We sat down with Kim Friends, VP of E-Rate of compliance at CSM consulting, to talk about the 2020 E-rate rules, MIBS and what schools should know going in 2020-2021.
To learn more visit us at Lockstepgroup.com & CSM consulting
Thanks for listening!
Ali Adib: 0:10
From Lockstep Technology Group, This is Ali Adib. And this is The Cosed Beta Project. The show where we talk to cybersecurity experts and influencers about how we can live and grow in the digital age.
Ali Adib: 0:26
Let's just jump into it. Can you give me a little bit about yourself, I know this is their second time. Um, this is a part of our episode to a great episode. Um, So welcome back, Kim. If you give me a little introduction by yourself and, um what we're gonna talk about today?
Kim Friends: 0:45
Sure. Okay. Thankfully, somebody Kim, friends and I, and vice president of You're a compliant service is for CSM Consulting. We're a full-service E-Rate applicant consulting firm working, uh, with about 400 applicants of all types on in 15 different states on we also serve as a state coordinator for can see Hawaii, and we work on the California State Great coordination team. Um, I've been doing the race since the beginning of time. Uh, so I've, you know, been through all of the ups and downs and trials and tribulations, and I think we were We're coming into some stability in the program coming up in the next few years with the caveat that this year is a little chaotic.
Kim Friends: 1:36
And so I think there will be a new interesting conversation today. Sort of talk about what people should be considering for this current year, while also seriously considering what to do for fund your 2021 beyond.
Ali Adib: 1:51
Okay, You mentioned being chaotic. What? What does that mean? Can you elaborate on that?
Kim Friends: 1:55
Sure. So I think the first, um I think the first ah thing that makes this year the fund here that we're finally for right now, which is 2020 2021. Ah, little chaotic was sort of late notice of the category to order. Last time we spoke was in July,
Ali Adib: 2:17
Kim Friends: 2:17
at that time, we had no order for Category two going beyond 2019 and the FTC did not release the order. Oh, gosh, I'm gonna I think it
Ali Adib: 2:30
Kim Friends: 2:30
November on when when we got the the order that tells us what's gonna happen for 2020 and 2021. And what will happen for 2021 beyond. And essentially, what the f b c did, which I think was a really good move is they made the 2020 2021 year sort of a transition year two new rules that will be, in effect, her category to budget starting in 2021.
Ali Adib: 3:01
Kim Friends: 3:03
So it's a little chaotic this year, to the extent that, um, I think a lot of people who first started using their category two budgets back way back in 2015 under the initial test five year budget cycle, we're really expecting to have, like, a whole new budget, starting with 2020. Um, and that's not necessarily happening. But the FCC has provided a provision, um 4 2020 for and made it essentially a six year of the five year test budget that began in 2015. They've added and um, uh, an additive for 2020 of an additional 20% to the per student budget. Um, over and above what the per student budget or per square foot budget was for libraries for 2019 and which is good news for applicants who haven't used all of their five year budget because they're starting out with a much higher number for 2020 and they don't have as much to subtract from the prior years. But for those who started early 2015 or even 2016 and spent a lot of their budget early in the cycle, um, I think they're a little bit disappointed that they don't have more money to spend in 2020. Uh, but at least they're going to have something
Ali Adib: 4:30
that's awesome. Um, so what do you expect? Me? What should people expect? Um, for us, for our schools and libraries. Go going into it. We should keep in mind. I know you said it was all chaotic because he was a late notice. And what should the provider is? Look into and keep in mind.
Kim Friends: 4:49
Well, so I think that the sort of key takeaway for 2020 is that, uh, it really is sort of a use it or lose that year. So applicants need to be aware and determine how much money they have available to them in 2020. Because if they don't spend it all in 2020 it doesn't roll over into the new five year cycle. That will begin in 2021. Everybody's gonna start fresh in 2021 on the same five year budget cycle. There's not gonna be this rolling, you know, everybody's kind of on a different cycle and started a five year budget a different year. Um, and I'm not one to be sort of an alarmist about the whole use it or lose it thing. But it's very clear, very black and white money that you don't spend in 2020 2021. Well, it won't be available in subsequent years. I don't want to say it will be lost, because if you don't need to spend it, don't spend it.
