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An Internet Service Provider's Guide
to the Universal Service $2.25 Billion Fund
For Schools and Libraries

Robert Cannon
Internet Telecommunications Project
Version 3.9 Updated: January 20, 1998

http://www.cybertelecom.org/
See UPDATES for the latest news.



© Robert Cannon 1997. May be copied freely but may not be reposted to the Word Wide Web (links to this page are welcome). Credit to the Internet Telecommunications Project and URL address of this page must be maintained.


Introduction: What is Universal Service?

Universal service is a noble part of the United States telecommunications tradition. While the historical foundation of universal service has been debated,1 it has become a vision and a goal for our society which has significantly influenced telecommunications policy for decades. But what does "universal service" mean?
Historically, universal service has meant widespread access to voice-grade telephone service, commonly referred to as "plain old telephone service" (POTS). The fundamental objective has been to give all Americans an opportunity to pick up the telephone and, at a reasonable cost, have voice conversation with anyone else in the country or, increasingly, the world.2
The Clinton Administration has long argued that the concept of universal service must be revised. The Administration argued
Increasingly, the ability of U.S. businesses to remain competitive in a global marketplace and to create challenging, high-paying jobs hinges on their proficiency in creating, manipulating, managing, and using information. Similarly, an individual's ability to acquire, develop, and sustain marketable job skills -- and, indeed, to be an informed, productive participant in American society -- will depend on how well he or she can access, analyze, and assimilate information.3

This policy is a matter of fundamental fairness; if information means empowerment, the United States "cannot accept a division of our people among telecommunications 'haves' and 'have-nots'"4

In order to ensure that the U.S. remains competitive in the global marketplace, the Administration has set the goal of connecting all schools and libraries to the Internet by the year 2000.4.5 This expansion of universal service was enacted into law with the Telecommunications Act of 1996.5

    A Brief History of Universal Service

The concept of universal service has been around since the turn of the century. The first true articulation of the concept is attributed to Theodore Vail, President of AT&T.6 The turn of the century was was an age of competition in the phone market, with several companies vying for any one market. One network could call Joe, another network could call Mary, and a third network was necessary to call Jane, but none of these networks could talk to each other. As a result, offices were required, in order to reach everyone, to have five incompatible phones from five incompatible and not connected telephone companies.

It was in this context that Vail came up with his vision of "one system, one policy, universal service." This vision is different from the concept of universal service which we have today. Vail's vision was premised on the idea that the way to get all of the telephones to talk with each other was to get rid of all of the competing telephone networks. In order to achieve this, AT&T was more than glad to step in as the monopoly.7 AT&T realized its dream of becoming the official blessed monopoly by the 1930s.8

The next step in the evolution of universal service was the Communications Act of 1934. The Act, in its preamble, stated that the Federal Communications Commission was created

for the purpose of regulating interstate and foreign commerce in communication by wire and radio so as to make available, so far as possible, to all the people of the United States, a rapid, efficient, Nation-wide, and world-wide wire and radio communication service with adequate facilities at reasonable charges.9
Since this was merely a policy statement in the preamble, not specifically calling for any program or action, it could easily have amounted to nothing more than a happy thought. However this small reference become the authority for the regulatory creation of universal service as we know it today. There was no further legislative mandate for universal service for sixty years.

    How Universal Service Worked

The mechanism of universal service was developed in the environment of the telephone monopoly. One company was mandated with the goal of providing telephone service to all customers in a geographic region. But the cost of providing of telephone service to certain customers far exceeded the cost of providing service to others. Therefore, a series of subsidies were designed whereby the more lucrative parts of the telephone network supported the more expensive parts.10

One such mechanism was geographic averaging. The cost of providing service to everyone in a telephone service area was determined and then the average rate per customer is calculated. Generally, the cost of providing service to the rural customer would be greater than the cost of providing service to urban customers where the customer base is denser and the customers are closer to the physical plant. By charging the average rate, the telephone companies are utilizing an implicit subsidy. The urban customers are subsidizing the rural customers, but the actually subsidy is not calculated. There was no universal service fund and no universal service tax. All costs were simply averaged.

