SHLB, State E-rate Group Propose Form 470, 471 Changes, With OMB Approval 'Lead Time'
E-rate stakeholders proposed "improvements" to FCC Forms 470 and 471 -- used by schools and libraries to seek competitive bids for projects and apply for funding -- and related Paperwork Reduction Act review requiring Office of Management and Budget approval.…
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The Schools, Health & Libraries Broadband Coalition and State E-rate Coordinator's Alliance said Form 470 "Category 1" (broadband connection) dropdown menu options must be revised to accurately describe internet-access service options. Instructions changed in 2017 "without any PRA review ... caused a great deal of confusion" and "jeopardized applicants' E-rate funding approvals" (see 1804110026), said the groups' filing Thursday in docket 13-184. "Had the FCC not intervened to ... hold applicants harmless because of the poorly worded and/or defined options (see 1805020038) there very well could have been funding denials." New tweaks were made but "do not resolve the underlying confusion and deficiencies," they said. The FCC should modify Forms 470 and 471 and instructions "consistent with our recommendations," publish drafts for comments this fall, and submit the forms to OMB, for approval by Dec. 31, they said, citing the need for "lead time" to develop online systems implementing changes. The new Form 470 could be available online by July 1, 2019 (for funding year 2020), and the new 471 available online by January 2020 (for the FY 2020 application window), they suggested.