None of us know what the full impact of Hurricanes Harvey and Irma will be. But this much is clear: the damage is extensive and it is going to take a lot of time, energy and resources to fix what can be fixed.
In the months ahead, the E-rate program could play a role in helping schools and libraries recover. Here are a few specific recommendations for the FCC and USAC to consider. These would apply to all applicants in regions with a declared state of emergency.
- Implement a blanket 120-day extension for all current deadlines. This would include Form 486s, payment paperwork, PIA responses, audit submissions, etc. If something is due between now and the end of October, it should be given a new due date 120 days later. Importantly, this extension should happen without any involvement from the applicant.
- Waive the Category 2 budget cap for 2018. Applicants in impacted communities should be given the opportunity to apply for Category Two funds without a per student budget cap. There are adequate funds available to cover the demand.
- Waive the 28-day bidding requirement. If an applicant needs to do an emergency procurement, require that they post a Form 470 as they normally would, but allow the contract award date to align with the local requirements (i.e. waive the 28-day waiting period if necessary)
- Allow services to start ASAP. Rather than making applicants wait, allow them to purchase goods and services as soon as their local procurement allows. Schools and libraries should not be required to wait until July 1 of next year to begin installing eligible goods and services.
Although only a small piece in a very big puzzle, I know that the E-rate program could help. I hope the FCC will waive whatever rules necessary to get support to impacted schools and libraries as soon as possible; and, I hope USAC will allow exceptions to its procedures and will make the changes necessary to accommodate the needs of so many applicants.