A second way in which telephone service is subsidized is access charges. For example, the lucrative long distance networks pay a metered access charge which goes to support the more expensive local network. This is the access charge from which independent ISPs (enhanced service providers) are exempt.11

    Telecommunications Act of 1996

On February 8, 1996, the world changed. President Clinton signed the most comprehensive reform of the telecommunications legal landscape since 1934. The Telecommunications Act marked a new era of promised deregulation, competition, increased choices for consumers, and reduces costs. It also marked the first true statutory enactment of universal service and broadly expanded its scope to include more telecommunication services and all telecommunication carriers. The new universal service program includes the provision of discounted telecommunications services to schools, libraries and rural health care provides. The Act specifically anticipates that schools and libraries will use the fund to acquire Internet access.

On May 8, 1997, the Federal Communications Commission released its Universal Service Order, implementing the universal service provisions of Telecommunications Act of 1997.12 This Order created the $2.25 billion school and library fund and a $400 million fund for rural health care providers. It also set forth how schools, libraries, and rural health care providers go about applying for the funding and acquiring telecommunication services.

Universal Service for Schools and Libraries

    Who is Eligible?

      States

In order to be eligible to participate in the universal service program, schools and libraries must meet the following requirements. First, the State must have implemented the FCC's universal service fund program.12.5 Most states have either implemented or are in the process of implementing the program. In order to determine the status of your state, contact your state public utility commission.13

      Schools and Libraries

Schools must (1) meet the statutory definition of an elementary or secondary school found in the Elementary and Secondary Education Act of 1965, (2) not operate as a for-profit business, (3) have an endowment under $50 million, and (4) use service for "educational purposes."14 This generally means that all public schools are eligible. Non-public schools that meet these criteria are also eligible.

Libraries must (1) be eligible for assistance from a state library administrative agency under the Library Services and Technology Act (LSTA), and (2) not operate as a for-profit business. Eligible libraries include public elementary or secondary school libraries, academic libraries, research libraries, and private libraries subject to state determination. Libraries must either be associated with an elementary or secondary school, or independent of any institution of higher education. Libraries which are a part of an eligible school will generally participate in the program as a part of that school.15

Schools and libraries can (and are encouraged to) aggregate their demand by forming consortia with both eligible and ineligible entities. By pooling resources and demand, a consortium may be able to formulate more attactive arrangements. However, the benefits received from The Fund must be provided to the eligible entities in accordance with their level of eligibility.
 

Schools Libraries
Must meet the statutory definition of an elementary or secondary school found in the Elementary and Secondary Education Act of 1965 Must be eligible for assistance from a state library administrative agency under the Library Services and Technology Act
Must not operate as a for-profit business Must not operate as a for-profit business
Must not have an endowment exceeding $50 million.
Services must be used for "educational purposes."

      Internet Service Providers

In the past, only telephone carriers had to pay for and only telephone carriers received the financial benefit of universal service. In the new world, "[a]ll telecommunications carriers that provide interstate telecommunications services are required to contribute to universal service support mechanisms."16 As a corollary, generally, only telecommunications carriers are eligible to take out of the fund.

But Internet Service Providers are not telecommunications carriers. From a regulatory history dating back to 1970, the FCC determined that Internet Service Providers are "Enhanced Service Providers." Since they are Enhanced Service Providers and not common carriers, they are not obligated to pay into the universal service fund. This also generally means that they are not eligible to receive support from the Universal Service Fund (see footnote 11).

There is, of course, an exception to the general rule. Section 254(h)(2)(A) of the Telecommunications Act directs the FCC to "enhance, to the extent technically feasible and economically reasonable, access to advanced telecommunications and information services for all public and nonprofit elementary and secondary school classrooms . . . and libraries." The FCC interpreted information services to include Internet access. Section 254(h)(2) also called for the Universal Service program to be competitively neutral; the subsidies should not favor one segment of the industry at the expense of the other. If the School and Library Fund only supported Internet access from telephone carriers, then the telephone carriers would have a significant advantage over independent ISPs in a competitive market. In order to ensure that the universal service fund is competitively neutral, the FCC sought to make all ISPs eligible.

