Item 21 squeeze play

On the Service Provider conference call this week, I heard that applicants will be required to submit Item 21 Attachments inside the window. Currently, applicants are encouraged to submit Item 21s right away, but you don't actually have to submit them until the application goes into PIA review.

The new rule makes some sense, and it won't be a problem for most applicants, especially since I've got to think that Bishop Perry, patron saint of the procrastinator, will force the USAC to allow Item 21s to come in late, either following a warning letter (like a missing certification) or as part of the RAL process.

It is going to be more problematic for us consultants, who have a lot of Item 21s to do. But I'm not a big believer in shaping rules for the convenience of consultants, so I'll just deal with it.

What bugged me on the call was a small technical matter that isn't changing: you can't begin to create an online Item 21 Attachment until the 471 has been submitted. In my presentations on how to file for the E-Rate, I used to recommend that applicants complete the 471, then do the Item 21s before submitting the 471, because sometimes you catch an error in your 471 while you're doing the Item 21s. I no longer recommend that, since you can't do it if you use the online Item 21s, which I encourage applicants to do.

The inability to work on Item 21s until the 471 is filed provides an incentive to do the Item 21s on paper. And no one wants that.

Taking a systems-design look at it, the inability to file the Item 21s before filing the 471 makes no sense. The Item 21 Attachment is a description of the service received. In theory, that should be known at the time the 470 is filed. OK, the Item 21s also have pricing info, which isn't known until the a service provider is selected. But still, service provider selection takes place before contract completion, so the Item 21 Attachment information is known before some of the other information in Block 5.

If USAC's tools didn't limit us, here is the process I would recommend to people who are filing:

1. When you file your Form 470, go ahead and fill out everything on the Form 471 except Block 5. (Of course, you can't do this unless you file your 470 after the window opens.)
2. Start working on the Item 21s. You'll have to revise some service descriptions after bids come in, and you can't do pricing yet, but get the basics in there.
3. After vendor selection is done, complete Block 5 (except for Contract Award Date).
4. Complete the Item 21 Attachments.
5. After contracts are signed, complete Block 5.
6. Review and submit the Item 21 Attachments.
7. Review and submit the Form 471.

While I'm on the subject, here are some previous rants about the Item 21s:

1. Fix the stupid thing where you have to select the type of service before you can import dollars from the 471, which erases the type of service so you have to select it again.
2. Last year, Mel predicted that Item 21s would be publicly visible. What happened to that?
3. Make the online Item 21 collect all the info that PIA needs.
4. Why do I have to file a new Item 21 if nothing has changed from last year?
5. At least give me an "import last year's Item 21" button.
6. Harmonize the Item 21, which only allows one-time charges for BMIC, with the 471, which only allows recurring charges.

And that's all I have to say about that.