Anyone who reads the comments I make to the FCC at every NPRM and Eligible Services List comment period about the "internal controls" that the SLD uses in processing applications knows that I hate them. Not only do they cause widespread fear, but they also promote waste, fraud and abuse: if the applicants could see all the rules, they'd know that some of the things they're doing aren't allowed. If they knew the secret "brightlines" that trigger an audit or Selective Review, they would keep their requests reasonable.
Well, I've never gotten a peek at those guidelines, but I did recently learn the size: 700 pages. That's right, seven hundred pages of rules that no one can see.
Here's a real ugly way to think about it: most of the rules in the E-Rate program are secret.
So in addition to following the rules contained in hundreds of pages of information spread all over the USAC and FCC sites, applicants also have to abide by 700 pages of rules that they can't even get a peek at.
I shouldn't complain: some of my clients came to me after they got blindsided by a secret rule, threw up their hands, and hired a consultant. And since I have handled so many applications for so many years, I have been able to discern many of the secret rules. So 700 pages of secret rules is very good for those of us in the consultant business. But 700 pages of secret rules is not good for schools and libraries, and aren't they what the program is all about?
So I was looking at the agenda for the USAC board's public meeting in April. There were 14 agenda items (not counting "miscellaneous"). Of those:
ReplyDelete6 had "Executive Session Recommended"
4 had "Executive Session Option"
4 were public
I don't want to make too much of it, since, for example, if I were being audited, I wouldn't want info on that to be published until the audit was complete. Also, the minutes have not been published, so I don't know which items went into executive session. But it is disconcerting that more than 70% of the items seem to have been discussed behind closed doors.