Nevertheless, the FCC could not just decide to pay subsidies to non-telecommunications carriers which do not pay into the Universal Service Fund. In order to get around the general rule that only telecommunications carriers are eligible to receive from the fund, the FCC concluded that "the language of Section 254(h)(2) grants the Commission broad authority to enhance access to advanced telecommunications and information services, constrained only by the concepts of competitive neutrality, technical feasibility, and economical reasonableness."16.5 Unlike the general rule, Section 254(h)(2) does not limit the school and library fund to support of only telecommunications carriers. Since support of independent ISPs enhances access to information services and is competitively neutral, technically feasible, and economically reasonable, then, in the opinion of the FCC, it is permissible under Section 254(h)(2). As a result, all ISPs, whether associated with a telecommunications carrier or not, are eligible to receive support from the universal service fund.17

NEW: Another general rule is that in order for a telecommunications carrier to receive support from the universal service fund, it must be certified. Again, there is an exception. On the federal level, there is no requirement that ISPs or vendors who participate in the School & Library Fund be certified (you should check for any requirements on the state level).17.5

    Discount Matrix

The FCC's Universal Service Order set forth the discounts for which schools and libraries are eligible in its discount matrix table.18 Two factors are used to determine eligibility. First, the universal service program will consider the percentage of students which are eligible to participate in the national school lunch program (for those schools which do not participate in the school lunch program, there is an alternative method of measuring poverty).18.5 Libraries will determine their eligibility based on the level of participation of schools in the national school lunch program in the area where the library is situated. Second, the program will consider whether the school or library is in an urban or rural environment. The Commission decided that "rural" shall be defined in accordance with the Office of Management and Budget's designation of metropolitan and non-metropolitan counties.19 Using these two factors, the discount matrix reveals the discount available for the school or library, which ranges between twenty and ninety percent. According to the discount matrix, every eligible school or library is qualified for at least a twenty percent discount.
 

School & Library Discount Matrix

% Students Eligible for 
National School Lunch Program
Estimated number of 
schools in category
Urban 
Discount %
Rural 
Discount %
<1 3 20 25
1-19 31 40 50
20-34 19 50 60
35-49 15 60 70
50-74 16 80 80
75-100 16 90 90

    What Happens If The Universal Service Fund Runs Out of Money?

The funds from the School & Library Universal Service Program will be distributed on a first-come, first-serve basis. Since there is $2.25 billion in the Fund, the FCC believes that there is little chance that the Fund will be exhausted. On the other hand, there are rumors of states planning to put the Fund to good use, setting up city wide or state wide networks. The FCC has set up the following procedures in the event that the Fund begins to be depleted.

When there is only $250 million dollars left in the Fund (10 percent of the Fund), a system of priorities will be initiated. The Fund Administrator will give notice that the $250 million trigger has been reached. For the next 30 days (or until the end of the year, whichever is shorter), the most disadvantaged schools and libraries will receive priority for funding commitments. If sufficient funds remain, institutions in other brackets will also receive funding commitments. This system of priority will continue until the Fund is exhausted.19.5

When the Fund first goes online, there will be a one-time, 75 day application window.19.7 During this time, all applications will receive the exact same priority. Instead of first-come, first-serve during this window, it will be as if they were filed simultaneously. Since there is this 75-day window, the School & Library Corporation encourages entities not to rush but to take the time necessary to correctly prepare and file applications.

    What is Covered?

The Universal Service Fund can be used by the school or library to acquire any telecommunication service (i.e., telephones, beepers, cellular phones). The FCC created a flexible fund so that schools and libraries can model technology plans according to their unique needs. It also is anticipated that the Internet is one of the services schools and libraries will seek to acquire.

Recognizing that the expense of Internet access involves more than the mere cost of the service, the FCC determined that The Fund could be used to acquire all equipment that "is necessary to transport information all the way to individual classrooms."20 This includes wiring, routers, hubs, network file servers (including the necessary software), installation and maintenance of internal connections, and wireless local area networks (LANs).21 Universal service funds cannot be used for

equipment such as computers (with the exception of network file servers) and other hardware, software (with the exception of the software required for the operation of network file servers), fax machines, modems, teacher training, upgrades to the electrical system, and asbestos removal.22
Also not eligible for discounts are subscriptions for content, "training, non-network software, voice mail or information services in general, electrical connections, and security."23

Funding for the uncovered elements may be obtained from alternative sources such as the Department of Education's Technology Grant Programs24, from corporations who are now eligible for substantial tax benefits for donated computers, or non-profit initiatives such as Net-Day. See For Further Information Equipment for Schools.

