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For nearly 30 years, E-Rate has been what one might call the most boring of utility programs — a broadband subsidy that quietly connects America's schools and libraries. Now the FCC is asking whether it should exist at all.

Reg Leichty, founding partner of Foresight Law + Policy and a longtime E-Rate advocate, joined the Tech & Learning podcast to break down the commission's newly opened review of the program. His first message: don't panic. His second: take this seriously.

"Sunsetting," he notes, is the polite framing — the proceeding is an inquiry into whether the investment should be terminated.

Leichty pushes back on the review's central premise, which ties E-Rate to concerns about student screen time. Questions about how much time kids spend online are worth asking, he says, but these fall outside the scope of the program and the FCC's telecommunications mandate — an inappropriate merger of two different streams of work.

The stakes are concrete. E-Rate is a need-based subsidy, scaled to community poverty levels, that supports everything from dark fiber projects to wireless access points. Remove it, and those costs fall on local communities — hitting hardest in low-income districts and expensive-to-connect rural areas such as the Nebraska town where Leichty grew up. He also sees a contradiction in questioning school connectivity at the very moment the administration is championing AI readiness.

Still, Leichty argues periodic review is healthy, and this proceeding is a chance to modernize the program's badly dated cybersecurity provisions using early learnings from the FCC's cybersecurity pilot.

The timeline offers breathing room: a 60-day comment period once the notice hits the Federal Register, 30 more days for replies, and likely no implementation before 2028.

Leichty's advice for district leaders: contact your members of Congress this month to educate them about what E-Rate does in their district, and file comments through the FCC's electronic filing system when the window opens.

Take action: The FCC's comment window opens once the Notice of Proposed Rulemaking is published in the Federal Register, and as Leichty notes, the commission is obligated to review every comment it receives.

- District leaders can file directly through the FCC's Electronic Comment Filing System — reference WC Docket No. 26-133 — using either a written document or the express comment field.

- The full NPRM and commissioner statements are available on the FCC's website.

- For advocacy resources and updates on the proceeding, CoSN has issued a statement on the review and maintains ongoing E-Rate advocacy tools for members.

- And per Leichty's two-part strategy: don't wait for the comment window — contact your House member and senators this month and tell them what E-Rate funds in your district.

Texas City ISD’s E-Rate Fiber Project involved designing and planning the installation of district-owned fiber internet to six campuses from the former La Marque ISD that TCISD annexed in 2016. Instead of leasing fiber-optic connections from external providers, the district will now own and manage the entirety of its own fiber infrastructure.

“We were buying leased fiber from Comcast which gets really expensive,” says Gina Covington, CTO at TCISD. “We owned our own fiber originally so we knew we had the ability. Besides the price tag, not owning our own fiber in those campuses meant we were at their mercy regarding when they wanted to take it down to do maintenance.”

On a normal day, this might seem a matter of a small nuisance to plan around, but the district found out just how disruptive not having control of your access could be.

”We were just starting our official state testing and everything went dark,” Covington says. “We scrambled, ‘What is going on?’ They said, ‘Oh, we planned some maintenance and forgot to let you know. Don’t worry, it will be fixed in a couple of hours.’ We told them, ‘You can’t just do this—we are in state testing!’ They restarted it a few hours later, but by that time, it was too late and we had to cancel testing for the day. That meant having to contact the state and making arrangements for another test time, which was no small thing.”

For the fiber installation project and other efforts, Covington was recently recognized with the Innovative CTO Award at the Tech & Learning Regional Summit in Austin, part of the Innovative Leader Awards.

She shares how utilizing the eRate program allowed her district to take back ownership of its lifeline to connectivity for better reliability and cost savings.

Adding Fiber to The Digital Diet

TCISD’s adopted lease-lit fiber campuses had already been disrupted at times due to unforeseen issues. In one case, a tree being cut in Dallas five hours away along the line shut down the entire area past the incident location.

“We had been trying to figure out a way to get this done,” Covington says. “We also had our original TCISD-owned fiber we wanted moved from overhead to underground, which is an expensive switch. We decided, let's go for an E-Rate project.”

Owning the fiber, controlling the maintenance timing, and being in control of issues that might arise to be able to efficiently address them outside of school hours was more than a matter of convenience, it was a matter of security.

“When we lost connectivity in the past due to outside forces, we suddenly had nothing,” Covington says. “It wasn’t just that we couldn’t go online for classwork, we were dead in the water. Our phones are IP phones. Our HVAC system, our cameras, our phone system, not only internally but for parents needing to get in touch with campus or their children, our badge access points—everything we have runs off our internet.”

An outside vendor’s whim of when to shut down for maintenance wasn’t the only challenge that made the project necessary. TCISD is located on the coastline, with some schools a mere 100 yards from the sea. Having overhead lines moved underground was critical to protect the fiber from hurricane winds, storms, and other environmental factors with potential damage along the Texas Coast.

