CoSN and ISTE File Comments on NPRM

In mid-October, CoSN and International Society for Technology in Education (ISTE) filed comments in response to the FCC’s Notice of Proposed Rulemaking and Further Notice of Proposed Rulemaking (NPRM) that sought input on the administration, management and oversight of the Universal Service Fund and the E-Rate. In their comments, CoSN and ISTE recommended:

1. The Commission should develop and implement new E-Rate performance measures that measure the program’s success based on the availability of adequate connection speed and bandwidth to student and teacher desktop computing devices or the wireless hubs that serve them. The Commission should also disaggregate and publish data about achieving E-Rate goals so that policy makers can measure progress for rural and urban districts as well as for low income and minority populations.
2. The Commission should not transform the E-Rate into a formula-based program, nor should it expand E-Rate support to non-telecommunications related services.
3. The Commission should undertake reasonable efforts to deter waste, fraud and abuse, including imposing stiffer sanctions on applicants and vendors who repeatedly and knowingly violate important program rules.
4. The Commission should undertake efforts to streamline the application process, including allowing multi-year Priority I applications, but also should establish deadlines for USAC’s processing of applicant funding commitments and appeals.
5. The Commission should retain school and library representation on USAC’s Board and formally establish a practitioner panel to guide USAC decision-making.
6. The Commission should require auditors to specifically define audit findings as not including ministerial errors and/or divide audit findings between ministerial errors and intentional fraud.

The comments filed by all other entities may be viewed via the FCC website. To view a PDF copy of CoSN and ISTE's comments, click here. CoSN and ISTE will file reply comments in mid-December.