Those librarians have some good ideas

The ALA has created a nice sheet about what should be Delete!Delete!Deleted! from the E-Rate program. Let's see if I agree with their suggestions. 

Here's what they'd like to see deleted: 

1. FCC rules on competitive bidding
2. Form 486
3. Annual NSLP checks
4. Application window for C2
5. Inability to make service substitutions

To which I say:

1.  Oh, hell yes! I've been saying for years that the FCC should not be regulating the purchasing decisions of local governments. The arcane rules confuse applicants and conflict with local rules.
2. A solid yes. C'mon, FCC, you already did it for the Cybersecurity Pilot Program: move the CIPA questions to the 471 and scrap the 486.
3. The ALA is suggesting that NSLP percentages get checked once every 5 years, to coincide with the 5-year cycle for Category 2 budgets. I'm all for that. Treat it like the C2 budgets: fixed for 5 years, unless the district wants to change it (if the enrollment and/or NSLP percentage changes to the district's advantage).
4. Why only for C2? We never come close to the program cap these days, so why do we need a filing window? There's plenty of money to go around, and the filing window was created to deal with funding requests exceeding the program cap. Ban the filing window! Want to change your Internet bandwidth in December? No problem, just file a new application. One of your switches starting smoking in January? File an application right then. (Combine this with #1, and you don't even have to wait 28 to make the purchase.)
5. If #4 would come true, there would be no need for service substitutions. Just file a new application. It seems like it would be worse to have to do a 471 for the new service and a Form 500 for the old funding, but it only seems that way if you've never had to do a service substitution; those things are a real PitA. But assuming that we're stuck with the filing window, then yes, applicants should totally be able to increase bandwidth or whatever. Service subs are way too restrictive.

You know what would make service substitutions better? Get rid of FRN line items. Why does the request have to be broken down into a bunch of little buckets? Because whoever made the online form decided to handle things that way; from 5,000 feet up, it looks more efficient. But let me tell you, down here in the trenches, those line items are a major hassle. Just make one big bucket of money, and if you must, list all the equipment or services paid for by that bucket. Then just change the list of items, and don't bother with the size of the bucket of money. Because if the change in items makes the price go up, no prob: E-Rate online funds the original size of the bucket. And if the change makes the price go down, then that gets cleaned up by a Form 500. FRN line items add complexity to the process for no good reason, just because whoever created the online 471 thought they were elegant and cool. They aren't.

Take the win, you fool

Hey, here's a little good news buried in USAC's Federal Universal Service Support Mechanisms Fund Size Projections for Second Quarter 2026. Tucked into page 6, there's a table showing the percentage of improper payments in the USF programs.  For E-Rate, it 1.27%. Huzzah! Why the celebration? Well, in general, it shows how little waste, fraud and abuse there is in the program, which helps the program's prospects for the future.

But it's also good news for applicants this year. Why? Because if that percentage is above 2.5%, that triggers an expansion of auditing in the program. Back in 2008, when I first looked into this number, it was 12.9%. Look at us with a 10-fold decrease! The only other data point I think I've blogged about this was in 2019, when we were at 2.59%. So we've been improving for a while.

I felt like we were getting fewer audits lately; I guess that's real.

I probably shouldn't bring this up (again), but I've pointed out a way they could get that percentage up. See, improper payments should include underpayments. So instead of looking only at payments that were made looking for ones that should have been denied, auditors should also look at payments that were denied, to see if any of the denials were incorrect.  Applicant error is, according to the auditors, a major cause of improper payments. Imagine if they included in their improper payment total every denied funding request or invoice where, if not for applicant error, the applicant would have gotten funded.

Short term, that's a disaster, triggering more audits. But long term, it would provide a strong incentive to make the application process more fool-proof, so we fools wouldn't lose funding that we should get. Imagine if the FCC and USAC got dinged every time an applicant made a mistake that cost them funding. Eventually, the application process would get simpler and simpler. Of course, it's a bit self-destructive for an E-Rate consultant to wish for a simpler process, because no one would need me, but what can I say, I long for a more just world. 

T-LEAPing into the future

Great idea. Now why not make it universal. Over at the Tribal Library E-Rate Advocacy Program (T-LEAP), one of the initiatives they've taken is to accept applications year-round. You heard that right: no filing window for applicants in the T-LEAP program. The increased flexibility has, of course, increased applicant participation. 

Wouldn't it be great to increase applicant participation across the board? So why don't we allow year-round applications for all applicants? The application window was originally created because the E-Rate program always hit its cap, so not all applications could be funded. To keep the application process from turning into a race to apply, the FCC nicely set up a filing window, and said all applications filed in the window would be treated as simultaneous. Well, the program never hits its cap these days. So the filing window is unnecessary. 

The T-LEAP program shows us that we'd get more participation if we had no filing window. Applicants wouldn't be forced to sign illegal contracts. PIA's workload would be more spread out. Changing service mid-year wouldn't be a nightmare. 

As I pointed out 10 years ago, the rules as currently written, in fact, say that applications should be accepted after the close of the filing window if there's still money left. So USAC should be accepting applications year-round already. 

