Episode Transcript
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On this week's episode of the K-12 Tech Talk podcast, we break down the proposed rule changes
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to the e-rate program by the Federal Communications Commission. Will schools and services be removed
from eligibility? And what role does screen time play in the e-rate program? Thanks for
listening.
Live from the NTP studios, this is the K-12 Tech Talk podcast. This is episode 268. We're
all back together again. And no, I am not an AI agent. My name is Josh. With me, I'm
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in mid-Missouri. It is hotter than the Dickens today. Just horrible. Chris is down the road.
He's probably sweating like crazy, too.
I did sweat today.
Yeah, it's rough.
Actually, I had a crimp brow. I was crimping a cable and sweat fell off my brow as I crimped
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it.
I got me a car foaming Ryobi pressure washer thing for Father's Day, and we were out washing
the Tesla the other night. I had sweat just pouring off of me while washing the car. It
was so stinking hot.
Mark, how's the weather your way?
He's not home.
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I'm actually near you guys. I'm in Indianapolis right now, and it's hot.
What?
He did not tell us he was going to be so close, Chris. We could have drove and met him.
Well, Mark, look out your window. That would be crazy.
That would have been hilarious. No, I did listen to the first couple of minutes of last
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week's episode because you people were texting me. I was on a cruise ship, and I was able
to ... I got a good chuckle out of that.
Yeah, so you didn't quite tell us what you thought of that one. You okay with that? You
got any hard feelings towards us?
You'll hear from my lawyer. No, it's fine. I should say, wait, I should say I only listened
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for the first five minutes, so unless you knuckleheads did something beyond that ...
Okay, so then, yeah, no, it's fine. It's fine. That's why you're still talking to us.
Shoot.
Got through that one.
All right, I'm going to have to listen.
No, no, no.
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Maybe I'll cue that up while we're recording.
Got to take that episode down.
So while ... I guess it was late last week or the week before, some news broke out of
the FCC at a ... I don't ... Was it a meeting of the FCC commissioners, or was it just an
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interview with Brendan Carr? Mark, do you remember?
You mean the rule changes?
Or the statement where he alluded to that he was going to publish these recommended
or suggested rule changes.
You know what? I don't know when he comments on that one, but I believe it was right when
the proposed rule changes were released.
Yeah, it was, I think, the day before. There was a big article that came out from Reuters
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about it, and then it was just a day or two later that the proposed rule changes to E-rate
were published. And there are a couple in here that I think are going to cause some
heartburn.
There are a couple, Mark and Chris, we've talked about this. There are a couple that
we could get behind, specifically around E-rate consultants. But there are several that are
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a little bit of a concern.
So that's what this episode is going to be about today. Mark doesn't have any news because
it's summer.
It's summer, man. This is the news.
This is the news, and hopefully you're here because of the outrageously click-baity title
of the episode Mark has come up with. We have yet to name this article.
What's it going to be? E-rate, shut down.
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E-rate dies.
Well, OK, I will—
Mark, we need you to come up with the title, but—
The slow death of E-rate is ahead.
No, no, no, no. I think this is a great pivot because I think in the next half hour or so,
I can convince you that the purpose of the rule changes, the proposed rule changes is
not click-baity E-rate going away kind of thing.
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I think that there is a much—that there is some good stuff in here, and I don't think
if you really read between all the lines that the goal of the FCC is to get rid of E-rate.
But certainly there are components in there that allude to that, and—
Yeah, the first item in the rule change.
Well, there's that.
Yeah, I think Brennan Carr—Chris, I think Brennan Carr has gotten to Mark.
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We'll see.
Yeah.
All right.
So I know Chris has at least four sponsors.
27. There's just 27 sponsors. We thought we'd have a lot of E-rate listeners, so we'll run
through the sponsors.
You cut down on the sponsors so we could have more content.
If we're not going to get E-rate funding, we might as well get sponsor funding. Am I right?
You know what I like about CyberNut? They actually do K-12 fishing. So you can check
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out CyberNut.com. They are built for K-12. They're also gamified with micro trainings
for faculty and staff and students that can take less than a minute. But you look at a
CyberNut fishing campaign, and they're designed for what teachers will actually receive, what
students will actually see. It looks like a real fishing email. So if you're into that,
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you want a competitor with no before kind of thing, check out CyberNut.com.
And they have a fancy wrapped truck that they take to conferences.
Fancy.
And a squirrel.
It was at the Kosen conference.
Yep. I just saw it today.
Is that what you saw when you looked out the window of your hotel room?
All right, Mark, lead us through this disastrous slow death of E-rate by a thousand cuts.
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Look, this is challenge accepted. I'm going to see if I can convince you and change your mind.
Nope.
Okay, then. All right. So if you look at this document, it's a very, very large document.
The entire purpose of this one is to throw out some hypotheticals and some questions,
some of them very broad and some of them very specific, and ask the public for comments.