Ali Adib: 5:50
But I'll tell
Kim Friends: 5:51
you what. If you need to send your money and you need to buy, you know, upgraded infrastructure for your schools or your libraries, this is the year to do it. Um, because if this is like a big giant sort of boosted year, um, like a super year Ah. Is 2020 and then 2021 beyond. We'll circle back to the status quo and find some normalcy.
Ali Adib: 6:17
Okay, when you say boost that, Do you mean as far as the funding is much bigger. So
Kim Friends: 6:24
the Lenny Lenny playing so last year 2019 per student budget. Waas uh one. It's E Homer Gosh one cities 1 56 39. But it went out like 11 decimal points.
Ali Adib: 6:42
So wow, so
Kim Friends: 6:43
that's what you started with on for 2019. For 2020 the per student budget is 1 95 63 rounded to two decimal points and then from that 1 95 63 that you multiplied by all of your students. You would then subtract any pre discount funded any pre discount approvals you've had since 2015. So and and then that's gonna give you your total amount of budget for school or her library on for 2020. But you're starting with a number that is significantly higher. You know, we weren't listening, were at 1 60 now we're at 1 95 I mean, that's that's a huge jump. 20% additive, essentially plus a little inflation adjustment of like 2.1%. Um, but that's a big number to start with, and, uh, depending on where you were in your budget cycle, on whether or not you spent any or all or most or some of your money in the prior five years. That's going to sort of determine what kind of a super year you have available like a supernova. This is kind
Ali Adib: 7:53
of like super gear,
Kim Friends: 7:55
right? So because this is really gonna be, like a one time thing, Uh, you know, once once we get, once we get rolling into the new rules, that will be in effect for 2021 which I would recommend we do apart three to sort of talk about
Ali Adib: 8:11
Kim Friends: 8:11
That whole another kind of it's not really applique. It's not applicable for this coming year. It won't be applicable until 2021. And there's still some some sort of amputees. A little, Um, we need some clarification on a few things that we're speaking all of that information as we speak. But you know, everybody's identification and, you know,
Ali Adib: 8:30
Kim Friends: 8:32
So you know, Anyway, we're trying to get that sorted out, but yes, so, so funny. You're 2020 is really a very special year. Eight year for any of the any of any of the audience has been around since the beginning of time. It kind of reminds me of year 2.5,
Ali Adib: 8:47
Kim Friends: 8:47
back in 22 years into the programme Halfway through the second year. They're like, Man, we got a lot of money left over. We should open another application window and they did, and all kinds of people got money that they weren't accepting. This is kind of like that,
Ali Adib: 9:03
Kim Friends: 9:04
it really is just a one. Time is a one time thing. And once it's here and then it's gone.
Ali Adib: 9:10
This is a good bonus. Basically,
Kim Friends: 9:12
Yeah, you know, I mean, I think the FCC absolutely did the right thing and, you know, showing the restraint to not try to implement all new rules in a very short time frame. Considering our form 4 71 window for 2020 opens on tomorrow. Ah, at New Eastern time. Um, you know, and we didn't get the order till November, so we would have only had a very short amount of time to sort sort out a lot of a lot of changes. And you back the administrator of the program, they're gonna have to do some really work on their portal and their tools to accommodate new rules for 2021. So I think the SEC absolutely did the right thing in waiting A here transitioning does these new rules. And I also think they did the right thing by making you know, Ah, reasonable adjustment to cover this transition year by bumping the per student in per square foot. Uh, budget multipliers by that 20% which was essentially one out of five years,
Ali Adib: 10:17
right? Yeah. And then do you expect
Kim Friends: 10:19
that where they kind of came up with that number?
Ali Adib: 10:22
Okay. What, do you expect it to go down again in 2021?
Kim Friends: 10:26
Yeah, well, it differed for 2021 beyond. We already know it's gonna be $167 per student on. I don't have the library numbers in front of me, the $167 per student, and that's going to persist across the entire five years,
Ali Adib: 10:42
so there won't
Kim Friends: 10:42
be inflationary adjustment. There won't be big changes, fluctuations and budget except as it relates to enrollment or new new buildings or that sort of thing for libraries. Um, so, yes, if I don't want to say it's going down because it's actually gone up quite a bit from last year.
Ali Adib: 10:59
Kim Friends: 10:59
were at 11 51 50 1 59 Um, Anyway, we're going to 1 67 it's gonna stay there. So they've accounted for anticipated, um, inflationary adjustments over that five year period. And rather than waiting around each year to find out what is the inflationary Justin, then people don't really know what they're actual budget is until that's released, they just said we're gonna set it at 1 67 for the entire five years.