“We are a heavy tech district,” says Covington. “Every student has a laptop, a Windows device. We have lots of access control, cameras, we have e-sports—you name it, we’ve got it. We are heavy on bandwidth and we need to make sure we have fast speed for everyone from students and teachers to our law enforcement and emergency management departments.”

E-Rate to the Rescue

The FCC's E-Rate program aims to make telecommunications and information services more affordable for eligible schools and libraries with funding from the Universal Service Fund.

“We applied for it and got approved,” says Covington. “Owning the fiber for the six campuses as well as burying our overhead fibers was a $3 million dollar project. We paid about the equivalent of one year of the Comcast fiber rent and USAC through E-Rate covered the rest.”

The E-Rate program provides discounts from 20 to 90 percent, based on determinations of poverty level, rural status, and library designation. The funds are geared specifically toward telecommunications, Internet access, and internal connections.

“Owning the fiber infrastructure will not only improve our access, but eliminate the need for budget allocations for leasing fiber, resulting in long-term cost savings for the district,” Covington says.

The massive endeavor involved collaboration between the district and local government, as well as the Texas DoT and railroad commission, as installation requires digging and affects many entities. Overall, the E-Rate Fiber Project was the perfect strategic initiative aimed at enhancing the district's technological capabilities and ensuring a stable and efficient digital environment for all campuses.

“Owning our own fiber means for consistency, we are always up, always on,” Covington says. “In terms of bandwidth and speed, those campuses we took over didn't have quite the same speed that we had, so this provided some equity to bring them up to the same speed with the ability to expand.”

Reliability = Responsibility

TCISD’s future-minded STEM Experience was designed to support the district's CTE pipeline by integrating coding and STEM activities early to prepare students for advanced technical and vocational training programs. The goal is to have every student learn to code by grade six.

“We start in Pre-K, teaching them how to program with color,” says Covington. “Purple means right, blue means left. They have little cars they can program by color. Then we move up to block coding, and on and on. Our area has a lot of petroleum refineries who are now looking for kids that can code because their machines are running off of coding. We're trying to prepare students to move into those fields.”

The STEM Experience includes robotics, makerspace, coding, and engineering design activities paving the way to future success. Schools have interactive walls and floors, and augmented VR tech in every campus. The district’s buses are equipped with WiFi so athletes can stay connected for studies on long rides to games. When hurricanes and storms hit, they drive those WiFi-enabled buses into neighborhoods without power or internet so students can stay on track.

With so many stakeholders relying on the ability to stay connected, finding a solution through the E-Rate Fiber Program was key for this Texas district to weather any storm.

“This will last for decades, that's the beauty of fiber,” says Covington. “We've set the next generation up for success. None of this would have been possible without my amazing team. These guys work so hard, You just can’t accomplish something of this level without such a cohesive group. We have a common vision. We always want to create a path for our students. That’s our job.”

3 Tips for Districts Considering Infrastructure Improvements

1. Plan far in advance. The partner you choose to do this is going to have to file all kinds of permitting documents with the state, Railroad Commission, DOT, etc. Don't expect it to happen within 12 months.
2. Use the E-Rate program. Other grant programs might work well in your state or region, but whichever way you go, just don't fund it all yourself. The money is out there!
3. Plan it to the granular level. Invite all the stakeholders to the table and really think it through. “It took us about a year of talking about it and mapping it out,” says Covington. “‘What bandwidth do we need? Do we need single mode? Do we need multi-mode? What speed are we looking for? How is this going to impact us?’”

Tools They Use

• Classlink
• Canvas
• MagicSchool
• ParentSquare
• Promethean Interactive Displays
• Sphero robots
• Aruba Central
• Lansweeper
• Lanschool
• Linewize
• Microsoft Intune

The FCC’s Affordable Connectivity Program, which helps low-income families pay for home internet services, will end without Congressional action. The program, known as the ACP, will stop enrolling new applicants on Feb. 7, and funding for all participants will run out by May. This has huge implications for school connectivity and the digital divide as the program aids nearly 23 million households to obtain internet access. 

Despite the dire state of the ACP, John Harrington, chief executive officer of Funds for Learning, says there’s a possibility for better funding for schools going forward. 

“One of the shortcomings of the ACP has been the fact that it still relies on families applying for it,” he says. “It certainly helped reduce or shrink the number of students who are not connected, but there's still a certain percentage of students that when they go home, they're not connected.” 

Instead of funding for ACP, many of the school stakeholders who Harrington speaks with are focused on encouraging the FCC to expand eligibility for E-Rate funding. The E-Rate is an FCC program that makes internet access more affordable for schools and libraries but currently cannot be used to provide wireless hotspots to students to take home. 

Affordable Connectivity Program: A Best-Case Scenario  

The FCC has proposed a rule change to E-Rate that would allow wifi hotspots to be eligible for funding. If enacted, it could be a better means for schools to ensure internet access for students than the existing ACP programs, which require individual households to apply, something that isn’t always feasible for all students' families. Expanding E-Rate eligibility to the home would bypass this. 

