Caveat applicant

Recently a client was caught in the mass COMADing of all FRNs for a Web hosting product called TeacherWeb. I don't see anything about TeacherWeb that doesn't meet the definition of Web hosting in the Eligible Services List, but I've never used the product, and the definition of Web hosting is vague (as I have pointed out during ESL comment periods).

This blog entry is complaining about a general practice in the E-Rate program. If a vendor assures an applicant that a service is eligible, and the SLD agrees it is eligible and approves the funding, if the SLD later changes its mind, the applicant has to pay. Granted, the applicant is really just returning funding improperly received, but it sets up a situation which promotes abuse. Several vendors have deceived the applicant and the SLD by mischaracterizing their product to squeeze it into eligibility. If they can squeeze it past PIA, it doesn't matter to them if the product is later found ineligible, because they've made the sale. The applicant, which relied on the expertise of the vendor and the SLD, is left holding the bag.

A couple of years back at a "train-the-trainer" session, when we were talking about the Eligible Products Database, I asked this question: If a service provider states that it's product is eligible and submits it for the database, and the SLD reviews it and posts it on their Web site, and it's later determined that the product is not eligible, who will pay? The answer: the applicant.

Applicants have no way of knowing whether a product is eligible. The FCC approving the ESL every year is a start. How about the FCC approving the Eligible Products Database?

Of course, I shouldn't be complaining. The complexity, changes and uncertainty in eligibility are a big factor in the growing demand for my services.