SECA (the State E-Rate Coordinator's Alliance) has entered the fray over proposed changes to the invoicing process. They filed comments opposing the idea of removing the option of discounted bills and a petition to have the FCC overturn its recent decision to allow AT&T's ARF system.
I agree with what they have to say, but I find it interesting that it is at odds with the invoicing system that the ALA proposed way back when (on page 24 of their NPRM comments). Who is speaking for the libraries on this question? Well, I haven't taken a survey, but I have done some presentations for library directors and library E-Rate staff, and my sense is that most of them like being able to do a single BEAR after the end of the year for telecommunications, but prefer discounts for Internal Connections. What they would definitely not like is the ALA system, where they pay up front and file a BEAR every month.
And SECA is definitely right that the ARF system is not an acceptable replacement for discounted bills. It's more like a simplified BEAR; since it uses the SPI, no certifications are required, so there's no faxing back and forth.
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