General Product Guidelines
Maintenance and Technical Support
Redundant and Spare Equipment
Redundant Supervisor Engine -- Ineligible
Content Networking
IP Telephony
IP Communications
Routers/Switches/EDGE Devices
Security and VPN Devices
Wireless LAN Products
Network Management

General Product Guidelines

E-rate provides discounts on the conduits that deliver information to the classroom or library. Generally speaking, if equipment can be removed without disrupting a classroom′s connection to the Internet (or other information source), then the equipment will not be eligible for E-rate support. Similarly, if students can not access the Internet or their e-mail without a certain device, then that device will be eligible for E-rate support. Note, however, that end user devices, such as desktop computers, are never eligible for E-rate support.

Technical Services and Support

Basic maintenance / Technical Services (such as SMARTnet & SAS) are eligible for E-rate discounts with the following considerations:

Eligible:


Note: UCSS is eligible for E-rate discounts but is considered Internal Connections.

Redundant and Spare Equipment

The E-rate does not provide discounts for the purchase of equipment that is warehoused, or otherwise sits idle. Spare equipment is not eligible for E-rate discounts.

NOTE: Redundant or spare equipment that is installed and functioning is eligible for support. For example, an additional power supply that is installed and functioning in a “hot standby” mode is considered eligible for E-rate support. Applicants should clearly identify how “spare” or “redundant” equipment is being used.

 

Redundant Supervisor Engine -- Ineligible

On April 18, the SLD issued findings in connections with the eligibility of Redundant Supervisor Engines. According to the SLD, a Redundant Supervisor Engine belongs in the class of “equipment that only becomes active if a primary component fails.” That category of equipment, the SLD contends, “is not necessary to transport information to eligible locations” and, therefore, is ineligible. The SLD′s position is directly at odds with the FCC′s conclusion that uninterruptible power supply (UPS) equipment is eligible. An applicant whose request for funding for a Redundant Supervisor Engine is denied should appeal that decision to the FCC, citing the UPS example as precedent for why the SLD′s decision should be reversed. E-rate Program rules permit any party adversely affected by an SLD decision to appeal it. Therefore, a vendor involved in a Redundant Supervisor transaction may also file an appeal.

Content Networking

Cisco Content Networking Devices consist of a family of products which route, switch and deliver voice, video and data content. These products primarily are eligible for E-rate support because they form a conduit that delivers information to the classroom or library.

 

The Cisco Wide Area Application Engine series products are being specified by Cisco as the replacement for the Content Engine line. The former Content Engine products were cost-allocated on the basis of their hard disk storage space, which is used primarily as a caching mechanism (which is ineligible for E-rate support.) With the introduction of the WAE series, Cisco changed the manner in which the devices are configured. The following Cisco part numbers ship with no hard disk drives installed:

WAE-511-K9 (Wide Area Application Engine 511, NO HDD INCL, SW ACNS/WAFS)
WAE-611-K9 (Wide-Area Application Engine 611, NO HDD, SW ACNS/WAFS)
WAE-7326-K9 (Wide Area Application Engine 7326, NO HDD INCL, SW ACNS/WAFS)


The hard drives required for the operation of the WAE series products, then, are as follows:

DISK-611SC-144GB 144 GB SCSI Disk Drive for WAE-611
DISK-SATA-250GB 250 GB SATA Disk Drive for FE/CE/WAE-511, option
DISK-SATA-250GB= 250 GB SATA Disk Drive for FE/CE/WAE-511, spare
DISK-SATA-80GB 80 GB SATA Disk Drive for CE/FE/WAE-511, option
DISK-SATA-80GB= 80 GB SATA Disk Drive for CE/FE/WAE-511, spare
DISK-SCSI-72GB (=) 72 GB Ultra 320 SCSI disk for Cisco WAE-7326
DISK-SCSI-144GB (=) 144 GB Ultra 320 SCSI disk for Cisco WAE-7326


Because the storage capacity of the WAE device is ineligible for discount, the part numbers for the storage devices (the “DISK” parts listed above) should be 0% eligible for discounts. The WAE devices themselves, then, should be 100% eligible for discount as they do not ship with any storage capacity installed.

 

IP Telephony

The Eligible Services list continues to state (under Internal Connections) that “otherwise eligible Internal Connections components may include technology for providing real-time or near real-time voice or video over IP (VoIP)”.

