Goose sauce seems de minimis

OK, not the most interesting appeal decision: the FCC concludes that applicants were not using equipment that E-Rate paid for.  But E-Rate geek that I am, I had to take a gander at the appeals.  And one of the appeals jumped out at me, not because I thought the appellant had a good case, but because of the amount to be recovered: $388!

I ranted about this before: how is $388 not de minimis?  An applicant makes a mistake (which is later corrected), but they either pony up $388 or get the Red Light treatment.  How is that cost-effective?  Just the USAC review of the audit cost more than $388.  The appeal to USAC cost more than $388.  The appeal to the FCC cost more than $388.  And I'm only talking about the cost to USAC and the FCC, not the poor applicant.  The de minimis standard should be at least $1,000.

As I pointed out, USAC states the de minimis standard for USF contributors is $10,000. (You'd prefer the FCC regulation? Here it is.)  That $10,000 is not about forgiving errors.  If a company would have to contribute less than $10,000, they don't even have to fill out the form to show that they don't need to make a payment (except VoIP carriers for some reason).  Sauce for service providers: $10,000.  Sauce for applicants: $388.

And while I'm whining, how come I know the de minimis standard for contributors, but the standard for audit victims is kept secret?

And of course I'm going to take it a step further, beyond audit recovery.  If contributors can just blow off filing if they owe less than $10,000, how about setting a de minimis standard that says applicants don't have to go through the whole application process for requests less than $10,000?  They could just fill out an online form with three blanks: BEN, discount percentage and total pre-discount expenses.  (What about Block 4?  For those few applicants who have more than one location and are requesting less than $10,000, just let them use BEN-wide totals, OK?)  USAC sets a funding cap for that applicant.  Then when the invoices come in, USAC can review the discount percentage and check to make sure the services are eligible (which they do at invoicing anyway, sometimes overruling the PIA decision).

Listen to John Lennon sing it:

Imagine there's no 470s
And no 471s, too
Nothing to file SPIN changes for
And no Item 21 attachments, too. 

Imagine tiny applicants
Filling out tiny applications. 

You may say I'm a dreamer....

OK, so the syllables don't fit into the melody.  I think the difference is de minimis.