As the Federal Communications Commission weighs potential changes to the E-rate program, consultant Deborah Sovereign shared some of her predictions about its likely course of action at the Texas Computer Education Association Convention & Exposition in San Antonio on Tuesday.
Sovereign, whose firm, Kellogg & Sovereign Consulting, specializes in E-rate programs for schools and libraries, presented “E-Rate Strategies for Maximizing Funding” with Myrna Martinez, director of information services for the Harlandale Independent School District and a client of the firm.
One expected change will be the establishment of a permanent filing window that will stay the same every year, likely from January 15 to March 30, Sovereign said. She also predicted that with the FCC entering the fifth year of its modernization program, districts will get an across-the-board refresh on their five-year budgets, although she emphasized that the FCC hasn’t yet made a decision.
Sovereign and Martinez presented several best practices that can guide districts to E-rate success.
1. Build an E-Rate Team in Your District
“You don’t ever want to do this by yourself,” Martinez said.
She advocated for engaging a consultant, like her district has, in part because E-rate program rules change so frequently.
“If you try to keep up with that, you’re going to miss something,” she said.
In addition to helping a district stay on track with its application process and manage the details for the best outcomes, she said a consultant can also help districts obtain and use their funding in a way that will help to avoid potential audits.
Internal E-rate teams should include district champions (financial leaders such as the CFO, superintendent or board members), a technical lead, the procurement manager and child nutrition professionals, since their departments are involved in determining the district’s eligibility.
Districts should also designate a primary E-rate point of contact, Martinez said.
2. Start the Application Process Early
Martinez said her best piece of advice is to start early. The danger of not doing so is that districts may run out of time to solicit bid proposals, particularly if they don’t receive enough on the first round and have to seek out more.
Ideally, districts will start preparing for the March deadline as early as the previous September or October, Sovereign said.
“It really is critical to stay on time,” she said. “There are a bunch of little ‘gotchas’” that can crop up, particularly in the request for proposal process.
For example, any time an RFP is changed, that resets the 28-day clock to receive bids, she said. If districts aren’t aware of that, or don’t allow enough time, it can create problems.
To make filing easier, Sovereign said, administrators should take the time to carefully read all of the instructions.
“Whatever you do, don’t forget to certify your app, which is the biggest part,” she said.
3. Pay Attention to Competitive Bidding Details
“Language can be critical,” Sovereign said.
She recommends that if districts want any specific requirements to be in their contract at the end of the process, such as a multiyear renewal or a mandatory meeting requirement, they include it in the RFP from the beginning. One of the benefits of the open E-rate process is that leaders can look at other districts’ RFPs for examples and ideas.
It’s also important to ensure that the matrix for scoring bids is the same as the matrix included in the initial RFP, Martinez said.
4. Be Mindful of Contract Provisions
Sovereign recommends a multiyear renewal clause, even if a district doesn’t initially think it will require one, so it doesn’t need to go through an RFP process every time an extension is required.
Administrators also should pay close attention to FCC requirements that govern E-rate contracts — for example, a signed contract is critical, even if the district has already issued an award letter to a specific bidder.
Contracts also should say that they are contingent on E-rate funding and on subsequent governing board approval, Martinez noted. That will mitigate the risk of potentially being on the hook for a termination penalty if circumstances change in the future.
“It’s called a nonappropriations clause and you definitely want it in there,” she said.
5. Think Ahead with Project Implementation
One of the best favors that administrators can do for themselves is to keep detailed documentation, Sovereign said. Auditors may come knocking in five or 10 years, so districts must keep track of their funding and how they use it.
Martinez’s district underwent an audit for Wi-Fi equipment that covered more than 1,000 access points. “The auditors wanted to see every one,” she said.
Fortunately, Martinez was able to quickly document each AP location by placing a red dot on building blueprints, so it was very easy to take auditors through the buildings they wanted to see and point out every AP.
“All the work we had done upfront to say, ‘This is exactly where the equipment is’” paid off, she said.
More common than site visits are Payment Quality Assurance audits, Sovereign said, but if districts aren’t able to produce satisfactory answers, these may trigger an in-person audit.
“They want to find something wrong, because that’s their job,” she said. “Take them very seriously and don’t put them aside.”
She said districts should save all of their documentation for at least 10 years. Each year when the application is finished, administrators should gather their supporting documentation and file it away for easy reference in the future.
Finally, Martinez encouraged attendees to take full advantage of any E-rate funding they can.
“The money is there,” she said. “As the director for a school district, I pretty much owe it to my kids to do this. The process is not as difficult as E-rate once was.”
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