FCDL Comment:
DR1: E-rate program rules require a competitive bidding process where an applicant chooses a service provider only after defining all of the specific services eligible for support at each eligible entity. Only by doing so can applicants ensure that they are receiving the most cost-effective services because bidders have sufficient information to determine exact bid prices. Price of the eligible goods and services, evaluated by using the actual dollar cost proposed by a bidder, must be the primary factor in determining the most cost-effective, and winning, bidder. Detroit defined the services at a high level but did not define which specific services would be delivered at each eligible location because those decisions had not been made at the time of the issuance of the RFP. Bidders were given information on two sample sites, from which they then had to extrapolate their total bid. The applicant selected multiple winners, and based on their own bid evaluation, the additional bidders were not most cost-effective. Furthermore, the applicant awarded a bid to all bidders instead of the single most cost-effective bidder. The bids received came in at different price points, but the applicant averaged the costs and used that average in determining the contract award amounts, none of which matched the original bids. Finally, the applicant awarded a fraction of the total funding it deemed necessary to complete the total work to each of the providers but still did not determine which part of the work would go to which bidder. All sites were included in each FRN for each bidder, and the district intended to then manage the funds between bidders in order to load-balance the work during the year. In essence, the applicant employed a two-step process: first, determine a group of providers and later determine the specific services to be delivered at specific sites. The arrangement described here is contrary to FCC rules and funding is denied.