Search This Blog

Thursday, October 26, 2006

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.

No comments:

Post a Comment