Justification for non-substantive change request

Federal Communications Commission

Explanation of Non-Substantive Changes to OMB Control Number: 3060-0806:

• FCC Form 471

Purpose of this Submission: This submission is being made for proposed non-substantive changes to an existing information collection pursuant to 44 U.S.C. § 3507. This submission seeks to make non-substantive changes to certain fields, instructions, and the filing process for the FCC Form 471 to implement the changes adopted by the Commission in the Category Two Report and Order, FCC 19-117. This submission also seeks to make non-substantive changes to the instructions and process by which applicants fill out the FCC Form 471 to improve the user experience and reduce the administrative burden. There are no proposed changes for the FCC Form 470. The FCC Form 471 is contained in an online database.

Background: In December 2019, the Commission adopted the Category Two Report and Order, which modified E-Rate program rules to, among other things: (1) make permanent the category two budget approach, which provides applicants with a set amount of category two funding for a five-year period; (2) allow applicants to apply for category two funding on a school district-wide or library system-wide basis, rather than an entity-level basis; and (3) decrease the administrative burden on applicants requesting funding for category two services. We seek to modify the FCC Form 471 to implement these changes for funding year 2021, as set forth in the Category Two Report and Order.

Summary of Proposed Updates to the FCC Form 471:

• We propose the following modifications to the FCC Form 471 to implement the changes adopted in the Category Two Report and Order:

  • Require applicants to provide full-time student counts to determine their category two budget. The modified requirement is a subset of the currently approved requirements. Currently, applicants are required to provide full- and part-time student counts to determine their category two budget;

  • Remove fields that currently collect information on total part-time students, peak part-time students, Institute of Museum and Library Services (IMLS) codes, and category two funding allocations for non-consortium applicants, because this information is no longer needed when applicants apply on a school district-wide or library system-wide basis;

  • Allow consortium applicants to provide information on category two funding allocations on a school district-wide or library system-wide basis, rather than an entity-wide basis, which simplifies the way the currently approved information is collected;

  • Allow school districts and library systems to aggregate student count or square footage on a per-school district or per-library system basis rather than per-entity basis, which simplifies the way the currently approved information is collected; and

  • Add an optional check box so that applicants can indicate if they want to update their student counts. Under the category two budget approach, applicants’ category two budget for all five years is set using the student count from the first year an applicant applies for category two support, but applicants may update their student count during the five-year cycle.

• We also propose modifications to the FCC Form 471 to improve the user experience. The proposed modifications allow applicants to clarify information that is collected under the existing information collection, reduce administrative burdens on applicants, and/or enhance the user experience by improving the FCC Form 471’s formatting or display. Changes include:

  • Allowing applicants to provide additional specificity about entity types, by adding “swing spaces” to the existing list of entity types from which applicants select to identify the types of entities that are included in their entity profile;

  • Allowing applicants that provide Community Eligibility Program (CEP) information to determine E-Rate program discount rates, to provide this information on the FCC Form 471 once every five years, rather than during the application review process every year;

  • Removing fields requesting bandwidth information for category one funding requests that are not related to internet access and/or data transmission service; and

  • Streamlining certain functionalities on the FCC Form 471, such as allowing applicants to select multiple recipients of service when creating line items and creating a mechanism to automatically flow to a line item, rather than requiring applicants to click on a specific funding request number to get to the line item.

• There is no change in the burden hours and no costs are associated with this collection.

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