Another restriction is that schools and libraries are not permitted to resell the services acquired through universal service funds.
 

Covered Excluded
Wiring 
Routers 
Hubs 
Network File Servers 
Necessary Software 
Installation 
Maintenance 
LANs 
Computers 
Hardware 
Non Network Software 
Fax Machines 
Modems 
Teacher training 
Upgrades to electrical system 
Asbestos Removal 
Security

The Schools and Libraries Corporation has produced a detail list (PDF) of eligible and ineligible network elements. See also Merit.net's compilation of eligible and ineligible elements.

    Application Process

Funding from the Schools and Libraries program starts January 1, 1998.25 Schools, libraries, and service providers should complete the application process as soon as possible.
  • TECHNOLOGY INVENTORY AND PLAN: The first step of the process is for schools and libraries to prepare technology inventories and plans for future need and use. Schools and libraries are required to make a full inventory of all equipment which they already have in their buildings and systems. They must then articulate exactly how new equipment will be used, what purpose it will serve, and who it is intended to benefit. 25.5
  • STATE APPROVAL: When a school, library, or consortium has their plan completed, it must be approved by the appropriate authority in their state. This achieves two goals. First, the state review is intended to ensure that the technology plans are not frivolous and wasteful. Second, it ensures that there is funding committed in the state's budget to cover its share of cost of the technology plan. The review of technology plans will be the responsibility of different entities in different states; the state also has the authority to delegate this responsibility. ISPs should consult the state's public utility commission or department of education to determine who the responsible entity is.
  • SUBMISSION OF APPLICATION TO USF ADMINISTRATOR: Using FCC Form 470, schools and libraries prepare a summary of their telecommunications plans and needs.26 Schools and libraries can submit an FCC Form 470 for their entire technology plan or any part thereof. Schools and libraries can choose to submit one FCC Form 470 for telephone service and another for Internet service, attracting separate bids from different types of providers. Upon completion, FCC Form 470 is submitted to the School and Library Corporation for approval, posting on the School & Library Corporation web page, and competitive bidding.
    • APPROVAL: The Administrator will review the applications for approval. The Administrator's review will consist of an examination of the applications for technical errors only, ensuring that all procedures have been properly followed. The administrator will not be making a subjective determination of the appropriateness of the technology plan.
    • COMPETITIVE BIDDING: Completed applications will be posted to the Administrator's web page for four weeks for the purpose of receiving competitive bids.27 Service providers bidding for plans must submit bids that constitute the "lowest corresponding price" for the service bid on.28
  • SELECTION OF PROPOSALS: At the end of the bidding cycle, the schools or libraries select the most cost effective plan (it need not be the cheapest; it should be the proposal which is the most appropriate for the technology plan).
  • COMMITMENT OF FUNDS: Notice is given to the Fund Administrator by the school or library of the selection of services and the formation of contracts using FCC Form 471. It is the FCC Form 471 which requests the Fund Administrator to commit funds to this particular contract or project. It is also the FCC Form 471 which determines the priority by which schools and libraries will receive funds. See Section Above: What Happens If The Universal Service Fund Runs Out of Money?
    • Pre-existing Contracts: An FCC Form 470 and FCC Form 471 must be submitted for all contracts. For pre-existing contracts, the FCC Form 471 can be submitted simultaneously with the FCC Form 470. For new contracts, the FCC Form 471 cannot be submitted until after the competitive bidding period is closed.
  • INITIATION OF SERVICE: Once approval of the application is received from the Fund Administrator, service can begin.
  • RECEIPT OF FUNDING: When service is initiated, the school or library must give notice to the Fund Administrative to approve reimbursements using FCC Form 486 (FCC Form 486 is not yet available). Schools and libraries pay their share of the telecommunications expense directly to the service provider.29 The service provider in turn must seek reimbursement directly from the Fund Administrator.30 The FCC has indicated that reimbursement should be provided no later than 40 days after request for reimbursement.
  • ANNUAL RENEWAL: Finally, schools and libraries must annually renew their applications with the Fund Administrator.31 The USF operates on the calendar year.