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So we are in the public comment period. This is the time where organizations, individuals
can respond to the questions and provide feedback. We highly encourage you to reach out to
your state consortium, your Kosen team, anybody that you are used to coordinating with
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on legislative items. Please reach out to them if you want to provide your feedback.
The changes that are proposed, or at least the questions that are proposed in this document,
kind of fall into two categories. There's broad brushstroke questions.
And that's where, Josh, you're right. There is this question around,
have we solved E-Rate? Have we accomplished the mission? And these are very, very broad
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categories that we'll talk about. I'm going to ask your opinions on some of these things.
And then there are very, very specific proposed changes, some very specific things around
application periods and deadlines. So let's start at the top. The question of whether or not E-Rate
has actually met its goal of providing broadband to the community, when E-Rate was launched in 1996,
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obviously schools did not have connectivity. Today, over 99% of schools have broadband.
And so the question is, has E-Rate program satisfied this need? And they're citing some
of the statistics around the demand is lower than the cap of the actual program. And so they're
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right out front asking, has Congress's directive in section 254 of the Communications Act been
satisfied? And that is what's caused everybody to be quite concerned, is this entire document
around getting rid of the E-Rate program because we have met the need. So I will pause there,
and Josh and Chris, if you have any thoughts or reactions to that one in general.
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Yeah. So I think it's one of those questions around, and this is going to sound political,
but it's not meant to be political. It's a similar conversation around, well,
we don't need the polio vaccine anymore because polio hasn't been around. Well, okay, but why
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hasn't polio been around? It's because of the vaccine. So I think you can look at this question
from the FCC about E-Rate in the same manner. Have they reached the goal of providing broadband
to schools? Clearly, with the statistics you quoted, Mark, 99%, yes. But if you were to remove
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the functionality of E-Rate for providing discounted internet services to school,
would that number fall back down? I don't know that it would to the dramatic level of what it was
20 years ago, but I think when you look at financial status of districts across the country,
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you are going to put an undue burden back on the district because, let's face it, all of these
discussions around screen time and devices, we are reliant. Internet is a core service for a
school district now, much as food service is a core service for the district. If you yank that
funding out, that's less dollars going to educate a kid in direct classroom materials, whatever,
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that now has to be spent on the internet connection because E-Rate isn't there.
That's the way I look at that question. Yes, it's been met, but it's because it's been so
successful, and if you remove it, will that need rise back up? Yeah. I think this also alludes to
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a general feeling or general kind of policy approach within the government right now is
to push more and more services and decisions down to local municipalities and states,
and part of that could be, hey, look, we've done our part in building the infrastructure. It's up
to you to maintain or sustain it. I think the overwhelming respondents to the question period
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is going to say, look, we need the E-Rate program to sustain this. If that just means that you need
to change the wording of it and the original directive or the overall directive, then so be
it, but I don't think you're going to get a lot of people who say, mission accomplished, you can get
rid of E-Rate. Right, and I think that fear could have been assuaged, or you could have been a
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little bit proactive with saying or adding a caveat saying, if you feel it's been successful
and has accomplished what the original need was or the original intent was, should we expand
the eligible service list to cyber items because we've proven that cyber items are a dramatic need
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now? So it could have been worded a little bit better, I think. Chris? Yeah, my son has been
saying a phrase, and we ask him a question that's going to be something he doesn't like.
If you were to ask him, do you think E-Rate is done, he'd say, heck no. Like, no, it's not done.
Like, when you look at my, I was just pulling up my budget. If you took away my E-Rate funding,
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I would then say, okay, I got to go to my tech fees budget line, where like my firewall services,
I'm taking that money out. I'm still going to have my internet access, yes. But I'm going to
like really stare at my tech fees and try to figure out, like, I need the E-Rate, my district
needs the E-Rate pot of money to offset cost. So completely agree. You could tell me I have to pick
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up my ISP tab, but then let my E-Rate fulfill my firewall services or other pieces of that money
I'm already spending in my district's tech program. Well, and Chris, you and I know a
number of districts that have subscribed to a MIB service like ClearPass, and that is a crazy
expensive service. And if you all of a sudden yank that away and that district is in the middle of a
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contract, that's a heavy burden. We're going to get to MIBs in a second because there is mention
of that as well. But part of the other thought too here, and they referenced the Broadband Equity
and Access and Deployment Program, which was from the 2021, basically the economic recovery
federal funding that went to build broadband or is still going to build broadband. And so part of
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the FCC is just saying, look, there are other federal programs that do this. Should we be
offering multiple federal programs to build broadband? And part of me wants to say, well,
okay, look, if there is another pool of money for districts to build out broadband,
maybe that would save money to your point, Josh, save money for cybersecurity services and allow
E-Rate to go towards a broader category of funding rather than just building the infrastructure.
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Yeah, I could care less. We apply for Category 1 and Category 2. I wouldn't be opposed to
smack those bad boys together and just give me the budget, give me the money.
Agree.
