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Tuesday, July 11, 2006

"Clerical and ministerial"

So the SLD has come out with it list of clerical and ministerial errors required by the Bishop Perry Order. Because I never make errors, it doesn't apply to me, so I didn't read it too closely. The only changes that jumped out at me:
  1. Now when you get the 471 RAL, you'll only have 15 days to make corrections; you used to have 3 weeks.
  2. You can now make corrections to Block 4 (discount calculation) or Block 5 (description of services) that will increase the amount of funding requested; it used to be you could make changes only if they kept the funding the same.

If you file the 471 on paper close to the deadline, the option to correct errors that used to be called Minimum Processing Standards is wonderful, but no one should be filing on paper.

The ability to certify after the deadline is nice for people who forget, but I find myself certifying everything online, so again it doesn't help me.

No word from the SLD yet on the "expanded outreach" requirement of the order. Here are some suggestions I'll make if anyone asks me:

  1. For each billed entity that files a 470, check to see if the 470 includes Telecommunication Services and Internet access. If not, send them a note. If the 470 were better (with standardized services choices instead of text boxes), the SLD would be able to ensure that basic phone service and ISP charges are on there. But don't get me started on the inadequacies of Block 2 of the 470.
  2. At 45 days before the end of the filing window, warn each billed entity that hasn't filed a 470 that time is running out. Of course, this will be difficult since the SLD database isn't clear on the difference between billed entities and locations.
  3. For each billed entity that files a 470, send a warning when the 471 deadline is approaching if they haven't filed 471s covering the categories requested on the 470.
  4. Warn applicants when the 486 deadline is approaching (I think we will see this requirement in an FCC order soon, since it was in the Bishop Perry order by mistake, before being struck by an Erratum notice).
  5. Six months into the year, check to see if applicants are billing on all their FRNs, and if not, send a reminder.
  6. 60 days after the end of the funding year, check to see if applicants are billing on all their FRNs, and if not, send a warning about the approaching deadline.
  7. Send quarterly (or at least annual) funding reports to all billed entities. The report should summarize funding for the last 3 years (for a quarterly report) or since the beginning of the program (for an annual report). If a billed entity didn't get funding in one of those years, make sure to show those zeros.
  8. Do more trainings. What is planned now, 6 trainings, 200 people each? Not enough. Maybe if all the trainings were Webcast.... Record the Q&A sessions from all the trainings, and make the recordings available on the Web.

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