“That would be a game changer for schools and libraries because then we would put them in the driver's seat for getting those connections into the hands of students and library patrons,” Harrington says. “They don't have to urge the parents to apply for it. They don't have to try to get community support drummed or run awareness campaigns. They literally can just get the wifi hotspots that they need for the students who need it.” 

He adds, “Another significant advantage of that is that schools can also manage things like filtering cybersecurity for that device that is connected to the student’s networks, so they have a lot more control.” 

The Worst-Case Scenario  

Harrington stresses the best-case scenario described above may not come to pass. Instead, E-Rate funding may not be broadened and ACP might lose funding.

“That's the real nightmare scenario,” Harrington says. “We've got all these devices in the hands of all these students, which is fantastic. We're really seeing how these learning management systems and content systems and all this stuff has really been incorporated to provide personalized learning, all these opportunities, and now we're approaching this cliff.” 

On top of these concerns, ACP funding has many applications beyond its use by students that wouldn’t be covered by E-Rate. “It doesn’t address the overall need for connectivity,” Harrington says. He notes that not every household has a student and people still need internet access for many aspects of modern life from applying for work to telehealth. 

Reasons For Optimism  

E-Rate funding was recently updated to include providing wifi access for schools. “That's a big step forward,” he says, which makes him optimistic the FCC is willing to update E-Rate. In addition, the FCC can change E-Rate without the need for increasingly elusive bipartisan political support, and possibly without allocating more funding. 

“The program has about a billion dollars in available spending that’s not requested each year. So there is money available. And it doesn't require an act of Congress to make those funds available, so that's why I'm pinning my hopes on this solution,” he says. “The FCC is well positioned to help support this need in a way that would better serve the community.” 

• How Schools Use Drones to Deliver Internet to Students
• How School Leaders Can Address the Inequities of the AI Digital Divide

Two major issues are on the minds of E-rate applicants this year, says John Harrington, CEO of Funds For Learning, an E-rate compliance firm. 

First, Funds For Learning’s most recent E-rate Trends Report revealed that many E-rate applicants would like to see E-rate funding expanded to include cybersecurity. Second, The FCC’s has proposed changes to the E-rate competitive bidding process in a manner Harrington and others believe could hinder the administration of the program, which provides discounts of between 20 and 90 percent on broadband access cost for schools and libraries.

E-rate Cybersecurity  

Without proper cybersecurity, school networks are vulnerable to attacks and can be shut down, leading to the loss of learning opportunities. Network breaches can also compromise student data. 

Even so, many of the cybersecurity resources schools need to protect their networks currently are not eligible for E-rate funding. “The mission of the E-rate program has always been to help connect students and library patrons to the internet, and to provide the support for whatever goods and services were necessary to make that happen, and nothing else,” Harrington says. “Just the essential pieces, not just not the software that they use, or any of that, but the essential pieces.” 

However, as time has gone on, Harrington says the regulations around the program have not kept pace with the way technology has evolved. “Now in order to just have a network up and running requires a whole different suite of hardware and software to keep it safe and accessible,” he says. “But the FCC has not kept the E-rate-eligible services list up to date. That is really the frustration point for school leaders today. They are looking at their networks, and it's not optional for them whether or not they provide security – they have to.” 

The argument against expanding E-rate-eligible services is that there may not be enough funding to cover these additional needs. However, Harrington and others say that since E-rate funding is already capped, district leaders should be able to allocate funding as they see fit. “Provide schools the opportunity to prioritize their needs,” he says, adding that many IT directors would choose to spend money to secure their existing network rather than expand it. 

Potential E-rate Competitive Bidding Change 

The FCC has proposed creating a bidding system in which all the E-rate requests would be processed through one centralized document portal managed by the Universal Service Administrative Company. This new system would replace the process by which service providers submit bids directly to applicants for E-Rate-supported equipment and services. 

“There's a great deal of skepticism around that, because there are about 21,000 applicants that participated in the E-rate program last year, and about 45,000 different contracts that are listed on applications,” Harrington says. “Each one of those applicants has a slightly different set of rules and policies, and there are different laws governing different states, different jurisdictions, and there is not a one-size-fits-all set of rules for procurement.” 

If the plan goes forward, he says, “Either the FCC is going to create a one-size-fits-all system that somehow everyone now has to adjust their bidding processes to, or they're going to have to make some incredibly complex system that can somehow accommodate all of the different requirements of these different states and different localities.” 

Although the proposed change will not impact the current E-rate cycle, many school leaders are worried. Officials in California have submitted comments saying that such an application process would violate California state law. 

The proposal was made in response to audits in which some E-rate recipients did not keep proper documentation of their bids. While those instances of non-compliance should be addressed, Harrington doesn’t believe a change this dramatic is warranted. “You don't have to re-engineer the entire system that's worked out really well for 24 years,” he says. 