So to that point, yeah, my district, like the 90 whatever percent of others, yes, we have internet
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access established. Kind of like the back in the day when they took away the telephone stuff,
that came with shock. But then you realize that it was going to open up some other opportunities
for E-Rate funding and it didn't hit as bad. Chris, you typically spend all of your E-Rate
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budget, right? Down to the penny. Yeah, see, and we, since I've been at my district, I have yet
to come close to spending my entire budget. But that's not to say I don't refresh my wireless.
We do all of that stuff. It would be curious to see the statistics of districts that are spending
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their entire budget versus not. And to me, that's an argument for opening up the eligible service
list. I should be able to buy other things. We're going to get to that in a second. But first,
the other dominant theme within this document is the dominant conversation right now in the
ed tech world, which is the screen time debate. And so the FCC is bringing the screen time debate
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to E-Rate and asking, hey, is all of this money that we've invested in internet and technology
helping or hurting our children, especially with all the screen time debates going on right now?
I think it's a very valid question to ask. And I'm glad that they're mixing these two things
together, even though that's a very controversial thing. I think for us, this allows us to say,
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this is about opening up access for education. This is not about hurting or harming children. So
I feel very differently about this. But I do think that this will be the time for people to have
the ability to publicly comment to the FCC around technology and show that there's
a different purpose to technology than just putting kids in front of screens.
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Yeah. I don't want to go on a rant, but the whole screen time conversation, I made a
potentially inflammatory comment the last episode that I was in person on about a large chunk of
a screen time problem is due to parents. I think I'm going to make another-
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And you said a whole lot last episode via AI as well about that.
I think another part of that conversation though is if you're going to put a litmus test on screen
time and if they decide, okay, districts have to put a limit on screen time, how are you judging
qualified use or good use versus a kid off task on YouTube and burning through that screen time
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minute watching a game walkthrough rather than using IXL?
So you're going to artificially force the hand of districts to become much more involved in
allowing blocking filter rule. It will become a management nightmare to make sure that that use
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is a qualified or however you want to phrase that meaningful use of those minutes.
Man, that's going to be a pain if it gets there.
Well, so here's my optimistic spin on this. Right now, the federal government has no
forcing mechanisms to impact schools and screen time. There's no law. I don't anticipate Congress
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is going to act very quickly on this one, if at all. I think we've got a lot of things on
our plate right now that the screen time conversation is really just going to be fought
in the social media realm. This e-rate is the government's only forcing mechanism to impact
how schools operate and if you get rid of the e-rate program, which was the first part of our
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conversation, then you have no ability to talk to schools about screen time and to impact that
conversation. So for me, I think injecting the screen time conversation is proof that the FCC
does not intend to get rid of the e-rate program and in fact, they're more around
tying the e-rate program to screen time so that they can start to influence school policy.
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Yeah, but that's like saying, we're going to allow you to use this,
but you've got to jump through 15 more hoops to do it.
I agree. I agree. There's a big difference between jumping through a few more hoops to
get through e-rate than jumping through school boards and voting to get funding because the e-rate
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program is gone. Potentially. Yeah, I don't know. I got three things on that. One, CDWG is a proud
sponsor of the podcast. I'm going to put a couple of links in the podcast description
to their solutions and their services and how they can help with cybersecurity. That's one.
Two, the Toy Story 5 trailer with the screen and the whole screen time debate,
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Disney Pixar on fire for when that movie's coming out with, this is what's just taking
over the nation. I haven't seen this. It's the toys versus the screen, man. It's wonderful.
I think it's going to be an epic movie that's going to try to get kids to go back to playing
toys instead of being on screens. Anyway, third, it is interesting, Mark, to think about when I'm
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clicking through my e-rate funding and I get to the point of I have to click that I am doing SIPA
stuff and I'm checkmarking those boxes that you can make me checkmark that I could be thrown in
the prison if my district, I'm promising that my school district is adhering to particular screen
time restrictions. That's a cool little thought to have that that could be the facilitator
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to get all school districts in line with screen time.
But again, you're making the IT department the bad guy with screen time. All you're doing-
Yeah. Going back to the, have we accomplished internet access?
Like, and you're inserting screen time debate. Back in 94, when I was at the one computer that
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the classroom had, that was the screen. And I had to put in a CD-ROM drive to get to some Oregon
Trail. But the screen was still there. If you start stripping away, you know, small school
district internet access, they're going to pick a crappy internet solution. And then we're just
doing a disservice to kids because everything's cloud-based and they have to play Oregon Trail
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or whatever. Then we're disrupting education to kids, even if we're debating the screen
and what they're doing on it. I want to know what screen monitor tool company is in the pocket of,
like, who's pushing this? Pixar.
Well, vendor influence is a very big topic. And then we're going to see that come up in a few
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more things. I think that there is a very, very strong message of screen time within this one.