Ali Adib: 11:26
Kim Friends: 11:26
no, that give people more predictability and more stability
Ali Adib: 11:30
program. Let's talk about this five year. Um, period, Um, how does that work for schools when they're trying to apply for your aid? Do they do it each year, or do they do it one time and it covers their five year period? Or can you break it down for me?
Kim Friends: 11:50
Sure. So the athlete, the great application process requires an annual applications
Ali Adib: 11:55
Kim Friends: 11:56
you can't file for five years worth of stuff except, you know, and people are gonna say all that you can apply for five year life is you can apply for this. That may be true. There may be components of category, too, that you can apply for up front for a five year period on, but generally as a general rule. Ah, the e great program requires an annual application
Ali Adib: 12:19
Kim Friends: 12:20
or the stuff that you're going to actually buy in that year.
Ali Adib: 12:23
Okay, um, one of the topics I want to talk to you about is, um am I B s. But which stands for managing to Robin? Yeah, MIPs. Sorry. So what does what does that entail? What does that mean on Hawkins, schools and libraries take advantage of it.
Kim Friends: 12:43
So managed to turn a broad dancers is appeared to be quite attractive to smaller applicants. You don't necessarily have, um, many or any, or even if they do have some technical staff. They may not be fully versed on all the various components of, um, an internal broadband network to deliver that broadband service throughout the building, to the students or to the library patrons. And so what the SEC did when they created matched internal broadband service is, as a subcategory of category two is, they're giving those applicants to feel like they could use 1/3 party to help them. Excuse me, Help them manage and monitor on their network eligible network equipment, ineligible locations for a monthly costs.
Ali Adib: 13:39
Kim Friends: 13:39
and you know that's essentially what it works out. You can either use equipment that you own and have 1/3 party manages, or you can seek on a part of managed, in turn, brought dancers. You can speak the opportunity
Ali Adib: 13:56
Kim Friends: 13:57
leave equipment as part of the managed internal broadband service whereby you're leasing use of the equipment from 1/3 party. And that same third party is managing your managing and monitoring your network.
Ali Adib: 14:12
No way. And then does do they have to pay so doesn't, like, get paid out monthly or is it an annual pay? But you know, it is
Kim Friends: 14:22
an interesting question because is apply for as a monthly costs. And that is because by e rate rule, the service's have to be delivered by June 30th at the close of the funding year, so you apply for it as a monthly cost there. I know there have been instances where a contract says that you can pay for it on the left front, and that's, you know, no problem, and then the service provider consume it. An invoice to you fact commensurate with the same time they submit the invoice to the applicant. But I will just go on record right now that I am hearing rumblings that if you apply, um, for funding as a monthly cloth that it must be invoice in monthly increments.
Ali Adib: 15:07
Kim Friends: 15:08
can't I can't confirm that. I'm just hearing that from some of my colleagues that,
Ali Adib: 15:14
Kim Friends: 15:14
that seems kind of oftentimes be like this little pet issue that you sack will pick up on this kind of Is it the invoicing timing of the invoicing? They're great rules require that service is delivered before discounts are given. And I think where you fat is coming down on this issue. If if in fact they are on is that if you're feeling for the whole year up front, you obviously haven't delivered the service yet, So how can they discount it? You've only delivered. You have delivered much, if any, of the service. If you're building all up front, that being said could could those conditions be overcome by terms and conditions in the contract that relate to payment schedule and that sort of thing? Perhaps, But I would just caution on members of the audience. Two. Be very sure about what they can and can't do before they agree to. But us, this is it. Terms and conditions in any contract from its services.
Ali Adib: 16:16
Okay, So, like, if if people buy so if the school by switches and then they haven't managed is that the discipline program or separate thing that you need to apply for? And
Kim Friends: 16:28
I don't Hold on. Let me just make sure that they're buying switches. And then you said in there sort of manage what? I don't know what that means.
Ali Adib: 16:35
So it's like, uh, managed. So if they're giving it to 1/3 party to be managing that infrastructure, uh, you know the wife I don't have good stuff. Yeah. Is that paid overtime? And I think you can I answer that question, but like, is it is it invoiced per item or is as a whole as a school itself, without,
Kim Friends: 16:57
in void by funding requests.
