What’s Trending In E-Rate in 2018: Is the 2014 FCC Goal of Simplifying the E-Rate Program Being Met?

Every year Funds for Learning (FFL), one of the most preeminent consultants to applicants in the FCC’s E-Rate Program, issues its informative and highly regarded FFL 2018 E-Rate Trend Report (FLL Report) by collecting data and comments and identifying trends gathered from survey responses from over 1000 applicants. Every E-rate stakeholder should at least take a glance at this from survey responses from over 1000 applicants.

In Goal #3 in the First 2014 FCC E-Rate Modernization Order, adopted on July 11, 2014 (2014 FCC E-rate Modernization Order), the FCC called for the “E-rate application process and other E-rate processes to be fast, simple, and efficient,” yet the FFL Report shows that the use of consultants has increased 11% from 45% to 56% since last year. In addition, only 46% of the E-rate survey respondents indicated that the FCC has met its fast, simple and efficient goal. Further, the FFL Report, also published 324 applicants’ comments, including frustrations and suggestions, which provide valuable insight to all E-rate stakeholders, as well as USAC and the FCC.

The FCC’s Goal #3 also established a target for USAC to issue funding commitments or denials by September 1, 2018 of each funding year. Yet, according to the Report, $2.8 billion of E-rate funding was requested in FY2018 and per Funds for Learning, as of August 17, 2018, approximately $1.07 billion had yet to be committed or denied. It appears that there may be an unfortunate trend developing as a result of the FCC setting only a target on the commitment side of the review process. In order for USAC to try to meet the September 1, 2018 deadline, it appears that it may be reallocating resources to that effort, thereby resulting in a dramatic slowdown of post-commitment processes and reviews that lead to inefficiency, uncertainty, and the type of frustration articulated by the applicants in the FFL Report. Or, maybe USAC is simply in need of additional staffing resources.

The FCC should take Goal #3 one step further and set and publish target dates and deadlines for USAC to process post-commitment forms and appeals, as well as ensure that USAC has sufficient resources to meet these targeted deadlines. E-rate applicants are held to multiple strict deadlines and failure to meet them often result in denials of hundreds of millions of much needed dollars to our nation’s schools and libraries. Lack of targeted deadlines to process post-commitment forms and reviews and lack of consistent and uniform guidelines lead to uncertainty, confusion, duplication of effort, and wasted time and resources. If the FCC were to set targets for USAC to follow across all processes and reviews, and not just funding commitments, then we would surely come one step closer to meeting the objectives of Goal #3.