The FCC asks, should the commission impose per day limits on the number of hours children and
minors can use E-rate funded networks and services? So we're getting very deep into not just
putting networks into schools, but tying that to usage and restrictions. So this could be a back
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end way for the federal government to impose screen time limitations by way of E-rate.
Now, I am opposed to those kinds of limitations at the federal level. I don't think that's a
federal decision. I think that's a local conversation. But that for me points to this
is your mechanism. If you get rid of it, therefore you have no mechanism. And you're going to hear
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that come up in a few more times. So this is why I go back to the very first question of,
should the E-rate program go away? Have we met our need? Well, if you think yes,
and you get rid of the E-rate program, then the whole screen time conversation is gone.
You have no mechanism. You can't do anything about it.
And SIPA compliance.
And SIPA compliance. And so there are things in here. They are trying to ramp up SIPA compliance
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and apply SIPA filtering and make sure that districts are applying SIPA filtering to all
devices, not just district owned devices, which I got to say, I think most districts are already
doing that. I don't think there's a lot of districts that are fine with kids looking
at inappropriate content on a personal device. I think we all generally agree that inappropriate
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content should not be in a school regardless of who owns a device. But the next big,
broad brushstroke category is around this funding mechanism and the formula.
There's a lot of conversation about the E-rate percentage. Should the National School Lunch
Program still be used as a mechanism to determine levels? And then there's this
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difference between urban and rural districts. And should we adjust that one as well?
There's even a conversation around, should we even remove the districts at the lower end of
the tier because they're just not taking advantage of that one? This is going to be your more
affluent suburban communities who have the lowest E-rate level. Going back to the screen time
conversation, if you want to put in screen time legislation or, excuse me, screen time rules,
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you're not going to remove the wealthy suburban communities from the E-rate program.
They're the ones who are clamoring for screen time legislation the most. And so, again, I think all
these things, when you look at them together, you can't pass all these rules. They all have
to work together. And that's where I'm a little bit more optimistic about some of these rules
that may seem at first glance as horrible and terrifying actually safeguard the program
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in other areas. So, is the discount matrix overhaul going to be changed? Are we going to change
which schools get more money or which schools get less money? What's the balance between urban
and rural districts and suburban schools? I'm not quite sure. Overall, rural schools and urban
schools with low poverty levels tend to be safeguarded the most in this. And FCC does a lot
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of questions and proposed rules do seem to safeguard the most rural and the most urban
low poverty districts the most. So, if you're in that category, if anything, some of these rules
that take funding categories away, put more money into that bucket for you.
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Yeah, I'm less concerned about that. I think the overhaul that they did with funding allocation,
what was it, six years ago, eight years ago, where they went to that per-pupil budget
that was a lifesaver. You finally had equity where you had districts across the country
now able to use, not just request, but able to get funds from Category 2. And that just flat
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never happened before. As long as they don't jack with that too much, I'm not as concerned about a
funding formula change. I agree.
Sign us up. So again, we have three big categories of questions in the documentation or in the
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proposed rules. The first is, have we met the goals, yes or no? The second is, what role does
screen time have in the E-Rate program, if at all? And I will say there's a lot of those questions.
So, I do think that we're going to start to see this conversation ramp up within E-Rate.
And this is where we really need to keep a close eye on that one. And then the other is,
do we need to make changes to the funding mechanism, the funding allocation? Those are
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the three main categories. And I think you can't have all three of those categories together.
It's going to be one or the other. You're either going to safeguard the E-Rate program so that you
can enforce screen time rules, or you're going to get rid of the E-Rate program and then you have
zero ability to do anything about screen time in schools.
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Yeah, but I could see that being the outcome just with the rhetoric that has been,
we want to do away with the Department of Education, we want to push everything local,
it's all states' rights. That, to me, is a very real conversation that has a,
I won't say likely outcome, but it wouldn't be far-fetched to see that happen.
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What, to me, would be interesting would be if they would require at least
screen time monitoring. Not saying you have to have a hard limit, but that you are actively
tracking minutes spent in front of a screen by a student. And oh, by the way,
we're going to make those tools E-Rate eligible. I could get there on that. They're not setting a
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hard limit, but they want you to track it. We do that with a number of things for reporting
purposes. So from that perspective, I could get there. But I don't know if that's where this will
end. Yeah. It is interesting because this is the first time where the FCC or USAC has really
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gotten into the business of telling you how you're going to use the service. Up until now,
it has been, here's the money to provide the service. By the way, you need to make sure that
you're compliant with SIPA. But after that, we're done. They are asking some very detailed questions
around how much time is too much time. They're even getting into Head Start and Early Childhood
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programs. Should we remove Head Start and Early Childhood because that's where the most damage
of screen time can happen. So now we're getting into governing how these services work
and filtering more than just providing the services. And I think that's where I get a
little bit more nervous because Brendan Carr, as the chairman of the FCC, has proven that he does
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want to get more involved in managing and monitoring content. Mark, didn't you say that
there were some proposed changes to consultants? Let's shift into that one too. So this is kind
of part two of this overall is the specific operational changes. This is where they want to
kind of think about how the program could run a little bit differently. And that first category
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that you just mentioned, consultants, that's the biggest one. Consultants, their proposed rule
changes defines consultants a lot more and actually says this is what an E-rate consultant is,
this is who it must be, and here's the requirements for that person. A lot of districts use E-rate
consultants. I think it's one of my biggest recommendations I give the districts is don't
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go into this one alone. But when you read these rules and you start to realize how unregulated
that consultant process is, it does make me think maybe we do need to put a little bit more structure
into this one. And so right off the bat, this is not about, or the FCC is saying we want to
actually collect the individuals who are the E-rate consultants, not just the businesses. And so when
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somebody misbehaves badly or has maybe a connection to a tech or a telecom company,
we need to document who that person is and what their potential violations are so that they can't
just go to another company and continue operating. So that's a big one is the consultant crackdown
on who's advising school districts on these programs.