Ali Adib: 16:59
Kim Friends: 17:00
Um, currently you Zach invoicing procedures do not require line items detail, except with the extent that copies of invoices are sometimes requested. Sort of enough, you know, spot, check, fashion. You know where they kind of check it on occasion, I would I would say it's very important for applicants who are considering mids or who are buying equipment and are expecting that there will be some sort of maintenance or, um warranty or something that has a line on a cost associated with it.
Ali Adib: 17:40
Kim Friends: 17:41
make sure that they apply I just to be safe, because there's still quite a bit of ambiguity about on what is mid first. Before his basic maintenance, I recommend that applicants applied for showing your instances. In your instance Italy, where you said Okay, they're buying switches and they want someone to manage it.
Ali Adib: 18:02
Kim Friends: 18:03
would apply for internal connection switches. I would apply for basic maintenance for any costs that may be associated with the manufacturer's warranty, and I would apply for managed internal broadband Service is on the form for 70. That gives you options in the event that you exercise upon reviewing your application that you should that the category for which you applied on your form 4 71 isn't correct. Well, then go back to the form for 70 and make sure that you apply for the right category in the form for 70 and then they can make the change. Unfortunately, if you haven't applied for the correct category on your form four seventies and there's a mismatch on your form 4 71 unless you're really, really clever um, you're you know, you're probably going to deny that funding request and then you'll have to go through this massive, you know, torturously appeal process. So I think just going forward if you're not sure, because especially because basic maintenance of internal connections and managed internal broadband service
Ali Adib: 19:07
Kim Friends: 19:07
our sometimes interchangeable. And the activities associated with each of those categories can sort of reasonably fit in either. Or I would I would put both on your form for 70 so that you're covered.
Ali Adib: 19:20
Kim Friends: 19:21
even the foot in your narrative. Look, we're just we're putting both because we're not sure exactly where the service is air gonna land.
Ali Adib: 19:26
Kim Friends: 19:27
want to make sure that we have a successful form 4 71 funding requests. And he's very you can put anything you want your phone for 70 in the narrative.
Ali Adib: 19:35
Awesome. Thank you for explaining and so simple saying that makes it. Here's the question. I
Kim Friends: 19:41
Ali Adib: 19:42
I think I fit in but I'm jewelry biased. I'm not running a school, so I can only imagine how difficult and complicated maybe for it can
Kim Friends: 19:52
be unnecessarily told some time. So, you know, winning about, you know, check all the boxes.
Ali Adib: 20:02
So here's the question I have. So when under moebs, when they're leasing, um, equipment is at least you own, or is it just simply lease? No,
Kim Friends: 20:15
never leave. Never can be leave their own. Okay, Anything that that you are purchasing or I'm sorry. Anything for which you are speaking, um e rate discounts on via a leaf
Ali Adib: 20:27
Kim Friends: 20:28
can never own. You could never own that equipment.
Ali Adib: 20:31
Okay, so can they still own it and have it to be managed by 1/3 party?
Kim Friends: 20:35
Yeah. If they already own it, they can have it managed by third party. Well,
Ali Adib: 20:40
that's a problem. Um, so here's a broader question. Hawkin schooled in library maximize. They're, um the rate. What's the one of the best things that could D'oh.
Kim Friends: 20:53
Um, well, I mean, for category, too. You know, you're constrained by the category to budget, which has a budget multiplier. And that's the maximum amount that you can apply for in a in a given period. Um, maximizing your e rate. I think that is all about planning, right, Because I have always been of the mind set that you don't just buy stuff for the sake of buying it, right? You want to plan out? What do you need over the next five years and then use the ear a program to leverage whatever dollars you would spend it here? It program didn't clip. Um, you know, if you're 80 or 85% rate discount, you know you can stretch those dollars really, really far, but it's not. Typically, it's been my experience that applicants wait to the very last second to sort of make decisions about what they think they need or what they're sure they need stand up sort of buying stuff. And then they have sort of buyer's remorse.
Ali Adib: 21:57
Kim Friends: 21:58
know, because you're like, a little, you know, if we'd had more time, maybe we could have done this other thing that would have sort of been a better fit for us for a longer period. Uh, you know, I've been acting applicants who have applied, um, and then they get approved, and then they're like you know what we don't Actually, that's not the right fit for us. Now that we've had some time to think about it, that's not really gonna be a good use of the fun. And it's not gonna be a good use of our funding, and then they just return the funding. And then they go again the next year with a more, um, detailed sort of, uh um, identified plan.
