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Thursday, October 01, 2015

The view from the top

If you're big enough E-Rate geek to read this blog, you've certainly seen Mel Blackwell's Letter to the Field.  I think that, as usual, he strikes a pretty good balance between being positive and being frank.

While he notes that USAC very nearly hits its goal of processing all the "workable" apps by Sept. 24th (well, there was a big batch of FCDLs that came out Sept. 25th, but that's close enough for government work), he does note that 6,000 applications are "unworkable," and expects that most will be processed within 90 days.  "Most" means at least 3,000, so it's possible that close to 3,000 applications will be languishing 90 days from now, which is half-way through the funding year.  And Mel admits that the remaining applications tend to be larger than average.

What is "workable" anyway?  The E-Rate Modernization Order gives us this definition:
“Workable” means that a funding request is filed timely and is complete, with all necessary information, to enable a reviewer to make the appropriate funding decision, and the applicant, provider, and any consultants are not subject to investigation, audit, or other similar reason for delay in a funding decision. Funding requests from applicants that decline to respond to USAC inquiries over the summer may be considered “unworkable” for purposes of this performance goal, though USAC will process these applications as quickly as possible when school staff return for the year. 
Doesn't "...with all necessary information, to enable a reviewer to make the appropriate funding decision..." exclude most applications?  It would seem that if PIA needs to request information from the applicant, the application is unworkable.  Unless they streamline PIA procedures dramatically, most applicants will have to supply additional information to PIA, in part because even though the Form 471 is more detailed than it used to be, it still does not collect all the information that PIA needs.  It seems to me that if the Form 471 doesn't collect the necessary information to allow 6,000 applications to be processed, the form has some serious shortcomings.

But back to the letter.  We get promises about how much better EPC will make our lives, but also acknowledgement that the roll-out has not been flawless.  I particularly appreciate Mel saying, " the accelerated timing of the deployment did not allow for adequate user testing."  I think that more could have been done to bring the applicant and service provider community into planning meetings, but I guess they can't let anyone look behind that curtain, since the FCC considers the application process to be a law enforcement activity whose workings need to be kept secret from the public (and the people going through the process).

But here's some good news: "We are committed to...user testing for the new EPC-based FCC Form 471 filing process."  Where do I sign up?

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