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Friday, October 12, 2012

Couldn't happen to a nicer bunch

USAC is calling another audit down on their own heads.  Funds for Learning spotted a USAC RFP for a "risk assessment" audit.  Of course I'm ill-equipped to perform the audit, but I'm happy to supply some of the requested assessments for free.  The list of assessments starts on page 3, and there are 16.  I'll only cherry-pick ones that I can answer without doing any actual work.
(3) Consider the effectiveness of USAC’s E-rate Program procedures in detecting the most significant problems identified in recent E-rate audits....
OK, see now there's a problem right there.  The most significant problems are not identified in audits.  The most significant problems are the ones that put people in jail.  Those are the risks the auditor should be focused on.  The fact that an applicant couldn't find a document proving that the Internet Safety Policy was approved at a public meeting 10 years ago is just stupid compared to a service provider and an applicant employee combining to steal $5 million from the program.
(4) Evaluate GAO’s statement that “[t]he E-rate program’s internal control structure is a product of accretion...."
After careful evaluation, I have reached the following conclusion:  No duh.
(6) Provide specific recommendations on how the application review process might be streamlined....
Here are some recommendations off the top of my head:
  1. If you're a public school or library, and the FRN is less than $3,000, PIA review is: nothing.  Approved.  Boom, there goes PIA for half of the FRNs.
  2. Cost-effectiveness reviews are just pointless harassment.  Toss them.
  3. Toss the 470 and the whole competitive-bidding charade.  It hampers competition and drives up prices.
  4. Don't require contracts before the 471 is filed.  It hampers competition and drives up prices.  And oh yeah, it's illegal.
  5. Publish the secret 700-page tome of PIA procedures.  Let everyone know what the rules are, and we'll all follow them.
  6. If you want third-party verification of NSLP numbers, get them from a third party.  Just sayin'.
  7. Every piece of information required to approve funding should be a part of the Form 471.  No attachments, clarifications, etc.  PIA gets the 471, and based on the information collected there, makes a decision.  Yeah, the 471 would have to be ginormous to provide all the information that PIA wants under current procedures, but that's kind of the point.  Force the ridiculous complexity of this program out into the open.  Imagine if the IRA looked over your tax return and said, "Hey, I see you claimed travel to your doctor as a deduction.  Could you send us a list of those trips and any other stops you might have made on the way?"  That's what audits are for.
  8. Stop sending out those useless, yet frightening Notification of Form 470 Posted but No Associated Form 471 letters.
  9. If you have a beef with a service provider, audit them.  Don't force every applicant to back up every invoice with a slew of bills and/or a service certification month after month.
  10. PIA should be required to tell applicants if they're about to lose funding.
(8) Evaluate whether ... audits of service providers, rather than just applicants, should be conducted.
And the answer is: Yup.  Name one case of waste, fraud or abuse that took place without the complicity of some service provider.
(13) ... evaluate whether the computer systems USAC has adopted for inputting and processing applications and invoices is both reliable and sufficiently flexible to incorporate E-rate Program changes promptly and efficiently.
Was it 2009 when Mel said that the entire system was going to be overhauled, which would allow for all sorts of improvements?  Since then, it's been patch, patch, patch.  How many trees died this month to send out duplicate 486 notices?  And we just got a Receipt Notification Letter for a 470 posted 63 days ago.
I'm ever the optimist (stop snickering), so I'm hoping that this audit will provide the grounds for real improvement.  But since it's a one-year contract, I won't hold my breath.
On a tangent completely unrelated to E-Rate, who decided to name a candy bar "Snickers."  I mean, naming your confection after a snide laugh?  OK, Nabisco had already released "Chuckles," but "Giggles" or even "Chortles" or "Titters" would have been better than "Snickers."

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