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Yeah. We had a consultant for a handful of years when I first started,
and then they screwed something up and they didn't want to take any responsibility whatsoever.
There was a threat of us needing to pay back some funding due to a missed deadline on their part,
not on my part, but on the consultant's part. And it turned into a whole big thing. And the
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consultant's like, yeah, sorry about that. Like zero ownership of the issue. They claim
that they had no financial responsibility if we did have to return any of the money. So
I would like to see changes around that consultant relationship and having them put
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skin in the game where they can be held liable financially if they screw up a deadline or piece
of paper or something like that. Yeah. And they reference a case in 2026 in this year where a
consultant pled guilty to receiving kickbacks from service providers. So you have people who
are filling out forms and acting on behalf of the district. And if they have a financial interest in
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this and a personal, this is something that we should be aware of. And so this is per the FCC,
this isn't just theoretical, this is an actual documented case. And this is something that the
GAO, the Government Accountability Office has said, look, we've done a report. We have some
concerns that the E-rate consultants can exert pretty strong influence over a district's decision.
Absolutely they can. Go ahead, Chris. I think it's interesting that consultants is a piece of this
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thing because that means that there's been some misuse, some thought.
And that to me has not really been on my radar or I haven't heard of a lot of stories about
consultant misuse in the E-rate program. So the fact that it's one of the bullet points,
like, hey, we're going to look at this pretty hard. Obviously, they think there's something
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there. It's not like it's just one of those things like, oh, we're going to look at this piece as
well. Yeah, it's interesting. They also have a question here around should consultants,
should we remove the ability for consultants to do a percentage-based fee? And I had not thought
about this one, but if you have somebody who's writing your E-rate applications and they're
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going to get a percentage of whatever money you get, of course, they're going to boost that form,
that application up a little bit more. And so they're saying, you know, are consultants who
are paid by a percentage actually inflating the program and causing districts to get more money
and not acting in the best interest of the district or the FCC? Yeah, and to that point,
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they're not just filing papers and forms. In a number of districts, they are sort of forcing
the hand as to what bids are selected. So to that point, Mark, completely agree.
The other thing, and I had never heard this one before, is the Kalamazoo exception. This comes
back from a case back in 2002. The Kalamazoo public school districts had a pre-existing
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service provider contract before the E-rate program came in. And the FCC came out and said,
you know, we're going to give you this exception that says, look, you already have a contract in
place. We're going to allow you to use that during the bidding process so that you can stay with that
service provider. You already have a contract and you can continue to collect E-rate funding. Well,
districts had actually started to take advantage of that one and sign long-term contracts with
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service providers before the bidding process and then use that exception to then basically get
through the form 70 process without getting any competition. So they want to close that loophole
and ensure that districts are getting fair and competitive bidding in place and not just
taking advantage of this single bid. Yeah, I could get behind that.
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Along those same lines, though, there's a lot of issues around districts that don't have options
and only have one service provider. And so you do see a lot of questions and rules around,
should we really think about how districts are getting bids and how they're getting sole
service contracts? And are there vendors and service providers that are actually taking advantage
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of districts knowing that they don't have options? And so they're starting to look at,
there's a lot of questions around, should we actually calculate rates based on all the historical
data we have of what these services should cost? Should we cap districts and service providers at
a calculated formula fee rather than allowing anybody to just release a bid? You only get one
(33:31):
bidder that comes back, and then that's how much you've got to pay for your service.
