific Eligible Category Two Equipment

Once again, the FCC has declined to provide a list of specific equipment and services eligible under C2 subcategories.

This isn’t a bad thing, as publishing a list could leave certain eligible services and equipment unnamed. If something isn’t listed, they’re concerned that an eligible product or service might be left off Form 470 or 471, which would put a school or library at a financial disadvantage. USAC prefers that requesting parties leave nothing off and they will approve Forms on a case-by-case basis so each district receives the support it needs.

E-Rate and Advance2000

Advance2000 has been a qualified E-Rate service provider for over a decade. We’ve bid and won dozens of FCC Form 470s and Requests for Proposals and our partners have been very happy with the results we’ve provided (https://www.advance2000.com/industries/education/). In collaboration with school IT departments, we’ve offered our expertise to our partners on an as-needed basis while they sought discounts for services via the Form 471.

Your Funding Year 2019 Partner

A seasoned partner will deliver and install the correct firewalls, supporting software, and provide basic support online and by phone for a smooth 2019.

As we’re experts in the IT service industry, have years of E-Rate experience under our belt, and have worked with enough schools to thoroughly understand the budget constraints districts encounter, you can feel confident in the solution we’ll deliver.

For more information about our role in E-Rate and how we can help your school and library get connected for a discount, contact us at 1-800-238-2621.