What District Leaders and Others Can Do to Have The FCC Listen to Their Concerns About E-rate?  

School leaders who want the FCC to expand E-rate funding for cybersecurity and who worry about the change to a centralized bidding system, should make their thoughts known by writing directly to the FCC while public comment is open, Harrington says. 

Additionally, he advises education leaders to reach out to their local congressional representatives who may be unaware of the potential negative impact of the proposed changes. 

“The E-rate program impacts every school district in America,” Harrington says. “They all depend on it. The internet connections that they have all rest on this program. And this action by the FCC could really disrupt that.” 

• Overcoming Digital Deserts: The Birth of Bronx Digital Equity Coalition
• School Cyberattacks: How the FBI Works to Protect School Districts

Applications for E-rate funding for fiscal year 2021 must be submitted by March 25. The FCC program, which provides discounts of between 20 and 90 percent for broadband access for schools and libraries, is considered particularly vital during the pandemic. 

Micah Rigdon, director of client services at Funds For Learning, a company that helps schools navigate the E-rate process, discussed what educators need to know regarding E-Rate applications this year. 

1. How is The Pandemic Impacting the Process? 

The pandemic has made calculating the funding your school qualifies for more difficult. “The E-rate program provides discounts based on the number of students who are eligible for The National School Lunch Program,” Rigdon says. “It's been more difficult for a lot of schools to determine their discount rates this year because they're not getting the same responses as they do in a typical year because every student right now is being offered free or reduced lunches through the USDA.” 

The increased free-launch offerings are due to the pandemic but have had the unintended consequences of complicating funding calculations. As a result, schools that are having difficulty tracking this year’s numbers are permitted to use data gathered during the last school year on their applications. 

2. What Are Other Changes This Year?  

In the past, E-rate funding that went to equipment purchases was capped per school by the amount of students within that school and per library by its square footage. “Now the FCC is allowing applicants to determine that cap based on the total student population for an entire district instead of at each school site,” Rigdon says. This should be a welcome change for educators as it allows for far greater flexibility. 

3. Could E-Rate Help Pay for Students’ Home Internet Access?  

Currently, E-Rate funding can only be used to provide internet access at schools or libraries. With so much need for remote learning, many districts are helping to provide access to students at home so there is a strong push to change this stipulation. “We are seeing some headway that there could be a policy change at the FCC level,” Rigdon says. “President Biden has directed the FCC to consider how they can expand the program in that way. We now have a new acting chairwoman, Jessica Rosenworcel, overseeing the FCC commission and E-rate is one of the projects that she's paid special attention to. So, there is an opportunity for them to take a look at that and see how it can be expanded.” 

4. When Should You Submit Your E-rate Application? 

The submission window for E-rate applications opened January 15, but much as with filing taxes, people tend to file closer to the deadline (March 25), which isn’t ideal. 

“I would encourage everyone who can to get their information together and file their application early,” Rigdon says. “The E-rate program administrator has already started reviewing applications that have been submitted early in the window. So there's a greater opportunity to receive funding decisions, more quickly, if you file early. There's one website that every applicant has to use. So it tends to get bogged down with traffic toward the end of the filing in windows, so you can avoid some of that.” 

5. Why Documentation is Crucial 

“There are many program rules in E-rate that determine whether what you're purchasing is eligible for discounts,” Rigdon says. “It's one thing to follow all of those rules, but it's a whole other thing to be able to prove that you follow those rules.”

For example, there's a 10-year documentation requirement for E-rate, and applicants can be audited at any point in that timeframe, so it's important to be able to show that you completed the requirements and followed the rules. “Being able to prove that you did something the right way seven years later without documentation is very difficult,” says Rigdon. 

Further Reading

• How to Find an Education Grant
• New COVID Stimulus Package Offers Schools More Funding to Innovate

The E-rate program, formally called The universal service Schools and Libraries Program, helps eligible U.S. schools to obtain affordable telecommunications and internet access. This year the need for such access is greater than ever, with the spike in remote learning due to Covid-19. But the requirements and paperwork may be daunting for overworked school administrators. Funds For Learning provides consulting services to guide school administrators in every aspect of e-rate compliance. 

In an effort to understand how E-rate funding can best serve modern needs of applicants and deliver feedback to the Federal Communications Commission (FCC), Funds For Learning has opened its 10th annual survey of E-rate applicants. The survey arrives as Congress assesses the need for additional funds to support remote learning.  

E-rate applicants are invited to submit anonymous responses from now until July 3, 2020. Survey response data inform key policymakers and administrative members in maintaining the value of the E-rate program, and adapting funding to meet stakeholder needs.  

“Keeping individuals connected to the internet has never been more important, as recent events have so poignantly demonstrated,” said John Harrington, CEO at Funds For Learning. “It’s essential that leaders and decision makers in Washington D.C. hear from applicants, and our survey is an opportunity to submit feedback easily and confidentially.”  

