Esta fuente no se SECA

SECA is at it again. They've sent the FCC another batch of good ideas. Here's a list. Of course I'm going to editorialize.

1. Direct reimbursement to applicants: Hell, yeah! But SECA neglects to mention the real reason that this hasn't happened yet: Currently, USAC sends electronic payments to hundreds of service providers, but if they reimburse applicants directly, suddenly they'll be printing and mailing checks to thousands of applicants. At the beginning of November, they'd need one big honking printer. And I shudder to think what address they'd send the checks to. Look for hundreds of missing checks each year.
2. Automatic Deadline Extensions for $0-Funded Invoices: OK, that would be nice.
3. Problem Resolution Outreach to Correct BEAR Error: Yup. I get that USAC wants to process all invoices within 30 days, but surely they could ask for a little info before pushing the "pass zero" button. And applicants weren't clamoring for quicker payment on BEARs; service providers were clamoring for quicker payment on SPIs. So do problem resolution on BEARs, not SPIs.
4. Enhance online BEAR: Yes to all those changes, especially the ability to go back and alter a BEAR after submitting but before service provider certification. I can't tell you the number of times that the service provider has a different total than I do, and I have to redo the BEAR over a few cents.
5. Applicants should be told when the invoicing deadline has passed and be given a second chance to invoice: Now that is a good suggestion that I had not heard before. It would be consistent with what USAC does for 471s and 486s.
6. Top discount percentage should be 75%: Yes! Yes! Yes! I've always thought that the 90% discount was too high for Priority Two. Now I'm starting to think it's too high for Priority One.
7. An applicant portal, creating "a virtually paperless E-rate application process": Oh, yeah. If they could really normalize the database, where you could put services on the 470, then when you make the Item 21 Attachment, you get to choose from things you put on the 470, then Block 5 of the 471 is filled in based on the Item 21 Attachment, and on the BEAR you can associate charges with items in the Item 21 Attachment. Something needs to be done about the creaky USAC codebase. I enjoy the quirks in the current system more than most people, but I'd trade it for some more reliability.
8. Comprehensive Requirements Manual: Oh, yes. Way back at my first Train-the-Trainer (in 2001, I think), they asked for suggestions for improving the program, and this was at the top of my list. Aside from the obvious benefit of making it easier for applicants to access program rules, the creation of a rulebook would: 1) show just how massive and complex the rules are for this program; and 2) show how quickly the rules shift in this program. It would be a powerful impetus to simplify the rules and to change them only quarterly, instead of the current practice of making changes whenever we feel like it.
9. Remove Funding Year from the Form 470: I've already said that this should be done.
10. On 470, remove distinction between Telecom Services and Internet Access, and between Internal Connections and Basic Maintenance: No, unless the distinction also disappears from the Eligible Services List. Having 4 categories in 2 priorities seems to add complexity, but really it just reveals the complexity that is there. I'm all for having the ridiculous complexity of this program in everybody's face. Because when you try to hide the complexity, the applicants suffer.

I've always thought SECA was a little snooty, sitting off by themselves at the DC training every year, but now I think they're heroes. A couple more of these salvos of common sense, and I'll have to start a fan club.