Thinking Outside Box 2

So I needed to post a Form 470 this week, and a couple of things occurred to me.

First, why does Item 2 (where you fill in the the Funding Year) appear on the Form 470? The 470 is not necessarily tied to a funding year. For multi-year contracts, a Form 470 will be used for several funding years. And for construction projects, it may be necessary to file a Form 470 two years before the funding year. So why tie the Form 470 to a funding year?

While I was thinking about the Form 470's role in the E-Rate process, I realized that it offers a solution to the problems created by the heinous new SPIN change regulations. OK, maybe the Copan Order left things too wide open: applicants could do a SPIN change any time, to any service provider, without giving a reason. The new rules in the Sixth Report & Order remedy abuse that was apparently going on, but throws the baby out with the bathwater: you can't change without good reason, and if you do change, you have to pick whoever was the #2 bidder on the original 470. That means if a new money-saving opportunity comes along, applicants can't take advantage of it for 6-18 months. How about letting applicants switch any time they want, as long as they post a 470? That would stop the kind of abuse that the FCC was trying to stop, while still giving applicants the flexibility to take advantage of more cost-effective solutions that come up in the middle of the funding year.

It would go like this: someone at the school finds out they could save $100/month by switching long distance providers. Under my proposed scheme, the applicant could post a 470, accept bids for 28 days, and then switch providers.

It doesn't solve the problem entirely, since the district personnel who make the decision to change providers are not always aware that saving money by changing service providers is a violation of E-Rate rules, and the people who know the E-Rate rules often don't find out about the switch until it's too late. But at least my mid-year-470 plan would help out applicants who want to save money and are aware of E-Rate rules.