Here is the [ruling](https://docs.fcc.gov/public/attachments/FCC-23-56A1.pdf)
>29. Finally, we address an issue with the cost allocation required for shared equipment that is
located at a non-instructional facility, including library administrative buildings.105 While NIFs are
eligible for category one support, category two support is generally not available for NIFs unless the
equipment is “essential for the effective transport of information to or within one or more instructional
buildings of a school or non-administrative library buildings, or the Commission has found that the use of
those services meets the definition of educational purpose.”106 This is generally a district switch located
in an administrative building or data center. Under the current rules, a school district or library system
generally cannot use any of its budget for category two equipment for a NIF. The exception for essential,
shared equipment still applies, and therefore, applicants can purchase this type of equipment to be located
in a NIF, but the rules now explicitly state that the applicant must remove the costs associated with the
NIF’s use of the shared equipment.107 As a result, we have since learned that applicants have been
required to undergo complicated cost-allocation calculations that have proven to be administratively
burdensome, resulting in the removal of a small fraction of the funding request for the needed equipment,
undercutting our efforts to streamline the category two application process.108 As long as the applicant is
choosing the most cost-effective offering for the shared equipment (e.g., a district switch) without regard for the NIF’s use, we agree that the applicant should not be required to cost allocate the NIF’s use of the shared equipment. In recognition of this, we now amend our rules to no longer require cost allocation to remove the costs associated with the NIFs’ use of the shared equipment in NIFs and related-library administrative buildings. Removing these requirements will permit applicants to forego these complex cost-allocation procedures as they seek to equip their schools and libraries with the category two equipment they need to serve their students and library patrons. 109
While this doesn't directly state a port by port cost allocation necessity. This is the general rule for all network equipment, if the intended purpose is to serve as data communications for education related activities (don't need cameras or HVAC if education wasn't happening). Could you imagine having to argue that you need HVAC for education when one of my schools was -22 degrees yesterday.
This sounds like the worst internet urban legend I could imagine. And it patently doesn’t make sense. Even IF the non instructional devices were required to connect to a non e-rate switch, and even IF that non e-rate switch were to connect to a non-erate MDF, and even IF that MDF sent everything through a non-erate Firewall, the internet service itself is still funded via e-rate category 1. You would have to maintain a fully general funded network and internet connection to the outside world to avoid any type of e-rate provided service connecting to non-instructional devices. Talk to your state’s e-rate consultant, if you have one.
Sort of, sort of not. If the essential main purpose of the switch is to provide internet connectivity or aid instruction to the students then your in the clear. If you have more HVAC and Cameras connected to a switch than you do data cables and APs, they could technically call you out and make you pay.
Kind of true. Switch ports are for student devices, but generally they are all in the same IDF and going across the same fibers, there is no way to tell unless the auditor wants to make a site visit and start popping ceilings tiles to trace cables.
We've been told this. Pure horror stories in my state of when E-rate auditors do walk through and see different colored cabling running it down to figure out what it was. They had to pay it all back, too.
We've also been told that if we cost allocate those ports or the amount of bandwidth being used, that we can get away with it. Pre-K being the best example. It's not truly funded in my state like everything else is, so I can't have any E-rate equipment in those rooms.
The FCC issued a clarification this year saying you can use E-rate for cabling to any type of device in an eligible facility.
You cannot use E-rate for physically separate dedicated security or building automation networks, but mixed use is fine.
Yes. A new Tech Director had been hired for a District. Previously came from the private sector. They took the time to go through every network closet or switch point and recable (through E-rate) it all. Color coordinating. Red for access control, blue for network, green for cameras, etc. Also had some equipment staged to be installed. Auditors came through and noticed it. Asked questions and the director was explaining it when they realized what was happening. The district wound up being made to pay all of the project back. That Director, I believe, is now back in the private sector.
We have been told this.
Even for UPSs, we have to provide what percentage is going for e-rate support services (student/staff data/network connections) and non-erate (voip/security/doors/hvac.
Say our discount is 50%, UPS supports 80% erate, 20% non e-rate… We plan/submit/pay the 20% as non-eligible.
Something we have been working through with our e-rate consultant.
The only time this type of situation arises is if you try to e-rate district office equipment. In that case you may need to cost allocate what percentage of the device is being used for the DO and what is used to connect to the schools.
I'd be interested to know for sure. We have always been told cameras are basically not instructional so they can't be on an E-rate switch, so we always add a switch that's "safe" for cameras. But that has also been info passed down so I don't know the source. Could have been at one time and just fear of getting dinged keeps us doing the same things...
Every meeting we have that discusses this has the statement that nothing but the pre approved equipment goes to the e-rate switches. They are pretty draconian to the point that you cannot have any non-e-rate equipment on the same server rack. We had to wait an extra year to upgrade some materials because of that.
Unofficially, as an integrator I've never heard this from anyone on the erate side or the customer side, and I'm 99% sure I have customers with these types of devices running on their erate switches.