      PRE-EXISTING CONTRACTS

Pre-existing contracts may be covered by the School and Library Fund without going through the competitive bidding process. There are two types of contracts which can be covered with two different scopes of coverage. In both of these situations, the School and Library fund will only cover eligible services and internal network connections which are provided after January 1, 1998.

Contracts signed on or before July 10, 1997 (new date) will be considered an existing contract and therefore exempt from the competitive bidding requirement for the life of the contract.

Contracts signed after July 10, 1997 but before the date on which the Schools and Libraries Corporation website is fully operational and accepting forms 470s will be eligible for support and exempt from the competitive bidding requirement for services provided between January 1 and December 31, 1998. Any services provided after December 31, 1998 will not be covered. In order for these schools and libraries to continue to receive School and Library funding, they will have to submit their technology plans for competitive bidding in 1998.31.5

Rural Health Care Providers

"Public and non-profit rural health care providers are eligible for support for any telecommunications services employing transmission speeds of less than or equal to 1.54 Mbps. 1.54 Mbps is equivalent to a T-1, so, for example, an eligible health care provider could choose a T-1, a quarter T-1, an ISDN line, or a satellite connection at supported rates. The 1996 Act requires that universal service funds be available on a technology neutral and telecommunications provider neutral basis.

"In addition, any public or non-profit health care provider that does not have toll free access to an Internet service provider is eligible for limited support for toll charges to reach the nearest Internet service provider. Universal service support per month will be the lesser of $180 of toll charges or the amount of toll charges incurred for 30 hours of access to an Internet service provider."32

Final Thoughts

This is a new program. Schools and libraries need to be educated about this new opportunity. Internet Service Providers can do a service to their community and create a great deal of business for themselves by promoting this program. Feel free to use this guide, the slides associated with it, or any other information on this site as you educate the educators about getting access to the largest library of information ever created.

The universal service fund means a lot of money changing a lot of hands. Some people are winners and some people consider themselves losers. Not everyone is please with the plan as set forth by the Federal Communications Commission. There is an appeal of the Commission's Universal Service Order pending in Federal Court. One of the complaints in this appeal is that entities which do not pay into The Fund are permitted to take from The Fund. In other words, some telecommunications carriers are not please that independent Internet Service Providers are eligible to receive funds and are challenging this provision. Watch the Federal Communications Commission Universal Service page for further information concerning the outcome of this legal challenge.

Finally, when Schools & Libraries are preparing technology plans and considering where in their buildings access will be provided, they should keep in mind the American Disabilities Act. The technology must be made available to all students. Make sure tech-labs are wheel chair accessible. Consider purchasing equipment which can be utilized by the visually impaired (there are programs which can translate WWW pages into braille).

For Further Information



 

Endnotes

1 See Milton Mueller, "Universal Service" and the New Telecommunications Act: Mythology Made Law (March 1997) http://www.ctr.columbia.edu/vii/u nivsvce/cacm.htm; Department of Commerce, Inquiry on Universal Service and Open Access Issues, 59 F.R. 48112 para. 1 (1994); Fraser, Telecommunications Competition Arrives: Is Universal Service Out of Order, 15 Fall Cal. Reg. L. Rep. 1 (1995).

2 Department of Commerce, Inquiry on Universal Service and Open Access Issues, 59 F.R. 48112 para. 2 (1994).

3 Department of Commerce, Inquiry on Universal Service and Open Access Issues, 59 F.R. 48112 para. 3 (1994).

4 Department of Commerce, Inquiry on Universal Service and Open Access Issues, 59 F.R. 48112 para. 7 (1994).

4.5 Vice President Gore, Speech before the Summit on the Internet: Focus on Children (December 2, 1997).

5 A good online version of the Telecommunications Act of 1996 can be found at the web site of Blumenfeld & Cohen http://www.technologylaw.com/.