Ali Adib: 22:37
Kim Friends: 22:38
maximizing the rate funding is all about planning and being ahead of the curve and not waiting till the last possible Second for you to post any form for 70 or r p r i a. B or whatever the case may be on and really because, you know, technology plans are no longer required for e great compliance. And though they were kind of a you know, what a pain in the you know what back when
Ali Adib: 23:02
Kim Friends: 23:02
required because they were maybe a space for a gotcha. They also did somewhat of a purpose because it kind of forced schools and libraries, too. Think about it and get it down on paper, listening about what are we going to do in the short term? In the longer term plan.
Ali Adib: 23:20
Kim Friends: 23:20
I think that a lot of you $8 air wasted on a corner of a wasted they're not add effectively used, Um, when decisions are made quickly, um, a form for 70 competitive bidding process can open as early as July 1st proceeding the start of the funding year, which is the first of the next year. But you could have a whole year to do your competitive bidding and think about what you want and make sure that you're making
Ali Adib: 23:48
Kim Friends: 23:48
decisions for your environment and for your, um, specific circumstances. There isn't really any way there's no magic. There's no magic to maximize e great
Ali Adib: 24:00
other than good
Kim Friends: 24:01
planning and fiduciary and fiscal responsibility.
Ali Adib: 24:05
So you talk about planning hooking providers, even like the service providers and vendors help with the planning. What tips of you have? Do you foresee or what to do? You have in your experience that can facilitate schools, and they're planning
Kim Friends: 24:23
well. It's stuff from the top one, because here it rules, prohibit service providers, Um, who want to potentially bid on Annie right applicants competitive process, whether it's the form for 70 or reform for 70 and some other documents. The rate rules prohibit any service provider involvement in developing those documents. Um, that's not to say that service providers can't have technology neutral conversations with their customers or potential customers. Um, and I think that service providers are well within their right to reach out early, early on. And
Ali Adib: 25:03
you know, if
Kim Friends: 25:04
they've got something new or or they just want to introduce themselves, they should do it very early, like in the summer. Late? No, no later than, like late summer on and And be very careful that they're having just, you know, this is us. This is what we do business. The latest greatest Have you considered and just very neutral conversation. And obviously, always be very mindful of the great gift cool, which essentially say you can't offer anything on over $20. Do a great African at one time or over $50 cumulatively, uh, so you know it. Service providers were kind of in a tough spot. Um, just because their service providers right, so you know, it's it's not. It's not an ideal situation, but there are ways that service providers can communicate what, you know, that they're around that they're available, that they you know that that they sell this matter the other. And you know it's compatible with this, that or the other. Or, you know, a lot of information that does not drill down into the specifics of that applicants seeds. And as I said early in this particular conversation, a service provider cannot be inappropriately involved in developing any specifications or developing form for 70 or anything like that. So
Ali Adib: 26:31
Kim Friends: 26:32
away from that house. Um, neutral conversations early on with customers, existing or potential customers and, um, be responsive. The responses to the form for seventies be responsive to the R P. Read all of the requirements and make sure that you comply with them so that you don't have problems with responsiveness. Um, I wish that I had a better answer for you, Ali. I know that's not great news,
Ali Adib: 26:58
but it does what it does. It does exactly what I was looking for. It that's the boundaries that separate providers have. They need to be within that. So let's push it back to her. The schools and libraries, what resources do they have to make sure the planning is smoother for them? so they can get ahead of the curve a little bit so that not even doing living in last minute and have that buyer's remorse,
Kim Friends: 27:22
right? So another good question. Another tough plot. You know, applicants, both school then libraries have varying degrees of expertise available on the staff. Um, you know, particularly smaller, mid sized smaller applicants don't typically have, You know, a technology director I t coordinator or something that that knows what the next best thing is. So I know many Atkins attend their state level, um, technology conferences and technology check Ed Tech conferences would usually her in spring and summer on, you know, never the attention sessions, and they learn about new things. And then they, you know, they should be going back to their staff into their district and having conversations about, you know, this is what we need to do in the next three years. To achieve this goal. How do we how do we best achieve this goal? Let's say, for example, they want they want to have a 1 to 1 computing computing initiative. What kind of band with her they're going to need in order to accommodate that on campus um, what kind of switches like they need to upgrade to in order to handle all of the various sessions that may be going on the network at a particular time? Um, they they learn about all this stuff in the ed kept conferences, you know? And most applicants do have, you know, service providers that they currently work with. And I'm sure that they ask questions of them. But again, both on the applicant side, those questions need to be very neutral. Very, um, be very circumspect. And I'm the service provided applied that same thing, very neutral thing. Applicants should not engage with the service provider to help them develop specifications. The service providers should not engage with the applicant to help them develop specifications. Because no matter what, that's just gonna end up in a big old nets and rule rule violations. You know, galore. Funding denied. Just not a good look.