Over the course of the survey’s 10-year history, the E-rate program has seen an increase in demand and efficiency. This year, the first wave of funding committed following the close of the 2020 filing window was the highest amount ever awarded to applicants.   

Survey results will be shared in the E-rate Trends Report, which is submitted into the official docket for review by FCC staff, circulated to Congress and the media, and shared with the general public.  

Participation in last year’s survey and report was a record high, with 1,763 applicants from every state and territory completing the survey, representing about eight percent of all school and library E-rate applicants nationwide.  

The 2020 E-rate Applicant Survey can be found here. 

On Monday, December 3, the FCC issued a Report and Order making significant changes to E-rate rules for Category 2* funding applications. The order adopts a long-awaited permanent Category 2 budget system for all applicants, and establishes streamlined rules which will take effect starting in FY2021.

Key takeaways are as follows:

Starting in FY2021…

-All applicant budgets will be reset.

-The program will adopt ‘fixed’ five-year budget cycles.

-Category 2 budgets will be calculated on a school district or library system basis.

-Equipment transfer rules will be eliminated.

-A new budget cycle will begin in subsequent five-year periods (e.g. FY2026) with no rollover of funds from cycle-to-cycle.

-The budget ‘floor’ for smaller sites will be increased to $25,000.

In FY2020…

-Category 2 budgets will be calculated using the same per-site methodology used in FY2015-2019.

-All C2 site budgets will expire at the end of FY2020 and will not carry over to FY2021.

-The eligibility of caching equipment and services, Basic Maintenance of Internal Connections and Managed Internal Broadband Services will be retained.

-All applicants’ site budgets will be increased by 20% (i.e. one-fifth of the maximum FY2020 C2 budget)

Response from Funds For Learning CEO John Harrington: 

“This highly anticipated Order from the FCC gives schools and libraries the assurance they’ve been seeking to proceed with RFPs for Wi-Fi and other Category Two services. By making permanent the enhanced Category Two budget system, the FCC is sending a strong message of support for our nation's students and library patrons. This move creates stability and offers reassurance to schools and libraries that look to the E-rate program for assistance.”

The full Report and Order from the FCC can be found here. Funds For Learning will provide deeper analysis of this news in a webinar on Thursday, Dec. 5. 

An excerpt from COSN’s K12 Cybersecurity cost report, released in September, argues that E-rate funds should not only make the Internet accessible to all students, but also make it safe.

Since the E-Rate program was created as part of the Telecommunications Act of 1996 it has helped ensure that eligible schools and libraries have affordable access to the Internet. The 2014 E-Rate modernization orders (July & December 2014) continued this commitment.

However, network access and Internet connectivity are no longer enough. While E-Rate funds help level the playing field by defraying school system costs for Internet access and network infrastructure, the very nature of the Internet has changed since the program’s inception.

The Internet is now an essential communications and data transmission conduit for education, government, business, and personal activity. In addition, it is also host to a wide range of nefarious hackers, identity thieves, and criminal and nation-state sponsored organizations utilizing networks to steal data, disrupt network activities, and destroy data systems.

The risks to school systems are only increasing as the number of data breaches and cyberattacks increase every year. According to USA Today, billions of people were affected by data breaches and cyberattacks in 2018 — 765 million in the months of April, May and June alone. In addition to data theft, ransomware attacks continue to pose a very real threat to school systems. This was recently demonstrated by the rash of ransomware attacks in Louisiana school systems in July 2019 which caused Louisiana Governor Edwards to declare a state of emergency. Louisiana’s experience is not an isolated incident; in 2018 there were over 204 million ransomware attacks worldwide.

While E-Rate should not be expected to cover all aspects of school cybersecurity, several simple changes to the E-Rate program would have a very profound impact on the ability of school systems to protect and defend their networks and systems from cyberattacks.

1. Expanding the range of firewall services that can be reimbursed through E-Rate would significantly increase perimeter and data transit security for school system networks and Internet access. This would include expanding the definition of covered firewall equipment and services in Category 2 beyond the current basic firewall functionality of ingress/egress traffic management to encompass advanced protections such as intrusion detection/prevention systems (IDS/IPS), advanced threat protection (ATP), anti-virus/anti-malware filtering, SSL encryption, encrypted traffic inspection, data loss prevention(DLP), and spam filtering. These are examples of additional functionality available on next generation firewalls that are not currently funded by E-Rate.