6 Department of Commerce, Inquiry on Universal Service and Open Access Issues, 59 F.R. 48112 para. 1 (1994).

7 Milton Mueller, Universal Service" and the new Telecommunications Act: Mythology Made Law (March 1997) http://www.ctr.columbia.edu/vii/un ivsce/cacm.htm; Fraser, Telecommunications Competition Arrives: Is Universal Service Out of Order, 15 Fall Cal. Reg. L. Rep. 1, 1 (1995); Mark Cooper, Universal Service: A Historical Perspective and Policies for the Twenty-First Century (Dec 9, 1996) (posted at Benton Foundation Universal Service Library www.benton.org).

8 Fraser, Telecommunications Competition Arrives: Is Universal Service Out of Order, 15 Fall Cal. Reg. L. Rep. 1, 2-3 (1995).

9 Section 151 of the Communications Act of 1934, 47 U.S.C.A. § 151.

10 Fraser, Telecommunications Competition Arrives: Is Universal Service Out of Order, 15 Fall Cal. Reg. L. Rep. 1 (1995).

11 For a further explanation of the "enhanced service provider" status of ISPs and the exemption from the metered access charge, see What is the "Enhanced Service Provider" Status of Internet Service Providers, Internet Telecommunications Project http://www.cybertelecom.org/.

12.5 See Universal Service Support Public Notice, Docket No. 96-45, DA 97-1892, detailing the procedures that states must follow in order to receive universal service support.

To notify the Commission that a compliant intrastate discount matrix for schools and libraries has been adopted, states must send a one-page letter to [the Universal Service Administration Corporation] stating this fact. A copy of the letter must also be sent to Sheryl Todd and the Office of the Secretary at the FCC. States should include a copy of the adopted intrastate discount matrix. Letters regarding the discount matrix must be received by the Office of the Secretary by December 31, 1997 to be eligible for funding beginning January 1, 1998.
Id.

12 Federal-State Joint Board on Universal Service Report and Order, CC Docket No. 96-45, FCC 97-157 (May 8, 1997) http://www.fcc.gov/ccb/universal _service/fcc97157/ (hereinafter "Order").

13 See the web site of the National Association of Regulatory Utility Commissioners < http://www.erols.com/naruc/stateweb.htm> for a hyperlink list of state public utility commission webpages. See the American Library Association's Web page for further information on the status of states: http://www.ala.org/oitp/stategrid.html. See also American Library Association, Universal Service : What Needs to be Done in the States http://www.ala.org/oitp/1st_step.html (July 17, 1997).

14 Order para. 552.

15 Order para. 558; FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment (July 2, 1997); Merit.net, About Universal Service Fund (July 20, 1997).

16 FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q20 (July 2, 1997).

16.5 Order Para 591.

17 Order para. 587, et seq.

17 E-mail from Irene Flannery, Common Carrier Bureau of the Federal Communications Commission, to Robert Cannon (November 19, 1997).

18 Order para. 498.

18.5 "A school that either does not participate in the national school lunch program or that experiences a problem with undercounting eligible students may use federally approved alternative mechanisms to determine the percentage of their students eligible for the school lunch program. A description of federally approved alternative mechanisms can be found at 34 C.F.R. § 200.28(a)(2)(i)(B) [Code of Federal Regulations]. For example, a school may choose to conduct a survey or use eligibility for a tuition scholarship program to determine the percentage of its students eligible for the national school lunch program for purposes of applying for universal service discounts." Frequen tly Asked Questions on Universal Service and the Snowe-Rockefeller Amendment, DA 97-1374, Q11 (July 2, 1997).

