FCC filings from the Bizarro World

So here's a little slugfest that's right out of the Bizarro world. (For those of you who don't read Superman (or watch Seinfeld), the Bizarro world is an alternate dimension where everything is the opposite: Superman is an ugly bad guy, etc.)

First, the ALA (American Library Asscociation) says that applicants should file invoices, not service providers, and get paid directly from USAC. (Item 13 (page 24) in their NPRM comments.)

I'm completely with them on the "get paid directly" part; if I choose to fill out a BEAR, why do I need to have service provider sign off on it and have the check go through them? When service providers submit an invoice, they don't have to get the applicant to sign off, and checks come directly to them. The rules seem to reflect an attitude that service providers can be trusted, but applicants can't. And to become an applicant, you have to prove that you are a school or library recognized by the state, while to become a service provider, you just have to file a form. (While I'm on this rant, here are some telling numbers: certifications required on a BEAR: 4 applicant, 2 service provider; on the SPI: 0 applicant, 0 service provider.)

But why does the ALA want to do away with discounts on bills? I think we should leave the choice with the applicants. Discounts are a great choice for lots of applicants.

Then (16 months later) AT&T leads a pack of large phone companies into the offices of the FCC to oppose the ALA's proposal to have applicants fill out the invoices, because "the large service providers do not believe that most applicants have the staff necessary to prepare and submit invoices and respond to SLD invoice reviews in a timely fashion." That's bizarre. I mean, these service providers sign off on thousands of BEARs every year. They know damned well that some applicants can handle the work.

So in this bizarro world, the ALA is saying, "make the libraries do all the invoicing work," and the big phone companies are saying, "let us do all the invoicing work."

To make it more bizarro: these are the same service providers who for the first six or seven years of the program claimed they were unable to discount bills. The whole BEAR process only came into being because the service providers said they couldn't manage the invoicing.

The bizarro crown: AT&T to this day requires applicants to manage the invoicing process. When applicants were given the right to choose discounted bills or reimbursements, AT&T filed an appeal, which I think is still pending, saying that it couldn't discount. AT&T does have the ARF system, which will generate a SPI, but the applicants have to do all the work of calculating and entering all the information that will go on the SPI after having paid the bill. As far as I know, AT&T still doesn't discount bills. (How do they get away with that, anyway? The SPI directions make it clear that you can only submit a SPI if you have sent out a discounted invoice. AT&T is using the SPI to allow applicants to apply for reimbursement.)

How did we get in this bizarro world, and why is AT&T raising a stink now, so long after the ALA first proposed the changes? Well, I noticed that some time in Dec. or Jan., AT&T removed the signed BEAR page 4 from their Web site, and started requiring applicants to fax in BEARs for signature. It was a sad day for applicants; up until that time, you could fill out a BEAR, print a copy of the page 4, date it, and send it in. It saved the hassle of faxing back and forth to get the service provider signature. I wonder if someone from the SLD or FCC twisted AT&T's arm, or if some AT&T lawyers noticed that they were certifying forms without looking at them and had a cow.

Since they now handle BEARs like everyone else, AT&T has realized that for recurring services, BEARs are a larger pain than SPIs for responsible service providers. Especially if you set up a system like AT&T's ARF where you have your clients fill out the SPI for you. So now they want the BEAR process to end.

Why do the other service providers want to kill the BEAR? Well, there is the work issue: I think the BEAR process is a little more work than the SPI process, once you have your accounting system set up to discount bills.

But the real issue is the float. It used to be that it tooks months for USAC to process invoices, which meant that service providers who discounted were essentially floating a loan to USAC for the time between the discounted bill and the payment of the SPI. Whereas with the BEAR, the applicant was floating the loan from the time the undiscounted bill was paid until USAC paid the BEAR. (As an added bonus, at least one of the large service providers often takes six weeks to turn around checks that it receives from USAC, which means that USAC is floating a loan to the service provider, which is money floated to USAC from the applicant.) So when it took USAC 3 months or so to process SPIs, service providers who discounted were floating a lot of money.

Now USAC's average invoice processing is less than a month. On-Tech's clients are schools and libraries, and let me tell you, it is very rare that our invoices get paid within a month: first payment of my invoice has to be approved at a board meeting, then the check has to be approved at another meeting. I see a lot of applicant phone bills, and it is routine for them to take over 30 days to pay. I assume that service providers have realized that USAC is actually paying more quickly than schools and libraries. So naturally they would prefer to invoice USAC directly.