You may say I'm crazy, but I'm not the only one. The American Library Association (ALA) has asked the FCC to allow rolling applications for C2. But why allow year-round applications only for C2? Let C1 apps be year-round, too.

Going one step further, why do we still have C1 and C2? The two Categories (nee Priorities) of funding were only created because the program never had enough money to fund all funding requests. Now that the program has plenty of money to cover all requests....

Cybersecurity Pilot update

I'm listening to the quarterly meeting of the USAC Schools & Libraries Committee of the USAC Board, and I learned some new things about the Cybersecurity Pilot Program (CSPP). 

First, USAC expects to open invoicing by March. Also, they're running an invoicing webinar tomorrow. 

Second, all CSPP applications should get FCDLs by the end of June. For those who didn't know, 172 FCDLs were issued on December 17th. Another wave should be coming out soon. But knowing when the last FCDL will be issued is good news for those of us who have applications languishing in "Certified" status.

GAO: USAC FTW

It's a clean bill of health for the E-Rate! The GAO (Governement Accountability Office) evaluted five programs for their adherence to "nine requirements and leading practices to oversee and prevent fraud, waste, and abuse in awards...." Alone among the five programs, the E-Rate had procedures for all nine.

The GAO has taken a dimmer view of the E-Rate program in 2005, 2009, 2010 and 2017. So it's a nice change to see the program getting a clean bill of health.

A step in the right direction

 Time for the annual table to see if the FCC stuck to their rule of 60 days between the release of the ESL and the opening of the window and if the window length stayed at 70 days, the recent standard.

 As is typical since 2019, the FCC missed the 60-day mark, giving us only 35 days, but the government-wide shutdown gives them a good excuse. 

And they pushed the window back a week to give us more time with the ESL before we have to file. Of course, that makes me happy, since I think the window should close in May. 

FY	ESL release	Window open	60 days?	Window close	Window days
2026	12/17/2025	1/21/2026	35	4/1/2026	70
2025	10/25/2024	1/15/2025	82	3/26/2025	70
2024	12/18/2023	1/17/2024	30	3/27/2024	70
2023	12/14/2022	1/18/2023	35	3/28/2023	69
2022	12/17/2021	1/12/2022	26	3/22/2022	69
2021	11/30/2020	1/15/2021	46	3/25/2021	69
2020	12/9/2019	1/15/2020	37	3/25/2020	70
2019	11/15/2018	1/16/2019	62	3/27/2019	70
2018	10/5/2017	1/11/2018	98	3/22/2018	70
2017	9/12/2016	2/27/2017	168	5/11/2017	73
2016	9/11/2015	2/3/2016	145	4/29/2016	86
2015	10/28/2014	1/14/2015	78	3/26/2015	71
2014	10/22/2013	1/9/2014	79	3/26/2014	76
2013	9/27/2012	12/12/2012	76	3/14/2013	92
2012	9/28/2011	1/9/2012	103	3/20/2012	71
2011	12/6/2010	1/11/2011	36	3/24/2011	72
2010	12/2/2009	12/3/2009	1	2/11/2010	70
2009	11/21/2008	12/2/2008	11	2/12/2009	72
2008	10/19/2007	11/7/2007	19	2/7/2008	92
2007	10/19/2006	11/14/2006	26	2/7/2007	85
2006	11/22/2005	12/6/2005	14	2/16/2006	72
2005	10/14/2004	12/14/2004	61	2/17/2005	65

E-Rate, baby!

The E-Rate got mentioned several times in a Senate hearing at which there seemed to be universal agreement that student screen time should be limited. That can't be good.

Not surprisingly, the first mention came from Sen. Cruz, chair of the subcommittee, who decried that "the Biden FCC sought to bankroll kids unsupervised internet access and undermine parental rights by expanding the E-Rate program to install Wi-Fi hotspots off-campus, including in school buses and students homes" and touted the legislation he created to revoke the eligibility of home hotspots. (20:08)

Senator Cantwell countered that "rather focusing on threatening E-Rate, connectivity for school, I think we should be passing meaningful protections for kids online privacy regardless of whether they're accessing the internet from home orschool." (24:31)

Senator Luhan also came to the defense of the E-Rate, pointing out that Internet access facilitated by the E-Rate must be filtered under CIPA and cannot be unsupervised. He also asked a witness to discuss the harm if the E-Rate ended. (1:48:19)

Finally, Senator Markey talked up the E-Rate, repeating that CIPA rules prevented unsupervised access, and saying that, "The E-Rate hotspots program was a responsible, carefully crafted effort to ensure that low-income students had the same opportunities as their wealthier classmates." (

So not bad, one criticism and three senators in support. Typically, it fell along party lines.

Still, as I look on the horizon for threats to the E-Rate, this one looks like the most threatening currently (though it has a lot of growing to do before it's a realistic threat). In the '90s and '00s, the pendulum swung fully to the "technology good" end of the spectrum, and it's now swinging to "technology bad." Currently, the agreement is "social media bad," with a growing "cell phone bad" sentiment. So far no one's saying "E-Rate bad," but I'm afraid the E-Rate could be the baby thrown out with the social media bathwater. It's already happened to home hotspot and bus WiFi.