Ali Adib: 29:23
Kim Friends: 29:25
so I think that at many applicants are they struggled with that. They struggle with how to know what is the next best, greatest latest whiz bang widget that is available. That's gonna help them achieve whatever goal they have set short term and long term.
Ali Adib: 29:44
So how can they fix that? Is this something that if he sees looking into fixing providing those resource is later on or what is the alternative solution for this?
Kim Friends: 29:55
So I I have not heard any whisper of the FCC or you Fact providing any sort of resource is along those lines. I know that there are technology consultants out there on that work with applicants to help them, you know, work with school district in libraries to help them figure out what's gonna be the best, ah, path forward to reach whatever goals they have within the organization. Unfortunately, I don't think they're free. Um, but if you really don't have any idea where start and you want to maintain compliance with the great rules so that you can leverage that you write fund to help you reach those goals, I would consider, you know, seeking some professional assistance with helping you at least get the ball rolling with how best to achieve whatever gold except for your organization.
Ali Adib: 30:54
Kim Friends: 30:54
I don't think I don't know of any free resources that are available
Ali Adib: 30:58
Kim Friends: 30:59
that. Um, at least that are not available publicly on our I'm not aware.
Ali Adib: 31:05
Okay. Um I mean, I I said just last time, Um, given what you know now that the 2020 2021 afterwards um, do you like the direction it's going Or how do you first see the 2020 ones and above and beyond looking for e rate and technology in schools?
Kim Friends: 31:27
Right. That's a good question. It was a good question then. It's a good question. Now I feel very, um, encouraged by the direction that the program is headed on. There it is maintaining, um, fairly substantial bipartisan support on the fact that they have set the five year budget cycle for C two as a permanent five year budget cycle. And they're already reference things the 2026 2 2030 cycle, which will be the next next five years. You know that Sort of a good sign that nobody's expecting that the, um, nobody's expecting that the uh, program is gonna go away anytime soon. There may still be changes tweets made to the program on, but I'm very encouraged by the direction that the program's going and and I'm particularly encouraged by this category to order as it relates mostly the 2021 beyond, because it does provide that predictability and stability that applicants really have been craving since the inception of the program. Because really, even even in this test five year period that we just went through with the modernization order effective in 2015 there were still pieces of that that were under that. We were uncertain about until late in the game, for example, that inflation adjustment. You know, we didn't often get the inflation adjustment on number until sometime in February. Well, the rate application window closes in March and, you know, in the past couple of years, then up, you know, upwards of to prevent. That's a big amount of money
Ali Adib: 33:10
and is you
Kim Friends: 33:11
not, You know, if you're not aware that it's gonna look like that, you could be leaving money on the table because you didn't have time to apply for all that extra money and doink location marked in here, you know? So I am quite excited to see, um, how things roll in 2021 beyond, because again, I think that at programs constituents, not just applicants, but service providers as well have really crave some stability and predictability. And I think that the new category to order provides a lot of that
Ali Adib: 33:49
awesome. Aren't any changes, new additions that we didn't talk to you right now? Talk about right now.