19"Information concerning an entity's urban or rural classification can be found at www.neca.org/funds/msa.htm; instructions for using the MSA list can be found at www.neca.org/funds/curl.htm"

The Order states that rural for schools and libraries shall be "defined in accordance with the definition adopted by the Department of Health and Human Services' Office of Rural Health Policy (ORHP/HHS). ORHP/HHS uses the Office of Management and Budget's (OMB) Metropolitan Statistical Area (MSA) designation of metropolitan and non-metropolitan counties (or county equivalents), adjusted by the most currently available Goldsmith Modification, which identifies rural areas within large metropolitan counties." Order para. 504. See Order para 649 et seq. for a detailed explanation of the definition of "rural". See also Updated Frequently Asked Questions on Universal Service for Rural Health Care Providers, Q2 (Sept. 5, 1997) (stating "Under our rules, a rural area is defined as a non-metropolitan county identified in the OMB Metropolitan Statistical Area list, together with those rural areas in metropolitan counties as identified in the most recent "Goldsmith Modification" of the OMB list. The "Goldsmith Modification" identifies rural pockets within larger urban metropolitan counties.") The FCC is promising to make available on its site a user friendly list of rural counties and area. Order note 1171. No such list was available as of September 10, 1997. See OMB BULLETIN NO. 95-04, Revised Statistical Definitions of Metropolitan Areas (MAs) and Guidance on Uses of MA Definitions (June 30, 1995) (providing guidance on how to acquire information on metropolitan areas); OMB Bulletin No. 95-04 Attachment, METROPOLITAN AREAS 1995 (June 30, 1995).

19.5 FCC's Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q25 (July 2, 1997). According to the FAQ,

during the 30-day period applications from schools and libraries will continue to be accepted and processed, but the administrator will only commit funds to support discount requests from schools and libraries that are in the two most-disadvantaged categories of the discount matrix and that did not receive universal service discounts in the previous or current funding years. To avoid discouraging schools and libraries from applying for discounts on basic telephone service, however, schools and libraries that are in the two most-disadvantaged categories will not forfeit their priority status if they have previously applied only for discounted basic telephone service.
There is some talk that, if the Fund is exhausted, the subsidy levels may be reduced in the next calendar year in order to ensure that all institutions can participate.

19.7 School and Libraries Corporation and Health Care Corporation Adopt Length of Filing Windows, Public Notice DA 97-2349 (November 6, 1997); Federal-State Joint Board on Universal Service, CC Docket 96-45, Third Report and Order, FCC 97-380 (October 14, 1997).

20 Order para. 459.

21 Order paras. 450-60; FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q8 (July 2, 1997).

22 FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q9 (July 2, 1997).

23 NTIA New Universal Service Guide (6-24-97) http://www.ntia.doc.gov/.

24 The Department of Education has a Technology Literacy Challenge Fund and Technology Innovation Challenge Grants. See Department of Education Web Page http://www.ed.gov/Technology/.

25 Order para. 607.

25.5 See School & Library Corporation, Nine Steps You Can Take Now to Prepare for the Schools and Libraries Universal Service Program (November 1997).

26 FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q28 (July 2, 1997); NECA, School, Libraries and Rural Health Care Providers Funds (accessed August 6, 1997). Until the Universal Service Administrator and its web page has been set up, the universal service fund will be temporarily administered by the National Exchange Carriers Association www.neca.org.

27 Order para. 480.

28 According to the Order, the "lowest corresponding price" means

that schools and libraries will be offered competitive, cost-based prices that will match or beat the cost-based prices paid by similarly situated customers for similar services . . . a carrier [must] offer services to eligible schools and libraries at prices no higher than the lowest price it charges to similarly situated non-residential customers for similar services.
Order para. 484. See also Fourth Order on Reconsideration, para. 133.

29 FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q17 (July 2, 1997).

30 Order para. 586. Service providers can receive funds from The Fund in one of two ways. First, the service provider can apply to the Universal Service Fund Administrator for reimbursement. The second method is "offset" and applies only to those service providers which are also telecommunications carriers. Those service provider/carriers owe a certain amount to the universal service fund. The amount which the service providers/carriers owe to the universal service fund can be offset but the amount which the service providers should receive as a result of providing service to schools and libraries.

31 FCC FAQ, Frequently Asked Questions on Universal Service and the Snowe-Rockefeller Amendment Q37 (July 2, 1997).

31.5 Fourth Order on Reconsideration, CC Docket No. 96-45, para. 217 (December 30, 1997).

32FCC Fact Sheet, Informal Questions and Answers on Universal Service Benefits for Rural Health Care Providers (June 3, 1997).



 
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