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Wednesday, October 03, 2012

My minimis is bigger than yours

Now this is a step in the right direction.  Actually, it's a giant, jet-assisted leap in the right direction.  Or maybe it's a typo.

Every 6 months, USAC releases a report on audits of the E-Rate program.  If I have a little spare time, I read the whole report, but today I just skipped straight to spreadsheet attached to the report, so I could start grinding my teeth right away.  I've whined again and again about the niggling little amounts that USAC goes out and collects from applicants.  USAC is not supposed to collect if the administrative cost is greater than the amount to be recovered (per the Fifth Report and Order).  Now I have no doubt that the good people at USAC are underpaid, but there is no way that a collection costs less than $276, which is the smallest amount I can see on this report that USAC is trying to collect.

But what's this under 2005?  It looks like 9 applicants were given de minimis exemptions totalling $164,639.  So that means that at least one of those applicants is getting a de minimis exemption for an amount greater than $18,293.  For 2006, the de minimis amount must be at least $2,883 for some lucky applicant.  (For the rest of the years, the de minimis cutoff could be less than $300.  Because USAC only publishes totals for each funding year, there's no way to say what the actual de minimis amount is, only the lowest amount it could be.)

But wait, there is some other applicant in the 2005 column in the early stages of collection for $7,465, and 2006 has the $276 collection I whined about earlier.  That means it is mathematically impossible for the same de minimis standard to have been applied to all applicants in those funding years.

Why am I reading tea leaves on this?  Why isn't the de minimis amount published?  Like maybe in the semi-annual report.  And while they're at it, they could explain where in the recovery process de minimis determinations are made.

But I guess besides me, interest from the public is de minimis.

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