PIA black box

So I was reading a new appeal from the Baltimore Public Schools, and it got my goat. In a nutshell, BPS had their discount level slashed and lost $10 million in Priority Two funding.

PIA is like a black box. USAC and the FCC keep 700 pages of PIA procedures secret. And it is clear that PIA reviewers are taught to collect information, but not to answer any questions. Also, PIA questions are all oblique, which cause unwary applicants to give the wrong answers. A couple of examples:
PIA says:
"Please confirm the SPIN for this FRN."
What it means:
"The vendor that you gave us is not an Eligible Telecommunications Provider, and this FRN's Category of Service is Telecommunications Service. You're going to lose funding if you don't either change the SPIN, change the Category of Service, or get the service provider to become an ETP."

PIA says:
"Please confirm the establishing 470 for this FRN."
What it means:
"Either you didn't wait 28 days to award a contract and file the 471, or the 470 doesn't include the Category of Service for this FRN. You're going to lose funding if you don't change the Category of Service or find a different 470 to use."

And if you give some information that is going to result in a funding reduction or denial, PIA doesn't warn you. In the case mentioned above, the first that BPS heard that their discount level was being slashed was in the FCDL. Most denials come as a surprise to applicants.

That made sense back in the bad old days; the FCC almost always upheld denials, so it was cheaper for Solix to deny rather than explain. Now, though, with every appeal being remanded, it would be cheaper for Solix to avoid appeals by telling applicants that they are about to be denied, and what they can do about it. It would also save USAC time, since these days I appeal to USAC just so I can get some more information about why an FRN was denied. Finally, it would save the FCC money by cutting down on the number of appeals. It would also save much time and pain for applicants, too, but that's not nearly so persuasive.

PIA is like the "black box" my physics teacher talked about. You can't see what's inside the box. You can only send things in, watch where they come out, and deduce what is inside the box based on the pattern of outputs. I love a good puzzle, so I'm always looking for the patterns of output from PIA, and I have been able to deduce a number of procedures.

But pity the poor applicant, who only gets to send one application into the black box every year. For them, the output seems random. Worse, since the rules change every year, some applicant can give the same input for 5 years and get a different output in the 6th year. And this is no academic exercise: in the case of BPS, $10 million was lost.

C'mon, FCC, open the black box. Or at least whittle down the secret rules to 100 pages or so. It will save time for Solix, USAC and the FCC, and make the process much less intimidating for applicants.