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CC DOCKET NO. 02-6CC DOCKET NO. 96-45IN THE MATIER OF REQUEST FOR REVIEW BY LOYOLA ACADEMYOF THE DECISION OF THE UNIVERSAL SERVICE ADMINISTRATORColemanGroupMANAGEMENT CONSULTING134 North LaSalle Street, Suite 1400Chicago, Illinois 60602P 312.850.4134 F 312 .893.2038www.colemangroupconsulting.comFCCOffice of the Secretary445 12th Street, SWWashington, DC 20554Attached is an Appeal to the Federal Communications Commission for Loyola Academy [BEN:68605].The purpose of this document is to appeal the Universal Service Administrative Company's decision todeny our original appeal, released May 4th, 2012. In this decision, the Universal ServiceAdministrative Company (USAC) denied Loyola Academy's request to fund the appropriate eligiblecharges from FRN 2230925 for web hosting service from Blackbaud, Inc. on the grounds that 30% ormore of this FRN includes a request for management software, which is an ineligible product/servicebased upon Program rules.The 30% rule subsection of Step 5 ofthe Application Review section ofthe Schools and LibrariesProgram of the USAC website states: IfUSAC finds during application review that an applicant hasincluded ineligible products and services in an FRN, USAC will contact the applicant to determine theexact cost associated with the ineligible items. The applicant can request that USAC either: 1) Removethe ineligible items from the FRN or 2) Create a new FRN and move the ineligible items from theoriginal FRN to the new FRN. If the applicant does not respond, USAC will remove the ineligibleitems from the funding request.Loyola Academy was not notified of any ineligible products I services in the funding request, and adecision was rendered to deny the funding request before Loyola Academy had the opportunity torevise the funding request.Please let me know if you have any questions, or if there is any additional information I can provide.We greatly appreciate your consideration of our appeal. Thank you for your time, effort, patience, andcontinued support of Loyola Academy.Aloy.t.f\- HcJ\ct Stephen Weiss312-850-4134 xl07 (w)630-430-7342 (cl)E',:;; 1s@colemangroupconsulti ng.com

CC DOCKET NO. 02-6IN THE MATIER OF REQUEST FOR REVIEW BY LOYOLA ACADEMYCC DOCKET NO. 96-45OF THE DECISION OF THE UNIVERSAL SERVICE ADMINISTRATORTABLE OF CONTENTSI)Application For Review By The Federal Communications Commission(1) A Statement setting forth Loyola Academy's interest in the matter presented for review. [Page 3](2) A full statement of relevant, material facts with supporting affidavits and documentation. [Pages 3- 5](3) The question presented for review, with reference, where appropriate, to the relevant FederalCommunications Commission rule, Commission order, or statutory provision. [Page 6- 7](4) A statement of the relief sought and the relevant statutory or regulatory provision pursuant to whichsuch relief is sought. [Page 7]II)Documentation of Prior Appeals and Correspondence(1) EXHIBIT 1 [Pages 8- 9]- The contract for services provided to Loyola Academy by Blackbaud, Inc underFRN 2239025.(2) EXHIBIT 2 [Pages 10- 14]- The PIA Review of Loyola Academy conducted by USAC.(3) EXHIBIT 3 [Page 15- 18]- Email Correspondence pertaining to the PIA Review in EXHIBIT 2(4) EXHIBIT 4 [Page 19]- The page from the USAC Schools and Libraries website pertaining to the 30% rule(5) EXHIBIT 5 [Pages 20- 21]- The decision from USAC on Loyola Academy's original appeal released May4th, 2012.

Before theFEDERAL COMMUNICATIONS COMMISSIONWashington, DC 20554In the Matter of)Request for Review by Loyola Academy)Of Decision Of)Universal Service Administrator))Loyola Academy)Wilmette, Illinois))Schools and Libraries Universal Service)CC Docket No. 02-6Support Mechanism)CC Docket No. 96-45(1} A Statement setting forth Loyola Academy's interest in the matter presented for review.In this matter presented for review, Loyola Academy is the sole appellant organization. Loyola Academyis seeking an Appeal to the Federal Communications Commission. Loyola Academy wishes to seekconsideration of the Universal Administrative Service Company's decision to deny our original appeal,released May 4th, 2012.(2} A full statement of relevant, material facts with supporting affidavits and documentation.Appellant I Organization Name:Loyola AcademyContact Person Name: Stephen WeissContact Mailing Address: 134 North LaSalle Street Suite 1400Contact Phone Number:312-850-4134Contact Fax Number: 312-893-2038Contact Email Address: sweiss@colemangroupconsulting.comFunding Year: 2011Date of FCDL Decision: 2/21/2012Billed Entity Name: Loyola AcademyBilled Entity Number: 68605FCC Registration Number: 0015289184Form 471 Application Number: 822163