2. Expanding E-Rate to cover advanced security services provided by a school system’s Internet Service Provider, including DDoS mitigation and the same advanced firewall features recommended to be added under Category 1, would both enhance school system cybersecurity and remove the burden of finding staffing to support these systems. Currently, ERate will discount basic ingress/egress firewalls provided by the Internet Service Provider, if that is part of the ISPs basic service package. However, this is limited to the most basic of firewall functionality. Expanding the definition of covered firewall services that an ISP could provide would allow school systems to contract with their ISP for advanced firewall features to protect their networks, and have the ISP be responsible for operating and managing these systems, reducing the burden on school systems to find positions and qualified staff to do this work in house. Many school systems use the same ISP provider, being able to purchase advanced firewall functionality through the ISP could be more cost-effective and leverage economies of scale driving down the price as more school systems purchase additional cybersecurity services. E-Rate does not currently offer discounts for distributed denial of service (DDoS) mitigation services that help school systems maintain connectivity and availability when faced with a DDoS attack. Where school systems have been able to find funding for DDoS mitigation provided by their ISP, this has been an effective method to mitigate the impact of DDoS attacks on teaching and learning and deter future attacks. Those districts have found the rates of attempted DDoS attacks decrease once attackers discover DDoS mitigation has rendered this attack vector ineffective.

3. Clarifying or updating the definition of “basic firewall” to align with technology industry standards would enable school systems to align their cybersecurity defenses with recognized industry standards and provide improved protection of their networks. E-Rate currently funds “basic firewall” services in both Category 1 and Category 2, and “basic” has been interpreted to be limited to ingress/egress traffic management. As noted earlier, this leaves school systems with inadequate firewall defenses. This definition of “basic firewall” no longer aligns with technology industry standards.

A “standard” firewall across the technology industry is typically a next generation firewall (NGFW) or unified threat management (UTM) appliance or service that offers, but is not limited to, the following protections:

■ Advanced threat protection (ATP)
■ Anti-virus & anti-malware protection
■ Data loss prevention (DLP)
■ DDoS mitigation » Intrusion detection/protection (IDS/IPS)
■ SSL inspection
■ Virtual private network (VPN)
■ Web filtering

As new cybersecurity defense technologies become available, the definition of discounted firewall services should expand to encompass current protections.

4. Making managed security services and/or security operations center (SOC) services for the purposes of monitoring and responding to cybersecurity attacks and incursions eligible for E-Rate funding would significantly improve the ability of school systems to monitor and defend their networks. Managed security services and SOCs leverage economies of scale to monitor and respond to security incidents across multiple organizations’ networks. The ability to fund participation in these services through E-Rate would expand school system access to cybersecurity tools and trained resources, removing staffing and technology funding challenges from the cybersecurity equation.

5. Adding web content filtering to the list of discounted services would remove a significant financial burden from school systems. The implementation of web content filtering is required for participation in the E-Rate program but is not a covered expense. The FCC’s 2014 E-rate Modernization Order reiterates, citing to the 2001 Children’s Internet Protection Act Order, the agency’s position that the Children’s Internet Protection Act prohibits the use of Universal Service Fund resources for filtering. We believe Congress’s intent was for that prohibition to apply to other appropriated funding, and not E-rate funds, and we urge the FCC to work with Congress to address this issue.

The E-Rate program has the opportunity to significantly improve the cybersecurity stance of currently funded networks and Internet access. An E-Rate program that does not address the lack of adequate funding for school cybersecurity equipment, services and personnel is putting schools and their communities at risk. The recommendations above do not include expansion of E-Rate funding to include user and end point protection technologies such as anti-virus/anti-malware endpoint protection, multi-factor authentication, mobile device management, and identity and access management. Those technologies are targeted toward end user devices and access, and as such, are less directly correlated to E-Rate’s goal of providing network and Internet connectivity and access to schools. The recommended changes focus on providing responsible and secure network and Internet connectivity and access to schools.

For the full report, go to: tinyurl.com/y5tg7xa2

The Federal Communications Commission recently invited public comment on a proposal to establish an aggregate cap on the federal Universal Service Fund (USF) and to rank-order the four USF programs relative to each other, including the E-rate program. E-rate - and the three other independent USF programs that serve farms, rural clinics, and low income Americans - already have program level budget caps. The new cap proposed could serve as the basis for reallocating resources among the four district USF programs, which could cause recurring funding shortfalls for the E-rate program and disrupt long-term district broadband infrastructure planning. Educators can access CoSN's filing in this proceeding here. 

How can school districts help? 

CoSn recommends that ed tech leaders communicate their concerns about a new aggregate cap, and a related proposal to merge the program-level caps for the E-rate and Rural Health Care programs. 

District leaders can participate in the rule making using the FCC's "Express Comment" system, by completing the following steps:

Comments must be filed no later than: August 26th.

• Click here to visit the FCC's Express Comment webpage.
• Enter the following "Proceeding Number" in the top field and hit return: 06-122
• Provide your contact information in the other fields.
• Use the following talking points, using your own words, to complete the "Brief Comments" field:

• As an education technology leader, I oppose the FCC's proposal to establish and aggregate cap on the Universal Service Fund, including the E-rate program
• My school district depends on the E-rate to help connect students to broadband. The program's existing cap ensures E-rate's fiscal integrity. Creating a new overarching USF cap, along with prioritizing the USF programs, will only serve to pit the E-rate and other USF programs against each other, to the detriment of students and other consumers who are often on the wrong side of the digital divide.
• I strongly encourage the Commission to abandon this USF caps proposal and instead focus on strengthening the E-rate for future generations of students.