I can think back years ago, there was some fiber runs coming through our area,
and they kind of had the schools and libraries come together. They
took us to a restaurant to sit us down to give this proposal. And the proposal was that
we were all going to agree to pay for all the build out. And if we would all chip in and agree,
(33:56):
that's how they could get from one spot to another, because they'd have a whole string of
customers in place. And what you were committing to was like a, I forget what it was, say a 10-year
commitment that everybody was going to agree for this project to take place. So that 10-year
commitment could make sense if you knew that E-rate funding was going to be in your place to
(34:18):
offset some cost. That makes sense to me. So if you start poking at that stuff,
that's where going back to your question of like, are we good now? Well, if I'm the little
bitty rural school in the middle of the woods nowhere that did the whole promise thing,
the commitment thing like I just talked about, I have some issues in not many years away if we pull
(34:42):
that back. Yeah. Yeah. So there's definitely, there's a lot of stuff in here around the rules
and making sure that service providers are not taking advantage of school districts, especially
the school districts in rural countries or rural counties that don't have the same access to
competition. I think the FCC in here really does underscore that competition is good and it works
(35:03):
in the public's favor in terms of driving prices down. And so they're starting to look at those
areas where there's a lack of competition and a lack of options for districts that is driving
the cost up with the E-rate program. One area around that, Josh, you had mentioned this earlier,
is MIBS, Managed Internal Broadband Services. Josh, I mean, do you want to talk a little bit
(35:24):
about what MIBS is and how districts use it? Yeah. So the use case that I know of that I'm
most familiar with is I know a number of districts that contract with MSP for ClearPass. And the
MSP manages their ClearPass installation as a MIBS product, which then qualifies that
(35:48):
ClearPass project as a whole, and that includes a couple servers, the software, licensing, and
support to be E-rate eligible. And this has been going on for, shoot, the better part of five years.
So it's that type of product service. It's kind of a conglomeration of the two items together,
(36:11):
or can be. Yeah. Now, you're getting lower upfront costs and higher annual operating,
but that annual operating cost is E-rate eligible. Well, FCC is saying, well, wait a minute.
We don't know how much that access point costs. We don't know if a district is getting a reasonable
amount or getting charged a reasonable amount for the access point because it's bundled into
services. And so they're starting to look for, should we begin to unbundle these things
(36:36):
and require MIBS contracts to only bill for work provided for the hardware itself,
the labor and configuration, and not the annual services? So I think they're really starting to
take a look at these areas where service providers could take advantage of school districts and
overcharge and therefore overcharge the E-rate program. And I think that does benefit school
(36:59):
districts in general. There are districts though that rely on MIBS. They rely on a lot of different
services that are, I'd say in the crosshairs of some of these rules that you should really take a
very close look at how this is going to impact your district and your costs. Yeah. If you yank
away a district's ClearPass installation as being MIBS eligible, that would hurt big time.
(37:24):
Yeah. Two things. One's a sponsor. Check out meter.com slash k12techtalk. They can do your
E-rate stuff with subscription-based networking. Do your full stack networking. The ClearPass bit
is a great example. Before MIBS was really the hot stuff in E-rate, my district went full on in
(37:46):
on ClearPass. Helps us manage our wireless network. It's like a Swiss army knife of managing your
wireless and all your clients and your Chromebooks and the whole bit. And that wasn't a thing with
E-rate. I couldn't apply for that. So I spent a crap ton of money buying out my licensing,
buying out my server, spending that whole bad boy up. And like a year or two later,
(38:09):
I'm talking to my neighboring schools about how great ClearPass is. And then MIBS solution comes
out with that. Their costs compared to mine, like night and day. And they get a much more
affordable thing. My tech budget hurt that year that I tried to push through to get that thing
(38:29):
going. So again, you just take that away in a couple years from now or in a year whenever this
stuff would impact. That's something that a lot of districts couldn't figure out before MIBS came
along that needed to be figured out. And to your point, Chris, to figure out how to undo it and pay
(38:50):
for it if it does get undone, that's going to take some time and a lot of really difficult
conversations. Yeah. Some of those almost, I think they go away. You can't afford it anymore.
And then the last change, and I think this kind of goes back into the broader category,
is the service provider annual certification. The form 473 is something that the vendors provide.
(39:16):
And basically kind of changing the cap or the deadline or enforcing a deadline.
And all of that is in favor of districts. Sometimes a service provider, if they miss their
deadline and the district is on the bare reimbursement model, the district is the one
that loses out because the service provider did not follow through on what they needed to do. And
(39:36):
so they're more codifying a deadline of June 30th for service providers to fill out that paperwork
and meet that certification requirement. These are things, they may seem small, but if you look
at these things in totality, a lot of this is the FCC trying to protect both public dollars
and school districts. And I do support those kinds of things. There is a broader question though,
(40:00):
that, and I'm going to read the exact wording here, because when you take a look at a lot of
these rules and in conjunction with the screen time conversations, one of the questions they
asked was we seek comment on whether or not, to what extent the expansions and changes in the
scope of eligible services funded by the program and discussed above have been driven or influenced
(40:20):
by vendor interests rather than the educational purpose requirement of the Communications Act.
And so it's very hard. We're seeing a lot of examples where vendors are influencing consultants.
