BEN hurts

Could we stop using the word "entity"and the acronym "BEN"? It all started when the SLD assigned Billed Entity Numbers to buildings. Wrong. School and library buildings are not billed entities, and billed entities are not buildings. Billed entities are usually associated with an address (the central office), but any billed entity can have multiple buildings.

It's like treating "company" and "office" as synonyms. IBM is a company with many offices. The individual offices are not companies. And IBM is not an office, it is a company. USAC is a company with one office. But USAC is not an office, and "2000 L Street, N.W., Suite 200" is not a company.

Now there seems to be some sort of kludgy distinction between "entity" and "billed entity," but it causes confusion. Here's how to clear it up.

First, don't call buildings "entities." Since two buildings on the same campus can be counted as one location, let's use the term "location" to describe buildings. Every location gets a Location Code. The simplest thing would be to use the current BEN. (The database administrator in me would prefer that all the codes be the same length, but applicants are familiar with their BENs.)

Second, don't call organizations "billed entities." Call them organizations. Every organization gets an Organization Code. You could use the BEN, but I think it would be better to use the FCCRN, because right now BENs can denote both a location and an organization (there is often not a separate BEN for the main branch of a library system).

To clear things up, the SLD should delete all the duplicate FCCRNs that were created when the SLD told us all we had to get an FCCRN for each school, which is not really possible, because FCCRNs can only be assigned to organizations. So what really happened was that applicants created duplicate FCCRNs with different addresses. By the way, the FCCRN mess was created because when the FCC said that all "entities" must have FCCRNs, the SLD misunderstood and thought that all locations (which are still called "entities" and are assigned a Billed Entity Number) needed FCCRNs.

Then when you apply, the FCCRN is used everywhere except Block 4 of the 471, and the Location Code is used in Block 4. Clear. Terminology matters.

Admittedly, it's an inconvenience for applicants with only one location, because they would have two IDs to keep track of. But with a little improvement to the online 471, the Location Code would autofill for such applicants. [Say, why doesn't Block 4 autofill now? Yeah, we might have to do some editing, but for 90% of applications, the work would be done.]

It's a major overhaul, but if they started now....