Kim Friends: 33:56
No. Um, now, we were really hoping we the royal
Ali Adib: 34:01
weeks, you know, were
Kim Friends: 34:03
hoping to see some. I think we talked about this in part one. We were really hoping to see some movement toward making advanced security features eligible for e rate funding. Considering the mission critical data, um, nature of these data networks that they simply you know, they can't be down. I heard. I know. I heard or read that. I think the whole state of Louisiana got taken down
Ali Adib: 34:30
by a cat, you know,
Kim Friends: 34:32
And that's happening in school districts all over the country. And, you know, this is sort of the new thing, right? And this ransomware and all this other whatever I really be found like I know what I'm talking about. I
Ali Adib: 34:45
bear you. D'oh d'oh! You're getting just I will
Kim Friends: 34:52
tell you that we were disappointed that the FCC declined Thio include on an expansion of the eligible thirties list to include some of these network security features, however, in the order two of the in the Sea to order that we've been talking about, two of the five commissioners indicated one just a rogue morsel. And Michael O'Reilly on indicated that they would like to revisit the on possibility of, ah, the eligible service's list incorporating some or all of these advanced network security features
Ali Adib: 35:33
in future years. And
Kim Friends: 35:35
I know that there is
Ali Adib: 35:36
a huge push from some of
Kim Friends: 35:38
the really large um uh, constituent organizations on stakeholder um, groups like Shelby and Cope in that are really going to push the FCC to make a decision regarding, um, advanced network security options as soon as possible, like well, in advance of the start of the 2021 year so that applicants can plan accordingly. Um, I would imagine that almost without exception, based on what I know about network security appliances, I think they'll be treated in category two, and they'll be subject to the limitations of the category to budget. But, um, I don't think people are gonna care about that. I think they're gonna really like the opportunity to
Ali Adib: 36:31
seek your funding, so helps
Kim Friends: 36:33
them protect these networks and protect the critical data privacy issues. All of the stuff that goes on every single day on these networks. So there's nothing really to add. Other than hopefully there will be something Dad
Ali Adib: 36:47
do you see, like the cyber security aspect of it to be part of mids, to be kind of managed by 1/3 party. Given the fact that many schools don't have them, which resource is, um I mean hardware by itself is great, but be able to react to it and manage that.
Kim Friends: 37:07
That's a good question. I can't answer that. I think that would be something that would need to sort of evolved out of the starting point, which is getting the FTC to agree that network security is a critical component of the rate the rate program,
Ali Adib: 37:27
Kim Friends: 37:27
I mean, they're funding all these switches, their funding, these huge networks with lots of big pipes and lots of bandwidth, and all this information is running all over the place. But the great program doesn't currently support security features to protect those networks from attacks on. I think that's an interesting point. A scar is whether or not you know, managing a an attack would be considered mid. I would recommend that anybody who thinks that's a good idea. You know, once we start talking about this in the public forum, you know, hopefully the FTC will issue a, uh, public notice or something when they when they want to do this or is part of the eligible service list to respond with comments to these public proceedings for the FCC is asking for comment. You guys, you know, they're asking for comment because they want to know what people think. So, you know, keep an eye on announcement from the various stakeholder on group like Shelby and Coats in. And if the, um, check with your state coordinator, he beat your favorite coordinators to see whether or not they have, um, any information regarding public notices or or proceeding better speaking comment regarding that issue. And I would just encourage anyone who thinks it's a good idea on two. So make comments would say, this is how I think that should be handled, and the FCC is gonna say something or nothing. He's like me. They're gonna
Ali Adib: 39:05
Kim Friends: 39:05
gonna say they're gonna say, Oh, that's a great idea, Ali, Thanks for suggesting it. We're gonna incorporate this
Ali Adib: 39:11
Kim Friends: 39:12
such and such, or they're gonna say nothing and just, you know, ignore it. But,
Ali Adib: 39:16
Kim Friends: 39:17
I know for sure. If it's not brought up, the answer will be No, because the FCC is not going to think of it on their own.
Ali Adib: 39:24
I see. But that's a good point. Where can people submit their comments online?
Kim Friends: 39:30
So in our last session, I provided a link to express content. Um, and I can provide that again to you. If you can't find it, you can submit a comment to the sGC at any time. There doesn't have to be an open for feeding.
Ali Adib: 39:46
Kim Friends: 39:46
know you can. You can just submit a comment and with the docket 13-1 84 and that you know, they do Rico comments. It doesn't necessarily happy. You don't necessarily have to wait for formal proceeding on. And
Ali Adib: 40:03
Kim Friends: 40:03
encourage anybody who feels very strongly that network security should be supported by the great program. Just start submitting on it. They we need help. We need help to afford these. Make make the service. Is this service available and affordable to us? Submitted school district don't have anything like this because they simply can't afford it. And then they've got to find the money to come up with to, you know, get out of the, you know, pay their ransom or, you know, they've got it. They've
Ali Adib: 40:35
got to pay their
Kim Friends: 40:36
service provider, Thio, get them. You know, out of whatever attacked pickle there in, um, so it's just it's just really it's really top. It's a tough situation.
