Undetectable errors

I took a couple of days off last week, so I'm just now reading the latest PIA requests. Since Aug. 11, there is a new section in the boilerplate. It says: "The following items on your Form 471 may contain errors, but we were unable to detect them during our review process:" and then lists all the areas on the Form 471 that might result in denial, and finishes with: "If you detect any errors in these items, you can make corrections during the next 15 days."

When I read the FCC's instructions in the Bishop Perry Order, I wondered: "How is USAC going to do that?" I guess this is the answer. I'm worried that USAC thinks that by listing all the important areas in the application, it is off the hook to later let applicants know if they discover a problem. I think that's wrong.

The spirit of Bishop Perry, it seems to me, is this: USAC shouldn't deny applications without telling the applicant that they are about to deny the application, then giving the applicant 15 days to fix whatever problem there is. I've told anyone who would listen that USAC should operate that way to reduce appeals and delays. Just tell people flat out: "On [date] we intend to deny your application for the following reason: .... If you don't want to be denied, please do the following: ...."

For the serious E-Rate wonks, there are some tea leaves here. Block 2 is left off the list of places to look for undetectable errors, which is the closest I've heard USAC come to acknowledging that the numbers in Block 2 are of no importance in getting an application approved.

On the other hand, "Block 6 – Amount budgeted for ineligible services" is on the list. When that onerous and meaningless* requirement was added to Block 6, I asked point blank at the "Train-the-Trainer" if any applications were going to be denied based on the number entered, and the answer was no. I guess now maybe the answer is yes.

*Tirade alert! Yes, the Item 25 number is meaningless because there is no way to calculate it accurately:

1. The instructions are vague. "The resources that are necessary for you to support and improve education and library services and to make effective use of the eligible services"? What does that mean? Does "Professional Development" include in-service days on subjects like the district's new IEP system, which is not itself eligible, but which runs over the Internet? Does a district include the cost of the staff salaries for that day?
2. How do I know what's "necessary"? You'd be crazy to run a network without anti-spam and anti-virus, but the FCC keeps them off the Eligible Services List, so are they "necessary"?
3. Districts don't track expenses according to their E-Ratability. Who knows how much of the electricians' time was spent installing and maintaining circuits that were required "to make effective use of the eligible services"? (You could drive yourself crazy: should you count the cost of removing asbestos in order to punch through the wall so that you can install an electric circuit to run air conditioning in computer labs to keep ineligible desktops from frying, because those ineligible desktops are necessary to access the Internet?)