New forms a-comin'

What's this new news item on the SLD home page? New versions of all the forms (except the 470 and 471)?! Oh, it's just "slight modifications," which, of course means more certifications. If this trend continues, I'll have to find a new job when some new certification includes the phrase "first-born child."

The FCC is accepting comments, though, and that's hard to resist. (Anyone who would start a blog on something as boring as the E-Rate must have a very high opinion of his own opinions.) So here's my suggestion: dump the 486.

But what about the CIPA certs? Move them to the BEAR and SPI. Of course that would mean that applicants would have to certify the SPI (just as service providers have to certify the BEAR), which would be a prudent measure to prevent waste, fraud and abuse. Think about it: public servants who submit a BEAR requesting reimbursement to a public entity (which has been approved by the state DOE or State Library) have to get their request approved by the service provider, but any company can submit a SPI, and they get funding, no questions asked.

And yes, this has created fraud. Qasim and Haider Bokhari are both on the Debarment list, an elite club of 10 people (like the FBI Most Wanted, only more boring). For those of us who like to create meaningless statistics, fully 20% of convictions for E-Rate fraud could have been prevented by having applicants counter-sign the SPI. (Assuming that anyone actually read those forms, which is a bad assumption.)

However, I'm not sure I can bring myself to propose something that will increase the paperwork for applicants, and delay the invoicing process. So maybe we move the CIPA certifications to the 471, where they wouldn't even be noticed among the 14 or so certifications that are already on that form.

Word to the wise: don't put the draft forms on the Required Forms page next to the real ones. You just know a few confused people are going to use them (meticulously whiting out the "DRAFT" watermark), then the SLD is going to be forced to deny them, and the appeal will go to the FCC, which will whip out its "waived" rubber stamp and remand it, then the SLD will approve it, only now it's six months after the funding year is over and nobody's happy.