Ali Adib: 40:47
Awesome. Not awesome. But that was a good answer to that because like, that's what exactly what? I wanted to bring up what we talked about this uncovered this last time that people can actually contribute and give feedback to to powers that be what is needed and what they can change And what, um, how to use cyber security as part of their year eight.
Kim Friends: 41:11
Yeah. I mean, we were all very hopeful that the SEC would pick up this banner this year. But, you know, for I'm sure they I'm sure they're good reasons. They decided not to this year, but the fact that two of the commissioner's indicated a willingness to revisit it. And I know there is ah lot of groundswell of support through some of these, you know, large advocacy groups like Shelby and cosign. And if he and the stadium coordinators lions on two, uh, you know, really encouraged the FCC to take a hard look at this and figure out a way to make it eligible for ear it funding to two again help school districts and libraries provide affordable access because, you know, having discounts on your network on your, you know, big pipe through your 10 gig pipes or whatever, that's fine. But if somebody attacks your network and it goes down, what then it does. Nothing matters, except that is down from providing you discounts on a network that down. And
Ali Adib: 42:20
Kim Friends: 42:20
may be down for who knows how long. Based on some of the, you know, crazy schemes that the hackers have come up
Ali Adib: 42:28
with. Yeah, so, um, what is next? I mean, the 2021 is coming up. This is a big year. I bonus here, But what is next? What do you foresee happening? In addition, hopefully the cyber security support,
Kim Friends: 42:44
I don't know.
Ali Adib: 42:45
So I don't like I mean,
Kim Friends: 42:48
I'm just being honest. We've all been so focused on the category too Border and pretty laser focused on the security issue. Um, you know, there are some other nuance changes thio substantive, and you want changes for 2021 beyond that are interesting that I think people will definitely want to tune into another episode two, um, sort of find out a little bit more about that. But the reality is what's next is your form for 71 window opens tomorrow,
Ali Adib: 43:24
so and it
Kim Friends: 43:24
closes on March 25th.
Ali Adib: 43:26
And so if
Kim Friends: 43:27
you have not yet posted a form for 70 for 2020 you probably should consider getting on that on. Be sure to get your app. You're great for, unfortunately, one applications submitted no later than the deadline on March 25th 2020. Uh,
Ali Adib: 43:43
Kim Friends: 43:44
know, I hear anything else
Ali Adib: 43:45
you see will be
Kim Friends: 43:46
brought up at the top of the
Ali Adib: 43:47
list and I'll
Kim Friends: 43:48
let you know, Ali, I
Ali Adib: 43:49
can't wait. Is there anything else you want to talk about that we didn't cover today?
Kim Friends: 43:53
Your suggestion about you know whether or not mid could cover? You know, handling an attack is an interesting concept that I don't I've never heard anybody bring that up before
Ali Adib: 44:05
Kim Friends: 44:06
That's something that I would recommend during, you know, proceedings that you comment and say, you know, these are the types of service is that can be provided by 1/3 party. Would this be something that would maybe be eligible under Mitt?
Ali Adib: 44:22
Yeah, because, like, I'm looking at the prices that people pay for ransomware and the price that they could potentially pay overtime to just have someone Manager security And then and then in case of ah attack, they could recover much faster and without have to pay a ransom, it's exponentially lower. Um, if if they think about it, to just be secure and, more important, that data that gets released nowadays. But their answer. If you don't pay the ransom where that of valuable information that you can't put a price on it
Kim Friends: 44:53
well and I'll tell you what any kind of documentation that anybody can provide to compare, you know, quantify the costs and quantify those those sort of conceptual ideas and why that's why this is a good idea to think about this as an option through the ear. It program any kind of data that can be provided to the FCC is welcomed by them and, you know, lock step. Y'all can make an appointment and go to the F You see and talk to the wire line Competition Bureau about stuff like this You
Ali Adib: 45:28
Kim Friends: 45:28
can have you can you can call the I'll give you the number you can call and make an appointment. You all can travel to D. C with all of your papers and even, maybe even just have a cost of Paul. But they're accessible. People think
Ali Adib: 45:43
Kim Friends: 45:43
their life on the head of stolen
Ali Adib: 45:45
nobody can get
Kim Friends: 45:46
quite. They're quite accessible
Ali Adib: 45:48
a lot. Thank you for listening Close. Better project Hope you've enjoyed this episode. If you did, please review like and share with your friends and colleagues. Closed beta project is produced and hosted by me. If you've any questions, please visit our website blocks that dot com until the next episode of Israeli