They are influencing the bids. They're taking advantage of sole source or low bid situations,
lower one bid situations. That does hurt the district, that hurts public funds, that takes
(40:44):
money from the e-rate program and puts it into areas where we could probably be spending those
funds on things like cybersecurity. And so, you know, again, there's a lot of things that make
me nervous. There's a lot of things I'm not necessarily in favor of. I'm not in favor of
the FCC saying how we're going to use these services. That's where the screen time stuff
(41:05):
comes in. But I do see if you take a step back and you see that there is a lot of questions and
themes around protecting federal money and protecting school districts. I do feel, I would
say, on a scale of completely opposed and completely in support, I'm leaning a little
(41:25):
bit more towards the support in general. But again, you have to look at each individual rule
rather than, we're not going to vote yes or no to the entire thing. We have to look at each
individual rule and provide specific feedback on that. So that's where I am. I think there's
some good stuff in here. I think there's some bad stuff in here. But if you look at the whole
(41:47):
totality of it, hopefully that will give you an idea that I think the FCC is trying to do right
for school districts in this. I think that USAC and E-Rate, we already did... When was the stupid
Supreme stuff? That was a year ago, right? It was a year ago. About a year ago, yeah.
(42:07):
Like we already did this thing about a year ago where we were like, what about that E-Rate? Is
that good still? Yeah. And it went to Supreme Court and it was decided that it's still good.
Yeah. So not long after, now we're evaluating it again. And it's like we're evaluating this thing.
(42:29):
Well, we're evaluating something that we already know is good. And I would, I don't know. I think
the FCC government, I wish they would look at other things than a school district program that
already went before Supreme Court and was decided good. I think we could poke at some other things
(42:52):
happening here in America. And even going back to Josh's point of how much Josh hates parents,
and Josh thinks that parents are the problems with the screens. Why don't FCC, why don't you
enforce more on like, I don't know, the corporations that are pumping out the stuff in homes
(43:14):
as opposed to picking at schools? What are we going to do? We're just going to polish this
thing up. We're going to do a couple of different rule changes. We're just really poking at,
we already decided E-Rate is good. So we're going to poke at a couple of things to make it
a little bit better. This isn't like a big overhaul. And to me, if you're going to poke at it
(43:37):
and make changes like this, poke at it and make the eligible service list better, bigger, more
encompassing of what we actually need on a yearly... Make my stinking firewall maintenance
subscriptions eligible. Make Sentinel One and CrowdStrike eligible. Those are the changes that
(44:02):
we need to see. We don't need to see a change tying our E-Rate funding to screen time. Give
me a break. But quit picking at the school. I'm saying, why don't we make Apple, why doesn't
FCC make Apple put more restrictions on their phones and their iPads that kids are sitting
(44:25):
with at home? Yeah. Why don't we go after Android phones and... No, Android phones are fine.
Why don't we go after that stuff? Again, school, we're doing pretty good actually. We should be
fourth or fifth or sixth on the list of things that the FCC should be poking at
in regards to screen time. This isn't just student safety. I think this is what's getting
(44:47):
me riled up too. It's not just the word student. This is children. So let's figure out what the
children are doing before after school. Let's assume that the school's doing the best it can
with children's safety during the school day. And let's poke at... If I get to poke at something,
I want to poke at what kids are doing before school and after school on their devices that
(45:09):
are sitting in their homes when they're in vehicles, when they're with their peers outside
of school. Well, does the US government need to take the steps that the Canadian government just
took and made it illegal for anyone under the age of 16 to have a social media account?
Maybe. How do you enforce that? I would rather talk about that than this, I think.
(45:32):
Well, I think, yeah. And this is where there's so much swirling right now. And Brendan Carr
has made it very clear that he is going to get involved in content. He is going to get involved
in what ABC and CBS put on their airwaves. If he wants to get involved in content,
and I'm not advocating that he did. I'm not saying that they should.
(45:56):
Mark, do you feel like me and Josh are attacking you right now?
No, no, no, no, no, no. Mark, you're dumb.
You tell your friend at the FCC.
I'm not saying that he should. I'm very much against the FCC getting involved in content
and governing how schools use the internets. But if he wants to...
Did you just say the internets?
(46:17):
The internets, yes, all of them. But if he wants to, then attacking the program and removing
eligibility from schools and removing services, that goes against it. And so that's where I
actually feel that this is not a document where you have to look at it all in one.
It's almost an either or. And I think we have made it very clear that the E-rate program is
(46:40):
here to stay. I don't think that the FCC is going to get any feedback or very little feedback on
getting rid of the E-rate program and cutting schools out of it. I think that's the safest
part of it. I do think we do need to provide quite a lot of feedback on what the FCC's role is
in screen time and governance. And that's where we're going to see the most activity on this one.
(47:01):
In terms of the specifics and changes in eligible categories, Josh, we've said this before,
I would want to see cybersecurity built into the E-rate program. I want to see these services.
I think they would get a little bit more support on a lot of these parts if they had said,
if we cut back on MIBs, if we cut back on single-source bids and no-bid sources
(47:29):
to save money in the program, that would allow us to add cybersecurity. I think if they came
out with that and said, by the way, if we do all these things, here's how much money we think we
can save, and we can put that into a cybersecurity pool, you'd have a whole bunch of people saying,
actually, I'm on board with that. But when a lot of these rules are just kind of
taking things away from districts, that's all that they're going to focus on.