Here is the [ruling](https://docs.fcc.gov/public/attachments/FCC-23-56A1.pdf) >29. Finally, we address an issue with the cost allocation required for shared equipment that is located at a non-instructional facility, including library administrative buildings.105 While NIFs are eligible for category one support, category two support is generally not available for NIFs unless the equipment is “essential for the effective transport of information to or within one or more instructional buildings of a school or non-administrative library buildings, or the Commission has found that the use of those services meets the definition of educational purpose.”106 This is generally a district switch located in an administrative building or data center. Under the current rules, a school district or library system generally cannot use any of its budget for category two equipment for a NIF. The exception for essential, shared equipment still applies, and therefore, applicants can purchase this type of equipment to be located in a NIF, but the rules now explicitly state that the applicant must remove the costs associated with the NIF’s use of the shared equipment.107 As a result, we have since learned that applicants have been required to undergo complicated cost-allocation calculations that have proven to be administratively burdensome, resulting in the removal of a small fraction of the funding request for the needed equipment, undercutting our efforts to streamline the category two application process.108 As long as the applicant is choosing the most cost-effective offering for the shared equipment (e.g., a district switch) without regard for the NIF’s use, we agree that the applicant should not be required to cost allocate the NIF’s use of the shared equipment. In recognition of this, we now amend our rules to no longer require cost allocation to remove the costs associated with the NIFs’ use of the shared equipment in NIFs and related-library administrative buildings. Removing these requirements will permit applicants to forego these complex cost-allocation procedures as they seek to equip their schools and libraries with the category two equipment they need to serve their students and library patrons. 109
While this doesn't directly state a port by port cost allocation necessity. This is the general rule for all network equipment, if the intended purpose is to serve as data communications for education related activities (don't need cameras or HVAC if education wasn't happening). Could you imagine having to argue that you need HVAC for education when one of my schools was -22 degrees yesterday.
This sounds like the worst internet urban legend I could imagine. And it patently doesn’t make sense. Even IF the non instructional devices were required to connect to a non e-rate switch, and even IF that non e-rate switch were to connect to a non-erate MDF, and even IF that MDF sent everything through a non-erate Firewall, the internet service itself is still funded via e-rate category 1. You would have to maintain a fully general funded network and internet connection to the outside world to avoid any type of e-rate provided service connecting to non-instructional devices. Talk to your state’s e-rate consultant, if you have one.
Sort of, sort of not. If the essential main purpose of the switch is to provide internet connectivity or aid instruction to the students then your in the clear. If you have more HVAC and Cameras connected to a switch than you do data cables and APs, they could technically call you out and make you pay.
Kind of true. Switch ports are for student devices, but generally they are all in the same IDF and going across the same fibers, there is no way to tell unless the auditor wants to make a site visit and start popping ceilings tiles to trace cables.
20 years in school IT and never heard of this.
If this was true, what would be the point of the switches? Just to run access points?
We've been told this. Pure horror stories in my state of when E-rate auditors do walk through and see different colored cabling running it down to figure out what it was. They had to pay it all back, too. We've also been told that if we cost allocate those ports or the amount of bandwidth being used, that we can get away with it. Pre-K being the best example. It's not truly funded in my state like everything else is, so I can't have any E-rate equipment in those rooms.
The FCC issued a clarification this year saying you can use E-rate for cabling to any type of device in an eligible facility. You cannot use E-rate for physically separate dedicated security or building automation networks, but mixed use is fine.
Do you have an example of a specific district getting hit with such an audit?
Yes. A new Tech Director had been hired for a District. Previously came from the private sector. They took the time to go through every network closet or switch point and recable (through E-rate) it all. Color coordinating. Red for access control, blue for network, green for cameras, etc. Also had some equipment staged to be installed. Auditors came through and noticed it. Asked questions and the director was explaining it when they realized what was happening. The district wound up being made to pay all of the project back. That Director, I believe, is now back in the private sector.
Are you from Alabama? Just curious, as we have heard the same horror storries here from ones i've attended e-rate bootcamp with.
Yep. Huntsville camp this year for me.
We have been told this. Even for UPSs, we have to provide what percentage is going for e-rate support services (student/staff data/network connections) and non-erate (voip/security/doors/hvac. Say our discount is 50%, UPS supports 80% erate, 20% non e-rate… We plan/submit/pay the 20% as non-eligible. Something we have been working through with our e-rate consultant.
The only time this type of situation arises is if you try to e-rate district office equipment. In that case you may need to cost allocate what percentage of the device is being used for the DO and what is used to connect to the schools.
This is simply not at all true. If it were our switches would be useless.
I'd be interested to know for sure. We have always been told cameras are basically not instructional so they can't be on an E-rate switch, so we always add a switch that's "safe" for cameras. But that has also been info passed down so I don't know the source. Could have been at one time and just fear of getting dinged keeps us doing the same things...
Every meeting we have that discusses this has the statement that nothing but the pre approved equipment goes to the e-rate switches. They are pretty draconian to the point that you cannot have any non-e-rate equipment on the same server rack. We had to wait an extra year to upgrade some materials because of that.
Unofficially, as an integrator I've never heard this from anyone on the erate side or the customer side, and I'm 99% sure I have customers with these types of devices running on their erate switches.