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Saturday, September 01, 2007

Cloak and dagger

Here's an appeal that burns my butt: a school district files two 470s, picks the wrong one for one of its FRNs, and gets denied.

This district lost funding because PIA clings to secrecy, whether it's warranted or not. The PIA reviewer did ask the district to confirm the establishing 470. (Those of us who do this for a living know that if you are asked to confirm anything, you're about to lose funding.) The unsuspecting applicant made the same mistake twice, and confirmed the wrong 470. Denied.

How should this have happened? The PIA reviewer should have said, "Your establishing 470 doesn't have this service listed. Either give me another 470 number or you'll lose funding." It would have saved everyone a lot of time, effort and heartburn, because you know the FCC is going to remand this one.

Why the secrecy? What could the applicant have done, knowing that the 470 was wrong? I cannot imagine a way for the applicant to use that information to defraud the program.

You want to know what great customer service would have been in this case? The PIA reviewer has access to the 470s filed by that applicant. S/he could have looked it up and said, "It looks like you picked the wrong 470 for this FRN. Did you mean to pick this other one? If you switch now, everything will be fine. If you don't switch, you'll lose funding."

Why do I hear John Lennon singing "Imagine" in my head?

The secrecy is creating a lot of waste. OK, I can see why PIA doesn't want to release, say, the algorithm it uses to select applicants for Selective Review; people would take steps to avoid being selected by the algorithm. (Of course, if you built a solid algorithm, it would serve as a deterrent to waste, fraud and abuse; people would avoid Selective Review by not being greedy, having service providers "help" file the 470, etc.) But it is just ludicrous that PIA reviewers don't say anything to applicants other than canned requests for information.

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