Funds For Learning has released findings from its ninth annual E-Rate Trends Report. 

Results reveal that the E-rate program remains critical in establishing broadband connectivity for schools and libraries. Key provisions of the 2014 E-rate Order that expanded federal support for broadband internet connections will expire in 2020. The FCC calls upon stakeholders to present insights to determine how the program will serve schools and libraries in the upcoming decade.

Key 2019 survey findings include: 

• Digital learning continues to explode. 88 percent of applicants expect bandwidth needs of schools and libraries to increase in the next three years.
• New admin creates positive results. 81 percent of applicants are satisfied with E-rate’s management under Radha Sekar, FCC Chairman Pai’s pick to improve customer service.
• Barriers to internet still exist. 82 percent of applicants agree that insufficient internet access to home of students or library patrons is significant issue in their community.
• New policies yield lower prices. 70 percent of applicants agree that E-rate competitive bidding rules are lowering prices for their internet access services.
• Wi-Fi remains mission critical. 88 percent of applicants feel Wi-Fi is extremely important in fulfilling their mission. 79 percent of applicants in FY18 cited the same need, showing a consistent trend in Wi-Fi access for schools and libraries.

Visit https://www.fundsforlearning.com/2019ErateTrends to download the complete 2019 Trends Report.

Need to upgrade current wifi?

Dual connection for load balancing, high availability Internet?

Network infrastructure sufficient to block/withstand intrusion/security risk?

Is insufficient Internet access in the homes of students and library patrons a significant issue?

Should the FCC permit schools to share Internet access off-campus (if there would be no cost to E-Rate)?

https://tinyurl.com/ybmhkfb7

The recent demise of net neutrality could threaten reliable Internet connections by raising prices, slowing downloads, and blocking some content, which could strain district finances and create headaches for teachers who use multimedia resources for teaching and testing. The now-defunct federal net neutrality policy, which ended June 11, barred ISPs from prioritizing web traffic or content. Critics are concerned that deregulation will pave the way for some providers to create “fast lanes” that allow some content to load or stream faster than others or require users to pay extra for some kinds of content. Some advocates have also said that the end of net neutrality could stifle innovation by making it harder for smaller education technology companies to operate and for teachers and students to access their content. Some states, such as New York and Montana, are trying to maintain regulations at the state level through executive orders. Washington state has enacted its own net neutrality legislation that ensures providers treat all traffic and content the same. If they’re concerned about “throttling”—which occurs when content from some sources is delivered intentionally at a slower pace—leaders should specify in their E-Rate applications and contracts with Internet service providers that they require neutral service. Unlike individual consumers, school districts have some leverage to negotiate their terms with Internet service providers. 

https://tinyurl.com/yamz7e75

Funds For Learning has added a suite of new services. My E-rate Guides℠ brings monthly online learning events, a community Q&A forum, an on-demand archive and hourly consulting opportunities to applicants as they navigate the federal E-rate funding program.

Based on a monthly or annual subscription model, My E-rate Guides℠ is a professional service providing E-rate applicants with access to expert information.

• Online learning: Monthly events focused on timely, relevant updates.
• Community Q&A: Forum to connect with and learn from colleagues every month.
• On-demand archive: 24/7 access to past events and resources.
• Hourly consulting: As-needed, fee-based access to Funds For Learning expert consultants.

Funds For Learning clients and E-rate Manager subscribers receive free access to My E-rate Guides℠. For more information, visit http://www.fundsforlearning.com/myguides.

Findings from a survey of more than 1,096 E-Rate applicants by Funds for Learning:

• 23,000 schools and libraries submitted requests for $4.6 billion in E-Rate services.
• More than 50% of applicants wanted to expand bandwidth, with requests for $2.5 billion in E-Rate data and Internet services.
• 55% of applicants want voice services to remain eligible under E-Rate.
• The average school now spends $32,576 on wifi equipment and services.
• 48% said E-Rate’s “self-provisioning” (or build-your-own-network) option lowers bandwidth costs.
• 44% of respondents still don’t like the E-Rate process.

Read more at www.techlearning.com/Feb18

The E-rate Form 471 filing window is now open and school districts have only a few weeks to submit their applications. Compare & Connect K-12 school broadband comparison tool offers district leaders information to help negotiate for better broadband deals.

EducationSuperHighway has made updates to make finding what neighboring and similar school districts are paying for broadband services easier.

