SLD no haberdasher

It seems that the SLD is not doing so well selling HATS. For those of you that don't know, this is the SLD's new outreach campaign, where reviewers come out and try to help applicants which have had trouble getting funding. A wonderful idea.

But at the last board meeting, apparently Mel Blackwell mentioned that about 40% of applicants contacted don't want the help, because they're afraid that it's actually an audit. Now why would that be? Could it be because the HATS visits are conducted by BearingPoint, which also runs the Extended Outreach Site Visits? Both SLD and BearingPoint tooks pains to declare that EOSVs were not audits, but one component of the EOSVs was an investigation of compliance. That's an audit. So now the SLD is sending out BearingPoint again, and again saying it's not an audit, and for some reason, applicants are dubious. Keep in mind that to be considered for the program, the applicants have to have gotten repeatedly burned by the E-Rate program.

If I were an applicant, I wouldn't be eager for a HATS visit, either, for two reasons:

1. I don't always get the right answers from the SLD (though this is constantly approving), so now I'm going to trust the advice of some consultants hired by the SLD who have never worked in a school district or filed an application?
2. The premise of the HATS program seems to be that certain applicants run into a problem when applying, and if we can fix that problem, they'll get funded every year. In my experience, applicants don't make the same mistake twice. Applicants that get denied year after year run into a new problem every year, because there are so many rules in this program, and they are scattered in so many places, and most of them are secret. HATSpeople will have to anticipate next year's error(s).

I do this full time, I spend probably 10 hours a week keeping up on rules and rule changes and rule interpretations, and every time I hit the "Submit" button, I still worry that I'll get tripped up by something stupid. So I'm not sanguine about the ability of BearingPoint employees to anticipate applicants' errors. Still, I suppose any help is better than none.

If the SLD wants to sell HATS, they should use On-Tech's slogan: E-Rate Funding - Guaranteed. Get the FCC FCC to pay someone (preferably not a company that also does audits) to come in and assist the applicant, and then guarantee that the applicant will receive full funding that year for all requests. (Except Priority Two for low-discount applicants, of course.) Applicants would be clamoring to get in.

Don't get me wrong; I think that the HATS program is a positive development. I'm just not surprised that applicants don't want in.