(47:51):
So I think there's going to be more negativity towards the removal of services or removal of
eligible services. But again, I just want to see that money go towards more things
to safeguard schools. And if they had come out with that in the beginning and said,
we have a goal of protecting the internet services that we're providing to schools and
(48:14):
giving schools more resources for cybersecurity and monitoring for dangerous activities,
I think they would get more public opinion. But we're in for a few months of pretty rocky,
negative, concerning feedback on this. Again.
Marc, has COSIN come out with a statement or an advocacy letter yet?
(48:37):
This is all—I mean, we were talking about this a week after this has come out.
All of the agencies—I'm at a conference here in Indiana, in Indianapolis, and COSIN,
Council of Emergency Schools, everybody is preparing for the next few months, I would say.
But I have not seen any public comments at this point.
(48:57):
Chris, do you want to share?
They did do a quick statement on June 4th that just says—I mean, they're ready. The FCC is
announcing this. E-Rate's been around for 30 years. COSIN encourages policymakers to carefully
distinguish between E-Rate's support and these broader concerns—well, it says,
(49:17):
broader concerns out of technology outside of school for entertainment and non-other
educational purposes. And that they're probably working on something more, right?
They were nicer in their quick statement than we just were. We want FCC to get out of here!
I can't say we weren't nice. These are very real concerns. Trust me, this is not me being mean.
(49:44):
Yeah, I think this is very measured commentary at this point.
I mean, even things like MIBS. I'm like, wait a minute, I'm paying for support and maintenance
out of this, and then the school district down the street has just bundled their services and
support into the E-Rate program. I'm like, wait a minute.
Yeah, go back to the ClearPass thing. I was a little aggravated that I paid a bunch of money
(50:08):
for my ClearPass, and then my buddy down the street's like, oh, I'm just doing a monthly
thing with it. It's cool. Yeah, that was interesting.
Yeah, because you're talking upwards of $100K outlay of cash up front, and then when MIBS is
eligible, you're getting a big old discount. You're breaking it out over a three-year contract.
(50:28):
Again, we spent local money up front to do it. It's not like the next year I'm going to be like,
hey, take your ClearPass back. I'm going to go the MIBS way. I already spent the money.
We already bought the car. Right.
So anyways, next 30 days for comments, 60 days for replies. So this is, again, the next two
months is really where we're going to see quite a lot of attention on this one, and I anticipate
(50:50):
the commission will have more to say in the fall. So again, we're not going to be impacting this
upcoming E-rate cycle whatsoever, but the entire thing is framed as, and I'm going to read their
exact words from the very beginning. We seek comment not only on how to ensure E-rate funded
services are advancing educational outcomes and protecting children online, but also whether the
(51:13):
program should be narrowed or otherwise reoriented to reflect the extent to which its connectivity
objectives have been achieved. And that last sentence is what concerns me. They are focused
on the original objective when it was established of connectivity, period, end of sentence. And if,
(51:37):
again, showing a bias, but if history is any sort of indication,
it would be an effort to remove E-rate as a tool, period. But that's just me.
We will see.
Whatever.
(51:58):
More to come. I'm sure we're going to be talking about this quite a lot. And again, if you want to
get involved, please, I think the best thing to do is reach out to your local COSIN agency, ISTE,
ASCD, all the agencies that we are used to talking about and working with are likely going to be
responding to this one. So whatever you can do to support those agencies would be probably your best
(52:18):
bet. All right, Chris, any 16 other sponsors to close it out? Yes, please. So Midwest Tech Talk
is coming up. We will be at Lake of the Ozarks in Missouri on July 20th and 21st. If you want to come
hang out with the three of us and many others, it's midwesttechtalk.com. But many of our sponsors
(52:38):
that are on the podcast are also there. I want to give them a quick mention. So there's Fortinet.
Fortinet podcast at fortinet.com to reach out for a Fortinet quote or to get specs checked out.
Classlink will be there. Classlink.com. Our friend David Wren at NTP, they can do your SOC.
D Wren at NTP-Inc. Extreme Networks will be there as well as Lightspeed for your content filter.
(53:03):
And then last but not least is SMC Electric. They're more of a Midwest Missouri company.
They've been helping K-12 schools create safer, smarter, and more connected campuses
from video surveillance to access control and AV systems, classroom tech, intercoms,
mass notification, and more. Check out SMC Electric. If you're going to upgrade, do any
(53:25):
upgrades over summer, they would be the company to talk to, to help you stay secure, connected,
and future ready. Thanks for listening. The views and opinions expressed on the K-12 Tech Talk
(53:46):
podcast are the personal opinions of Josh, Chris, and Mark, and do not represent the views or
opinions of our sponsors or other organizations.