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Friday, May 25, 2007

Sterilize imperfections!

Remember the Star Trek episode where the NOMAD probe sent from Earth gets damaged, then melds with the alien probe Tan Ru and becomes super-powered and thinks it has to sterilize all imperfections (which includes all life forms except William Shatner)? I'm starting to feel that way about COMADs.

I can absolutely see the need for a COMAD when an audit shows that an applicant engages in waste, fraud or abuse. I'm not so sure about the need for a COMAD for cases where an audit shows a clerical error resulted in an applicant getting too much funding, but I can see where USAC doesn't have much choice.

But at some point, COMADs went bad. USAC is now going back to find apparent rule violations, and then COMADing them. They're not limiting themselves to waste, fraud or abuse, they're going back to find ministerial errors and COMADing them. And some of the ones I've seen are not even completely clear rule violations.

We don't have Cap'n Kirk to befuddle COMADs into self-destructing, as he did with NOMAD. However, I think Bishop Perry may enable us to befuddle COMADs and beam them off our ships. I just got an email from the SLD saying that they intended to reduce the funding from a client's 2005-2006 FRN because they have retroactively found some ineligible services in there, and giving me 15 days to respond. They even list exactly which charges are ineligible. Could it be that COMADs will no longer be lightning bolts out of a blue sky?

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