 

Interconnected Voice over IP (Priority 1 VoIP Services)

For the 2007 funding year, the SLD has included “Interconnected Voice over IP” as an eligible service in the Priority 1 funding category. Interconnected VoIP provides E-rate applicants with an IP-based service that allows them to place or receive calls from the traditional public switched telephone network (PSTN) using broadband data connections. The FCC identifies iVoIP in the Internet Access service category. To qualify as iVoIP, a service must meet a host of requirements. These requirements can be grouped into three categories: (1) iVoIP-specific, (2) CPE (customer premise equipment)-related, and (3) general E-rate requirements.

At the current time, official eligibility rulings of proposed solutions are unavailable for analysis. However, based on a detailed analysis of applicable regulations it appears that the service with the highest likelihood of being funded is an iVoIP service that consists entirely of equipment located off of school property. A solution that includes limited CPE would also likely be eligible as long as it was delivered under the same service agreement as the school’s broadband connection. Solutions that are based on the deployment of switches or call processing equipment to end-user locations are unlikely to meet with success. Because iVoIP solutions will be evaluated for eligibility on a case-by-case basis, applicants and service providers are strongly encouraged to seek guidance on specific solutions prior to requesting E-rate support.

 

Note: because the Federal Communications Commission has not yet determined whether Voice Over IP is a telecommunications service, iVoIP will not be eligible for discounts in the Telecommunications Services category, pending resolution of this issue. All iVoIP funding requests should be filed in the Priority 1: Internet Access funding category.


IP Communications

 

 

Routers/Switches/EDGE Devices

All types of routers and switches are eligible for E-rate support. Optical transport platforms and other EDGE devices are also eligible.

 

Certain models of the Integrated Services Router line shold be cost-allocated to remove ineligible functionality like SRST. The most recent cost-allocation information may be found by clicking here .

 

Redundant Supervisor Engine -- Ineligible

On April 18, the SLD issued findings in connections with the eligibility of Redundant Supervisor Engines. According to the SLD, a Redundant Supervisor Engine belongs in the class of “equipment that only becomes active if a primary component fails.” That category of equipment, the SLD contends, “is not necessary to transport information to eligible locations” and, therefore, is ineligible. The SLD′s position is directly at odds with the FCC′s conclusion that uninterruptible power supply (UPS) equipment is eligible. An applicant whose request for funding for a Redundant Supervisor Engine is denied should appeal that decision to the FCC, citing the UPS example as precedent for why the SLD′s decision should be reversed. E-rate Program rules permit any party adversely affected by an SLD decision to appeal it. Therefore, a vendor involved in a Redundant Supervisor transaction may also file an appeal.

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Security and VPN Devices

Starting with the 2004 funding year, “firewalls” became eligible for discounts. From a historical perspective, the SLD has remained quite consistent in its response that only “basic firewalls” are eligible for support. The SLD’s definition of “basic firewall” is a simple stateful packet inspection firewall, such as Cisco’s PIX 500 line of security products. Our observation has been that (while seemingly contrary to the rather broad language in the Eligible Services List) the SLD denies funding for any network security product beyond a basic firewall. This includes, but is not limited to, intrusion protection/prevention, anti-spam and anti-virus filtering, content filtering, firewall traversal products, and network admission control devices.

- Firewalls:


- VPN-related hardware and software

- Cisco Security Agent (Server and Desktop): The SLD has now decided that CSA is ineligible and WILL reject funding requests. However, the issue remains under discussion. Therefore, applicants should apply for discounts on CSA Server and CSA Desktop, each in a separate Form 471 funding request (FRN), and file an appeal with the SLD or FCC if/when rejected. When the SLD rejects a funding request, both the applicant AND the service provider named on the application have the right to file an appeal.

- Cisco Intrusion Prevention System components

- Cisco Clean Access: Funds For Learning participated in a lengthy dialogue with the SLD regarding the eligibility status of CCA, and we were ultimately told that CCA would not be eligible for discount as the SLD’s policy is to only fund “basic firewalls.” In addition, the same response was given when we inquired as to the eligibility of other manufacturers’ NAC solutions.

 

Wireless LAN Products

Wireless LAN networking equipment is eligible for E-rate support.

Network Management

Equipment that provides network monitoring or managment functionality is not eligible for E-rate support.

 

 

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