Funding RequestFunding Request Numbers: 2239025SPIN Code: 143035534Service Provider Name: Blackbaud IncOriginal Commitment Amount: 20,188.42Under the 30% Rule\ if 30 percent or more of the services included on a single funding request areineligible, the funding request will be denied.2Within FRN 2239025 there is one line item in the contract that should be considered eligible. This lineitem is for charges for eligible services related to web hosting for the website and not for themanagement software as follows: Online Community Campus with OLA Subscription- Contract Term (mo) 60 17,000The Online Community Campus Product provides web hosting service for Loyola Academy's DepartmentPages, Online Directories, Athletics Pages, and Calendars.After removing the proportionate amount of the discounts, our revised total annual cost would be asfollows: ( 17,000- ( 22,579* ( 17,000 I 73,050))) 11,745.48. Therefore our revised requestedcommitment amount would be 40%* 11,745.48 4,698.19.Electronic Code of Federal Regulations C.F.R. 47 §1.3 states that The Commission may waive anyprovision of its rules for good cause shown. We will demonstrate (i) special circumstances warrant adeviation from the general rule, and (ii) such deviation will serve the public interest.(i) Special circumstances that warrant a deviation from the general ruleThe 30% Rule for Funding Requests Containing Ineligible Products and Services states as follows:If USAC finds during application review that an applicant has included ineligible products and services inan FRN, USAC will contact the applicant to determine the exact cost associated with the ineligible items.The applicant can request that USAC either:1EXHIBIT 4- The page from the USAC Schools and Libraries website pertaining to the 30% rule2EXHIBIT 2- The contract for services provided to Loyola Academy by Blackbaud, Inc under FRN2239025.

1)Remove the ineligible items from the FRN or2)Create a new FRN and move the ineligible items from the original FRN to the new FRN. If theapplicant does not respond, USAC will remove the ineligible items from the funding request.Loyola Academy was not notified of any ineligible products I services in the funding request during the3PIA Review or subsequent email correspondence4.A decision was rendered to deny the funding requestbefore Loyola Academy had the opportunity to revise the funding request.(ii) Deviation from the general rule will serve the public interest.Founded in 1909, Loyola Academy is a co-educational, private, Catholic, Jesuit college preparatory highschool educating over 2,000 students in and around Chicago and the North Suburban Wilmette &Glenview areas. Loyola is the largest Jesuit college preparatory high school in the United States. Loyola iscommitted to the full development of the whole person. Their curriculum thoughtfully and intentionallyintegrates the academic, spiritual, emotional and physical development of their students with theexperience of service to others.Loyola students are not required to participate in school sponsored service activities; however,approximately 90% of students participate in voluntary service work. Students regularly donate theirtime around the Chicagoland area by: working in retirement communities, tutoring, assisting adults andchildren who have disabilities, working in soup kitchens and food pantries, and working with children inafter-school programs to make sure kids have safe places to go until their parents are home. Over thesummer many students work in camps for children and young adults with illnesses or physical andmental disabilities. Particularly dedicated students work in hospice programs or communities for adultswho have lost their vision, and teach or tutor immigrants their citizenship classes or English as a secondlanguage. At different times in the year students will travel to other cities in the United States for weeksat a time serving the communities in soup kitchens, neighborhood outreach and social service centers.Each year students also travel to various destinations in Central America, focusing on communitybuilding through service, prayer and education. These endeavors listed above are only a cross section ofthe depth of service that students from Loyola Academy contribute to their community.3EXHIBIT 2- The PIA Review of Loyola Academy conducted by USAC.4EXHIBIT 3- Email Correspondence pertaining to the PIA Review in EXHIBIT 2

(3} The question presented for review, with reference, where appropriate, to the relevant FederalCommunications Commission rule, Commission order, or statutory provision.On May 4th 2012 Loyola Academy received the Universal Service Administratorls Decision on Appeal51.The decision states as follows: Your FCC Form 471 application included costs for the following ineligible products and/orservices: Blackbaud web hosting. FCC rules provide that funding may be approved only for eligible products and services. FCCrules further require that if 30% or more of the applicanfs funding request includes ineligibleproducts and/or services] then the funding request must be denied] otherwise the fundingrequest will be reduced accordingly.The 30% rule subsection of Step 5 of the Application Review section of the Schools and LibrariesProgram of the USAC website states: If USAC finds during application review that an applicant hasincluded ineligible products and services in an FRN 1 USAC will contact the applicant to determine theexact cost associated with the ineligible items. The applicant can request that USAC either: 1) Removethe ineligible items from the FRN or 2) Create a new FRN and move the ineligible items from the originalFRN to the new FRN. If the applicant does not respond] USAC will remove the ineligible items from thefunding request.6The FCCs Aiken County Public Schools Order directed USAC to permit the applicant 15 calendar daysfrom the date of receipt of notice in writing by USAC to revise its funding request to remove theineligible services or allow the applicant to provide additional documentation to show why the servicesare eligible.5EXHIBIT 5- The decision from USAC on Loyola Academis original appeal released May 4th 2012.6Aiken County Public Schools Aiken File No. SLD-397612 FCC 07-611