School drain, library flight

Another year, another 3,000 applicants leaving the program.  Funds for Learning has released an analysis of the number of applicants posting Forms 470.  What does it show?  Since 2014, about a third of the non-district schools and libraries that were applying have stopped.  But as I've done before, I'm going to look at the total percentage of entities applying for E-Rate.  I'll use data from NCES, and say there are 13,588 districts and 33,366 private schools in the country.  And I'll use IMLS data to say there are 9,082 libraries in the country.  Based on those numbers and FFL's data, here are the participation rates:

	2014	2017
Districts	97.2%	84.7%
Schools	25.1%	17.1%
Libraries	43.6%	27.9%

That's a pretty quick drop.  Why?  Here are my speculations:

1. Voice phase-out.  Many smaller applicants are at the point where it no longer makes sense to fill out the forms.  Because the only service for which they can get E-Rate funding is their cable modem, which might cost only $960 per year.  At a 40% discount rate, that's $384/year in funding.  Let's take the ridiculously optimistic Burden Hours that the FCC put on the forms, it takes 9.5 hours to do the 4 forms.  That would be $40/hour.  But that doesn't count the time spent learning the rules, which are splattered across the USAC Web site (781 pages last time I counted) and FCC orders (over 500 orders last time I counted).  Sorry, just not worth it.
2. EPC (and that system we had for one year before EPC).  Having to learn a new interface is a big time suck.  Making applicants learn two new interfaces in subsequent years was too much.  I can't say for sure that it drove applicants out of the program, but it certainly got me a bunch of new clients.
3. The Form 498.  We really had trouble convincing some clients to certify that form because: 1) they didn't want to give out banking info, and 2) they very much preferred paper checks to electronic payments.  Another change that jarred people.

How can we get the participation back up? Here are some suggestions off the top of my head:

1. Fix EPC.  Even better, burn it down and start from scratch.  Step 1: set a timeline, letting everyone know at least a year ahead of time when the new system will be out.  Step 2: ask users what they would like to see in a portal.  Step 3: release a beta; we consultants would be happy to kick the tires.
2. Simplify, simplify, simplify.  Get the FCC out of the business of regulating how a school district decides whether to pay $79/month for Internet access to Comcast or FiOS.  Make P2 budgets district-wide. Etc.
3. Dump CIPA.  OK, the FCC can't just give it the heave-ho, but it seems like someone should point out to Congress that CIPA requirements are keeping a lot of libraries and some private schools out of the E-Rate program.
4. Can the filing window.  With voice gone, P2 capped and the cap raised, we haven't come close to hitting the funding cap.  Which means we don't need a filing window.  Allow applicants to make purchasing decisions when they want and file when they want.