Transcript We have four discussion topics at this time… 1. FCC NPRM that proposes many major changes to e-rate. 2.

We have four discussion topics at this
time…
1. FCC NPRM that proposes many major
changes to e-rate.
2. Continued commitment on the part of MDE
to pay for district circuits
3. The award of an infrastructure grant to Inline
to build out fiber infrastructure in Mississippi.
4. PQAs – Payment Quality Assurance
1. FCC’s NPRM
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Notice of Proposed Rule Making
Published in the FR June 9th
Initial Comments due July 9th
Reply Comments due July 26th
Announcement expected September 16th
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www.fjallfoss.fcc.gov/ecfs/comment_search/input?z=z71sm
– 02-6 in the proceeding box
– From Date should be 7/1/2010
INTRODUCTION
• In this Notice of Proposed Rulemaking (NPRM), we initiate one in a series
of rulemaking proceedings to implement the National Broadband Plan’s
(NBP) vision of improving and modernizing the universal service programs.
The Joint Statement on Broadband, released with the National Broadband
Plan, identifies comprehensive universal service fund (USF) reform as an
essential goal for the Federal Communications Commission (Commission).
Upgrading the E-rate program (more formally known as the schools and
libraries universal service support mechanism), the second largest
component of USF, represents a significant initiative to meet that goal.
With more than a decade of experience with the current E-rate program
and a national imperative to maximize the utilization of broadband, it is
time to re-examine what is working well and what can be improved in the
current program. This NPRM also seeks comment on several potential
reforms that would cut red tape by eliminating rules that have not
effectively served their intended purpose, while continuing to protect
against waste, fraud, and abuse.
SECA’s Initial Comments :
1. Recommends the abolishment of the current
E‐rate mandated technology planning
requirement for all funding requests – priority
one and priority two.
2. The form 470 should be abolished altogether or
a simplified form 470 should be redesigned for
the use and benefit of all applicants.
3. When codifying the general rule governing the
competitive bidding requirement, specific
examples of inappropriate or appropriate
conduct should not be included.
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4. Electronic filing and access of forms and all
notifications and processes should be
implemented.
5. Supports the recommended simple average
discount calculation for school districts.
6. The current method for the rural/urban
designation should be updated and continued.
7. The form 471 application should be substantially
revised and streamlined to reflect the simplified
average discount approach and to insure that
applicants are not required to provide
unnecessary information.
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8. The funding of wireless services outside of school
through the E‐rate program must be carefully
coordinated with other universal service support
mechanisms.
9. Dark fiber service should be eligible.
10. Eligibility of services to residential areas of schools
should be approved.
11. Web hosting should be eliminated from the list of
eligible services.
12. The framework for evaluating and determining
eligibility of priority two services and equipment
should adopt the OSI model.
13. Various components and services that are currently
eligible for priority two funding should be made
ineligible.
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14. In order to meet the goals of providing more
applicants with internal connections funding and
ensuring a predictable amount of funding for
applicants , SECA recommends a two pronged
approach:
– Utilize a priority two funding “formula;”
– Establish a process of funding “down” the discount levels
until all applicants and discount levels are funded.
15. Basic maintenance of internal connections should be
eliminated from eligibility.
16. Basic phone services should continue to be eligible.
17. Indexing the annual cap to inflation should be
adopted.
18. Equipment disposal should be permitted under
certain conditions but reporting the information to
the Administrator should not be required.
2. Continued commitment on the part
of MDE to pay for district circuits
• Toby Frazier: “Nothing has changed…”.
• Should you panic?
– Yes, if you like the attention
• Should you update your budget?
– Yes, if you want to be prepared for the worst case
scenario
• Should you file a Form 470?
– Yes, if you might change from ITS contract 4000
The award of an infrastructure grant to
Inline to build out fiber infrastructure
in Mississippi.
• Congratulations to Inline
• Derrick will be providing you will details
• Does this affect RFP 4000?
– No, this is no different from any other contract with
any other provider
• Does this affect your local service or long
distance?
– No, as far as I know voice services will not be affected
New Process – Payment Quality
Assurance (PQA)
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The PQA Program starts in August 2010.
PQA assessments are not audits. They are not performed by auditors. They do not
require on-site work by USAC staff. They take significantly less time than audits.
They are meant only to gather information about individual payments and
generate estimates of program-wide rates of improper payments. Audits, on the
other hand, focus on annual payment amounts.
USAC contracts with an outside firm to provide staff to conduct PQA assessments.
USAC exercises program management and oversight responsibility of the PQA
program.
It will take participants varying periods of time to gather the requested
documents, depending on the volume and accessibility of documents requested.
When fewer documents and/or simpler data are requested and beneficiaries have
ready access to the information, gathering the materials should take a matter of
hours. With more documents, more complicated data, and/or more difficulty
getting access to them, beneficiaries will need more time to comply with the
request. High Cost and Low Income beneficiaries have 15 business days to provide
documents, and Rural Health Care and Schools and Libraries beneficiaries have 10
business days.
Now…
• What do you think?