CoSN to the FCC: Strengthen E-Rate to Help Schools Improve Cybersecurity

New Findings Reveal Growing Cybersecurity Costs and Challenges in Schools
Washington, DC
Tuesday, September 3, 2019
 
CoSN today submitted Reply Comments to the Federal Communications Commission (FCC) urging the agency to expand E-Rate funding to help school districts meet critical cybersecurity needs and take other steps to strengthen the program’s internal connections component. The Reply Comments were submitted in response to the FCC’s request for public feedback about the future of E-Rate Category Two, including possible expansion of the program’s eligible services.
 
With school cyberattacks on the rise, school system technology leaders have consistently cited improving cybersecurity as their No. 1 priority. CoSN’s comments underscore new findings from the organization’s K-12 Cybersecurity Cost Report — Fall 2019. The survey of edtech leaders nationwide identifies specific cybersecurity challenges school systems are facing and the cybersecurity expenses that should be eligible for E-Rate funding.
  
“It’s clear that the cybersecurity challenge is real and prevalent in school systems nationwide. More must be done to address this 21st-century priority. The FCC and U.S. policymakers should take stronger steps to help schools better protect their networks and student data. This includes expanding E-Rate eligible services to include cybersecurity protections,” said Keith Krueger, CEO of CoSN.
 
“The E-Rate program importantly builds networks and provides internet access, but does not provide essential funding to protect and secure those networks. These investment holes put school systems at risk of being unable to fully protect their networks and, subsequently, information on students, teachers and administrators,” said Pete Just, CTO, MSD of Wayne Township (IN).
 
The survey of rural, suburban and urban school systems nationwide found that:
 
Consistent deployment of basic cybersecurity tools in school systems is heavily influenced by the requirements and limitations of the E-Rate program;
School systems encounter significant funding limitations that prevent them from deploying more advanced cybersecurity tools to protect their networks, systems and internet access; and 
School systems face ongoing staffing challenges in implementing, managing and monitoring the cybersecurity of their networks and systems.
 
CoSN proposes the following cybersecurity recommendations to the FCC to improve the E-Rate program:
 
Expand the range of firewall services that can be reimbursed;
Expand funding to cover advanced security services provided by a school system’s Internet Service Provider;
Clarify or update the definition of “basic firewall” to align with technology industry standards;
Make managed security services and/or security operations center services eligible for E-Rate funding; and
Add web content filtering to the list of discounted services and make it a covered expense.
 
CoSN’s Reply Comments also called on the FCC to:
Continue the current Category Two funding model;
Make the installation of Wi-Fi on school buses an eligible E-Rate use while maintaining the program’s support for caching, managed internal broadband services and basic maintenance of internal connections;
Increase the Category Two formula’s per-student amount to at least $250, up from the current $150, and raise the funding floor for small, rural applicants to at least $25,000;
Permit the use of school district-wide budgets; and
Establish a common five-year budget cycle.
 
 
“When the E-Rate program was first created, schools and libraries relied on internet for basic tasks and processes. Today, schools and libraries work with data-sensitive applications that must be protected from cybersecurity vulnerabilities. Expanding the E-Rate eligible services list to include security services further modernizes the E-Rate program to meet the needs of today’s schools and libraries and aligns with the purpose and intent of the E-Rate program’s promise. We want to thank the Wireline Competition Bureau for inviting comment on this issue,” said Michael McKerley, CTO of ENA, co-sponsor of the K-12 Cybersecurity Cost Report — Fall 2019. 
  
“The future of any nation begins in its schools. Unfortunately, the cybersecurity risks that schools face are not going away and the costs of recovering from a compromising event continue to rise. Combatting today's cybersecurity threats requires deep network visibility and multiple points of enforcement throughout the network — something that aging network defenses are simply unable to provide. Juniper Networks supports the expansion of the E-Rate program, as we believe schools should have the tools they require to focus their efforts on education, even as their cybersecurity threat landscape continues to evolve,” Said Gavin Lee, K-12 Practice Leader, Juniper Networks, co-sponsor of the K-12 Cybersecurity Cost Report — Fall 2019.
 
Read CoSN’s full comments to the FCC here. Learn more about CoSN’s cybersecurity leadership at: cosn.org/cybersecurity.