• New service provider view: Providers servicing school districts can now evaluate their impact on the classroom connectivity gap and find new business in districts who aren’t meeting goals.
• Improved user experience: Compare & Connect K-12 now has simplified map views
• New functionality to help districts find the most relevant bandwidth upgrade options: Updated maps help school districts display nearby comparable districts that have more bandwidth for the same price or less.
• Direct access to free resources and support: Districts can now access RFP templates, school network tips, webinars and technical assistance directly on the tool.

Jon Bernstein, Founder and President, Bernstein Strategy Group, Marty Creel, Chief Academic Officer/Vice President, Curriculum & Instruction, Discovery Education, and John Harrington, CEO, Funds4Learning What does a Trump presidency mean for the future of E-Rate, ESSA, personalized learning, credentialing, appropriate tweeting, and more? Here are some highlights.

[Listen to Part 1 of the complete podcast focusing on E-Rate here and Part 2 of the conversation focusing on the possible impact of a #TrumpEducation on teaching practices here.]

Where to begin? This seems to be the most widespread question since President-elect Trump’s historic election victory in November. On December 7, the Tech&Learning editors invited a wide assortment of advisors from the worlds of edtech industry, government policy, and school leadership to answer that question within the context of two of the most prevalent issues concerning the future of education—digital access and personalized learning.

JOHN HARRINGTON, CEO, FUNDS FOR LEARNING
I think that, fortunately, E-Rate was not a big discussion point in the election and because it enjoys bipartisan support at the FCC and, I believe, in Congress, I’m not worried about the immediate impact of change. In fact, I think because of the discussions about infrastructure that there may actually be opportunities.

JON BERNSTEIN, PRESIDENT, BERNSTEIN STRATEGY GROUP
E-Rate is not just bipartisan, it’s also a public and private school program. There is no federal education program that actually provides dollars to private schools in the way that E-Rate does and when you look at your incoming education secretary designate, Betsy DeVos, who sent her kids to private school, who attended private school, and who wants to shift more money to voucher programs that will allow kids to attend private school, I think she can look at E-Rate and say this is a program that’s not just a public school program.

DAVID ROSS, CEO, PARTNERSHIP FOR 21ST CENTURY LEARNING
The infrastructure build is fascinating to me because of the interplay between the potential focus of the new administration on vouchers and school choice. I co-founded a charter in northern California; I realize every state is different, but part of the charter application in my state is you have to have a significantly different pedagogical model, instructional model, or outcomes from the public schools in your area in order to be authorized as a charter. Well, a lot of the models that we see across the country are founded on concepts of personalized learning or blending and in order for that charter to even exist it has to have the infrastructure to be able to do that. So if, per se, the Trump administration will support an increased number of charters they commensurately have to support an infrastructure build.

IRENE SPIRO, CHIEF STRATEGY OFFICER, COSN
I think it would be useful to discuss outcomes but also to think in terms of what kind of message on infrastructure is going to resonate with this new administration. It’s not going to be the one we would have had if the election had turned out differently. It is not what we had in the past, so what kind of message are we going to create? We can’t split off. We really have to have a unified message. And that’s why I’m happy that SETDA and SIIA and ISTE and CoSN are all coming together this spring and having a policy summit to carry a uniform message to Congress.

MARTY CREEL, CHIEF ACADEMIC OFFICER / VICE PRESIDENT, CURRICULUM & INSTRUCTION, DISCOVERY EDUCATION
I think what we know most about the incoming secretary of education, if she’s approved, is that she’s a passionate advocate for school choice. So I think we can expect to see a lot of impact in that area. Will that then trickle down into MOOC’s, formative assessments, blended learning, digital curriculum? Will having that increased school choice make a difference? I can see there’s two different schools of thought.

One is that we’ll have very little impact because when you get down to the classroom it doesn’t matter if you’re in a charter school or a private school or a traditional public school. The other school of thought is that parents are going to choose schools based on innovations and that they’re going to look for schools that have more innovative approaches. That change, that expectation for more choice, is going to mean more differentiation. If I’m a school administrator I’m going to differentiate my school from the others and look at innovative technologies, which may be a way that I can really differentiate myself as a school, which then is going to increase the trend.

LISA NIELSEN, THE INNOVATIVE EDUCATOR, DIRECTOR OF DIGITAL ENGAGEMENT & LEARNING, NYC SCHOOLS
Another area I think we’ll see assessment going is collaborating with some corporations and doing microcredentialing and certifications. I think we’ll start to see some industry certifications taking place in our schools as well as the microcredentialing with partners like Future Ready and Digital Promise who are going down those paths. I think we’ll start to see them bubbling up more prominently.

At the New York City Department of Education we did start a program where we’re partners with many companies, both large and small. Common Sense Education is one of our partners, as are Google and Microsoft, but also smaller companies like Brain Pop. There are more than two dozen. Basically what we’re doing is those edtech companies are providing certification programs for our educators and then those educators become the leaders across our city who can turn what they’re learning to their school districts or boroughs and they can also be places where people can go in and see what is happening.