Death of the 30% rule?

Check this out from page 22 of the Eligible Services List, under the "Cost Allocation" entry: "When no cost allocation is provided for funding requests that require cost allocation, USAC will contact the applicant to request such cost allocation."

That seems to fly in the face of the 30% Rule, which says that if USAC finds that ineligible services make up more than 30% of a funding request, the whole request is denied. This ESL says that if USAC finds any ineligible services, they have to contact the applicant and request cost allocation.

Good riddance, I say. Whenever I do presentations and I explain the 30% Rule, attendees' reactions range from disbelief to outrage. Just because you made a mistake and included something that's not eligible, you lose all your funding, for eligible and ineligible items?

And don't give me the "administrative convenience" argument. OK, I agree that it would be heinous if applicants just starting throwing everything including the kitchen sink onto a 471, and made the SLD sort it out, but really, are applicants going to do that? And what's to stop them from putting the kitchen sink in its own FRN? The 30% Rule only hurts innocent applicants who have no idea they're requesting ineligible items.

And it doesn't save the SLD any work. How does a PIA reviewer invoke the 30% Rule? By calculating the cost of the ineligible services. Since s/he has already figured out the value of the ineligible items, it is not really any extra work to just reduce the funding request.

Now if we could just get rid of the "2-in-5" rule.

ESL at last

So the Eligible Services List is out at last. The FCC did some good things.

First, VoIP is eligible. Now schools can get E-Rate funding for Vonage. Actually, what seems more likely to me is schools getting local service with no message units through their ISP.

Blackberries are eligible. Now districts can rethink their wireless plans, since they can now get E-Rate funding for wireless Internet service for their mobile devices.

Web hosting looks to be more restricted. The new list seems to be much more restrictive on what's allowed as Web hosting. An entire industry has popped up to provide value-added Web hosting to schools, and the E-Rate has helped. If the definition of Web hosting is narrowed, look for that industry to implode.

More tomorrow.

Where's the color?

Let me start by saying that I hope the SLD employee that came up with the idea of a different color paper for each program year got a big, fat raise for that brainstorm. And I hope the employee who decided that white should be one of the colors got a reprimand.

So lately all the correspondence from the SLD has been on colored paper, but in a white envelope. Don't like it. For starters, it's aesthetically upleasing to have the yellow paper peeking through the windows of a white envelope. And it was nice to be able to glance at a stack of mail and see if there was something from the SLD.

I'm holding out hope that they decided to take white paper out of the color rotation, so now they're using up all the white envelopes that were lying around.

I think I need some more leisure time. It scares me a little that I'm even thinking about envelope color and what it might mean. I guess after all these years, I just reflexively try to guess what the SLD is up to.

While we're on the subject of correspondence from the SLD, I have two things to say: white space and fonts. The SLD letters are dense blocks of courier type, with no variation of font size. As part of Mel Blackwell's drive to make the correspondence more user-friendly, I hope they have someone with layout experience look at the letters. They need to go to a proportional font (like Times), leave more empty space on the page, and use different font sizes to create section headers. But please, no clip art, no matter what the layout experts say.

More outreach

The SLD is piloting a new outreach program. So far, they’ve only visited two districts, and one of my clients happened to be the second one.

In the pilot phase, they are looking at applicants who had trouble getting funded for a couple of years, then did get funded, and asking them what turned the program around for them. It was a big team: three SLD staffers, two reviewers from BearingPoint, and one other guy whose title I didn't catch, but I think was also from BearingPoint.

There was no investigation of compliance, no documentation required, just questions about what was difficult for the applicant, and how they managed to turn the process around, and what could the SLD do to improve the process. They wanted to talk to anyone in the district who had been or is currently involved in the E-Rate application process. The interview was pretty unstructured (again, perhaps because it was a pilot).

I hope this will turn into a full-blown outreach program, because it looks like it has nothing but an upside for applicants. My understanding is that it will expand to districts that are currently having trouble, so the SLD can help them directly. Excellent news for districts having trouble, but perhaps not so great for those of us who make our living helping districts that are having trouble.